An Overview of Used Oil and EPR Registration for Used Oil
Used oil can come from many sources, including engine oil, gear oil, hydraulic oil, and petroleum-based or synthetic oils that have been used and are suitable for reprocessing. If used oil is not recycled, it can become a huge threat to the environment. To tackle this problem, India's Ministry of Environment, Forest and Climate Change has made EPR (Extended Producer Responsibility) registration mandatory for used oil under Rule 3 of the Hazardous Waste Management Rules, 2016. Waste oil producers, collection agents, recyclers and importers can now obtain EPR certification for used oil through an online registration process with the Central Pollution Control Board (CPCB).
Role of EPR Registration for Used Oil
The Government of India aims to ensure better management of used oil and assist in the regulation of related stakeholders through EPR (Extended Producer Responsibility) registration for used oil. This is the fifth EPR (Extended Producer Responsibility) policy for used oil in India after various types of waste such as e-waste, plastic waste, tyre waste and battery waste. The main objective of this policy is to promote effective management of used oil, protect the environment and meet sustainable development and economic goals. Under this, all stakeholders including producers, recyclers, collection agents and importers of used oil are required to follow strict EPR guidelines for its disposal and recycling.
Entities Required EPR Registration for Waste Oil
If you are engaged in the sale of base oil or lubricating oil, or the manufacture, production, or import of industrial waste oil, at any place in India, you are eligible to obtain EPR registration.
- Producer: Those selling base oil or lubricating oil in India.
- Recycler: Entities engaged in recycling used oil.
- Collection Agent: Agents who collect waste oil and supply it to registered recyclers.
- Importer: Those importing used oil for the purpose of reprocessing.
Documents required for EPR Registration for Used Oil
To successfully complete the EPR (Extended Producer Responsibility) registration, several important documents are required. These documents enable you to register your unit, purchase an EPR certificate, secure EPR certification for waste oil, and file returns on time. Below is the list of documents that applicants must attach for EPR registration:
- ID and Address Proof of the Authorised Persons
- Business Registration (CIN, MoA, Partnership Deed, MSME, etc.)
- PAN and GST Details
- Import Export Code
- Details of Manufacturing
- EPR Plan to fulfill the targets
- Details Regarding the Manufacturing
- Details Regarding the Annual Returns
- Data Regarding the Generation of Used Oil
Fee for EPR Registration for used waste oil
The application fee for waste oil EPR (Extended Producer Responsibility) registration is based on the amount of waste generated by each applicant. EPR certificate holders are required to complete their authorized EPR targets within the specified licensing period. Non-compliance with EPR regulations may result in fines or even cancellation of the business license.
| S No. |
Sale of Base oil/Lubrication Oil (MTPA) |
Registration Fees Amount (INR) |
| 1. |
> 1,00,000 MT |
10,00,000 |
| 2. |
> 50,000 - 1,00,000 MT |
5,00,000 |
| 3. |
> 10,000 - 50,000 MT |
2,00,000 |
| 4. |
5000-10,000 MT |
50,000/- |
| 5. |
< 5000 MT |
25,000 |
Renewal of online EPR Registration for Used Oil
The Central Pollution Control Board (CPCB) has streamlined the Extended Producer Responsibility (EPR) registration process for used oil. Producers can expect initial EPR registration and subsequent renewals within 15 working days, provided all documentation is complete.
Key Points:
Renewal Timeline: Producers must submit their renewal application along with the required documentation at least 60 days before the registration expires.
Quick Processing: CPCB is committed to efficiently processing new registrations and renewals, completing reviews within 15 working days.
Process of EPR Registration for Used oil
Complete Registration Process for EPR Registration of Used Oil in India is given below.
1. Assessment and Documentation
The applicant must ensure that all the required information for the EPR Certificate is complete and accurate. All documents must be error-free to avoid any delays or problems in processing.
2. Filing of EPR Registration Form
The application, accompanied by accurate and complete documentation, must be submitted to CPCB officials via the online EPR registration portal for used oil.
3. CPCB Assessment of Application
The Central Pollution Control Board (CPCB) will evaluate the online Extended Producer Responsibility (EPR) application. If any problems or discrepancies are found, appropriate adjustments will be made to resolve them, and ensure compliance with regulatory requirements.
4. Issuance of EPR Authorization
Once the application is approved and all requirements are met, the CPCB will issue the EPR authorization, enabling the applicant to legally carry out the specified duties related to the management of used oil under the Extended Producer Responsibility framework.
Benefits of EPR Authorization for Used Oil
Obtaining EPR Certification for Used Oil provides many environmental and economic benefits to Producers, Collection Agents, Recyclers, Used Oil Importers.
Environmental Protection: Waste oil contains toxic chemicals, including benzene, lead, zinc, and cadmium. When not properly managed, these harmful substances can leach into soil and water sources, leading to severe environmental contamination and posing risks to ecosystems and human health.
Reduction in GHG Emissions: The high consumption of oil significantly contributes to greenhouse gas (GHG) emissions. By promoting the recycling of used oil, we can effectively decrease the demand for new oil production, thereby helping to reduce GHG emissions and minimize environmental impact.
Climate change mitigation: Mitigating global climate change from oil production and disposal is crucial to reducing the carbon footprint across ecosystems.
Conserving Resources: Encouraging the use of re-refined oil helps to preserve petroleum reserves, thereby decreasing the demand for crude oil.
Promoting circular economy: Collecting, processing and remarketing used oil promotes a circular economy.
Sustainable Development: Promoting eco-friendly practices for used oil management not only minimizes environmental impact but also contributes to achieving Sustainable Development Goals, fostering a more sustainable industrial landscape.
Economic Benefits: Refining used oil requires only one-third of the energy needed to process crude oil, which significantly reduces energy consumption. This efficiency not only reduces costs for industries but also brings huge economic benefits.
Regulated Waste Management: EPR (Extended Producer Responsibility) certification for used oil promotes efficient management and regulation, offering a structured approach to handling industrial waste responsibly.
Compliance and Accountability: Establishing a strong framework for compliance and accountability, ensuring that producers, recyclers and other stakeholders are responsible for the proper management and disposal of used oil.
Public Health Protection: Reducing the risks of improper disposal and mismanagement of hazardous waste oil is critical to protecting public health and ensuring environmental safety.
Responsibility for producers under EPR for Waste Oil
Registered waste oil producers must adhere to the following compliance requirements:
Producers must first obtain EPR registration for used oil through the CPCB’s centralized online portal before engaging in any business activities.
Engagements with entities lacking CPCB registration for used oil are strictly prohibited, ensuring all partnerships align with the Extended Producer Responsibility (EPR) requirements.
Producers are required to meet their EPR targets and submit completion certificates issued by CPCB-authorized waste processing units as proof of compliance.
Key Responsibilities of Stakeholders Under EPR for Used Oil Compliance
Extended Producer Responsibility (EPR) regulations for waste oil impose distinct duties on various stakeholders to ensure proper management and recycling. Below are the essential roles and responsibilities assigned to each group involved in this process:
Producers must register for EPR through the Central Pollution Control Board (CPCB) portal.
They are required to establish and maintain a robust collection system for used oil.
Producers need to submit regular returns to demonstrate compliance with EPR mandates.
Collection agents are tasked with gathering used oil from generators, such as industrial or automotive users.
They must supply collected used oil to certified recyclers or producers in accordance with EPR guidelines.
Responsibilities of Collection Agents Under EPR for Used Oil
Registration: Register on the CPCB portal to operate under EPR.
Collection and Supply: Collect used oil from generators and supply it to registered recyclers or producers.
Storage and Transportation: Ensure safe collection, transportation, and storage of used oil, following regulatory standards.
Compliance: Adhere to all regulatory requirements for hazardous waste handling.
Reporting: File quarterly and annual returns online, detailing oil collection and recycling activities.
Responsibilities of Recyclers Under EPR for Used Oil
Registration: Register on the CPCB portal and engage only with registered entities.
Recycling Processes: CPCB guidelines strictly for recycling used oil.
Certification: Issue EPR certificates to producers, specifying the recycled quantity and compliance details.
Reporting: Submit quarterly and annual reports on recycling activities to the CPCB.
Record Keeping: and file comprehensive records of used oil recycling data in regular returns.
These responsibilities support regulatory compliance and ensure traceability in the recycling of used oil.
Responsibilities of Importers Under EPR for Used Oil
Under India’s Extended Producer Responsibility (EPR) framework for used oil, importers are required to comply with specific responsibilities to ensure environmentally sound management of used oil. These responsibilities include:
Producers must register for EPR through the Central Pollution Control Board (CPCB) portal.
They are required to establish and maintain a robust collection system for used oil.
Producers need to submit regular returns to demonstrate compliance with EPR mandates.
Collection agents are tasked with gathering used oil from generators, such as industrial or automotive users.
They must supply collected used oil to certified recyclers or producers in accordance with EPR guidelines.
Responsibilities of Collection Agents Under EPR for Used Oil
Registration: Register on the CPCB portal to operate under EPR.
Collection and Supply: used oil from generators and supply it to registered recyclers or producers.
Storage and Transportation: Ensure safe collection, transportation, and storage of used oil, following regulatory standards.
Compliance: Adhere to all regulatory requirements for hazardous waste handling.
Reporting: File quarterly and annual returns online, detailing oil collection and recycling activities.
Responsibilities of Recyclers Under EPR for Used Oil
Registration: Register on the CPCB portal and engage only with registered entities.
Recycling Processes: Follow CPCB guidelines strictly for recycling used oil.
Certification: Issue EPR certificates to producers, specifying the recycled quantity and compliance details.
Reporting: Submit quarterly and annual reports on recycling activities to the CPCB.
Record Keeping: Maintain and file comprehensive records of used oil recycling data in regular returns.
These responsibilities support regulatory compliance and ensure traceability in the recycling of used oil.
Responsibilities of Importers Under EPR for Used Oil
Under India’s Extended Producer Responsibility (EPR) framework for used oil, importers are required to comply with specific responsibilities to ensure environmentally sound management of used oil. These responsibilities include:
EPR Registration: Importers of used oil must register on the Central Pollution Control Board (CPCB) portal dedicated to used oil management. This registration is required for compliance and monitoring purposes.
EPR Target: Importers are required to recycle 100% of the used oil imported in the previous year. This target ensures that all imported used oil is properly managed and recycled.
Use Restriction: Imported used oil must be used only for re-refining purposes. This restriction aims to promote recycling of used oil into base oil, thereby reducing environmental pollution.
Failure to comply with these responsibilities may result in cancellation of registration and possible legal action. By fulfilling these obligations, importers play a key role in the effective management of used oil, contributing to environmental sustainability and efficient use of resources.
Environmental Compensation under EPR for Used Oil
If producers do not comply with the EPR norms prescribed by CPCB, they will have to pay environmental compensation. Even after paying compensation, producers are not relieved of their EPR (Extended Producer Responsibility) obligation, but they will still have to meet the used oil recycling target.
In the following circumstances, a producer will have to pay environmental compensation-
- Non-fulfillment of EPR obligations for used oil
-
Non-registration of used oil under these regulations
-
Providing incorrect information of used oil recycling to obtain registration
-
Using incorrect EPR certificates for waste oil
The producer must maintain the environmental compensation received from the CPCB in a dedicated escrow account. This fund must be used for activities such as collection, recycling and safe disposal of waste oil. Alternatively, the CPCB reserves the right to determine its appropriate use.
