EPR Registration for Used Oil - Process, Documents, Fees

frequently asked questions (FAQ)

• What is Extended Producer Responsibility (EPR) for Used Oil in India

It implies, the producer (manufactures/ importer) of BASE oil/ lubrication oil and importer of used oil, must attain the desired target of recycling the used oil. The same is to by buying Re- Refining or energy recovery certificates from authorized recyclers for environmentally sound management of used oil under Hazardous and Other Wastes (Management and Transboundary Movement) Second Amendment Rules, 2023.

• What is Base Oil?

A base oil is a major component of finished oils, which is derived mainly from crude oil in refining and further refined or processed in the manufacturing of oil-based products, including lubricant oils or synthetic oils, in particular. Moreover Base oils are used in manufacturing oils used for transmitting force (hydraulic oils, etc.) and to facilitate cooling (transformer oils, thermal fluids, etc.) or lubrication. The oils after its intended use may be considered as Used Oils or waste oils, and they can be necessary to treat in an environmentally safe manner (e.g.c refinate, energy recovery or dispose of).

• What is Lubrication Oil?

Lubricating oils are often used to limit the lower the friction between parts in contact in various transport and industrial operating machines in order to lower the heat production during their contact. Once the lubrication oils have served their purpose, the used oils can then be classified as a Used Oil or Waste Oil which need to be managed either environmentally, through re-refining, energy recovery or by disposal.

• What is Used Oil?

“Waste Oil” means any oil, including sludge, derived from crude oil or any other source or any mixture containing any such oil and is irrespective of wheth¬er processing has removed any inadmissible impurities or separated any unidentified fractions and includes used lubricating oils drained from engines, gear boxes, and other equipments45 waste oil that is submitted for reprocessing and is meeting the specification laid down in Part A of Schedule-V of Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 but does not include waste oil as defined under the Hazardous and Other Wastes (Management & Transboundary Movement), [HOWM] Rules, 2016.

• Which entities have obligation for meeting EPR targets.

(i) Producer [defined at a.). above], including: (i) manufacturing and selling domestic base oil or lubrication oil under own brand; (ii) selling domestic lubrication oil under own brand (using imported base oil by another producers), and (iii) selling imported base oil or lubrication oil domestically]; and Importer of used oil are under the responsibility to fulfil the recycling targets of the used oil by procuring the EPR certificates from the registered re-refineries.

• Which type of oils are exempted from Used Oil EPR Target?

The manufacturers of oils, namely white oils, process oils and lubricants, including greases, which do not produce used oils that cannot be reclaimed or reused may not have any EPR requirement. But you still have to register on the EPR Portal. This “guaranties regulatory compliance and monitoring, even though product is not accounted for in used oil waste. Appropriate registration facilitates the surveillance by authorities of the use of oil and compliance with the environment in terms of the EPR regimes.

• Who needs to register on the Used Oil Portal?

The following authority/organisation shall get themselves registered as respective authority/organisation on the portal of CPCB; 1. Produces / Importers of Base Oil/ Lubrication Oil/ Other Products from Base Oil Shall be designated as “Producer” at Portal 2. Used oil Recycler 3.1 Used oil Recycler shall register in the portal as “Recycler” 3. Used oil Importer shall register as “Importer” on the portal 4. It is authorized as Collection agent under Used oil Collection agent needs to registered as “Collection agent” on the portal.

• Does the producer of exempted oil from Used Oil EPR need to register on the portal?

Yes, Producers of oil exempted from Used Oil EPR Target will still need to register on the Used oil portal and submit the details to confirm their exemption. Additionally, on review, CPCB may relax the EPR targets if the declared oil does not add to the stock of used oil.

• Are units engaged in exports, have any EPR targets to meet under Used oil EPR framework?

Export-oriented entities not introducing base oil, lubrication oil, or used oil into the domestic market are exempt from EPR targets. However, they are still required to register on the Used Oil EPR Portal. This registration ensures regulatory oversight and maintains accountability, even when the products are meant solely for export and do not impact the domestic environment.

• What are the EPR targets for units established after 1st April, 2024?

The units which are established after 1st April, 2024, the extended producer responsibility obligation will start after two years from the end of the financial year in which the unit was established.

• Is it possible to login with the same credentials for multiple entities profiles?

By registering for more than one entity at the same time during Sign-Up, you can issue one ID and password for use with the multiple entities. But after having entered the website, the module, the profile, the registration, and the transactions of every entity are independent and unconnected. This arrangement allows for efficient entry, while still having distinct functions in terms of compliance and management, which are effective within the used oil EPR system.

• Is there a limit to the number of times an organization can sign up?

Producer, Recycler, Importer, or Collection agent, if they have several roles, can register all entities under one GST number which are for mixed roles. The activities in question should be selected during the registration process. This consolidated registration simplifies compliance by ensuring that all roles are accounted for appropriately under the used oil EPR system.

• What is Recycling and Re-refining of Used oil?

"Recycling" shall mean any process of re-refining of used oil to manufacture base oil or lubricating oil or any operation of energy recovery from used oil in an environmentally sound way with proper facilities as per the SoP or Guidelines prescribed by the CPCB; "re-refining" shall mean any operation of removal of unwanted impurities from used oil and production of base or lubricating oil as finishedproduct in accordance with the SOP or Guidelines issued by the CPCB.

• What is the Extended Producer Responsibility certificate?

Producers will be obligated to meet their EPR by purchasing or importing EPR certificates from recycler (who are registered with the CPCB, else problem is E-waste authorisation) via EPR portal of CPCB. The portal provides for the generation of EPR certificates on the basis of the quantity of used oil recycled by the registered recyclers, transparently and accountably fulfilling the EPR obligations in used oil management.

• Can used oil be imported for energy recovery?

The import of used oil is permitted for the purpose of re-refining only.

• Are recyclers required to recover Base oil meeting the quality standards outlined by BIS?

The CF (Conversion Factor) for issuing EPR Certificates on the re-refined base oil is based on the quality of re-refined base oil circulated by CPCB. The oils that satisfy the BIS specifications will be given a weightage, to ensure that the re-refined oil that gets an EPR Certificate is only of the highest standard of quality to encourage environmental and regulatory compliance.

• As a Producer, should I procure Re-Refined Base Oil, EPR certificates, or both from a Used Oil Recycler to fulfill my obligations?

At this time, the Producers is required to fulfil their Extended Responsibilities by purchasing Extended Producer Responsibility Certificates from registered recyclers online through EPR compliance purchasing portals. However, the base oil which has undergone re-refinement can eventually be put to use in the manufacturing processes of lubrication oil. Therefore, the purchase of Re-Refined Base Oil by Producers aids in achieving the nation’s Circular Economy objectives.

• How can producer purchase such EPR certificates?

On the portal dashboard, for every producer, availability of EPR certificate and also the list of Recyclers who have the EPR certificate will be made available. Producers can meet their Extended Producer Responsibility by purchasing extended producer responsibility certificates from the registered recyclers at the agreed cost within a predetermined range of price by CPCB and the Recycler transfers the agreed volume of EPR certificates to the account of the Producer. CPCB shall work out the mechanism for such conversions and for trading at a later stage.

• How much quantity of EPR certificates can be purchased by any producers?

A Producer may purchase EPR certificates equivalent to its current year (Year Y) liability, remaining liability from prior years, and 10% over and above that year’s liability. This provision provides some compliance flexibility and also helps to keep the level of purchase of certificates from exceeding specific regulatory limits under the EPR for used oil.

• What is the validity of EPR certificates?

The duration of Extended Producer Responsibility (EPR) certificate is two years beginning at the end of the financial year in which it was issued. When the certificate expires it will either be automatically removed or archived on the EPR portal. This in turn facilitates practical use of EPR and easy observation of compliance in the SVO system.

• Whether EPR certificates are tradable between the registered Producers/ Used oil importers?

EPR certificates are not tradable between the registered Producers/ Used oil importers.

• Is there any additional fee for late submission of the missing information sought by CPCB?

In case the applicant does not republish the complete application properly filled in time after receipt of the returned incomplete submission by CPCB, a late fee will be chargeable. The detailed form and amount of the late fee shall be informed separately at a later date. That will also help to ensure that EPR registration continues to operate properly and efficiently.

• How is the EPR target calculated on the EPR Portal during registration?

Upon registration, an Extended Producer Responsibility (EPR) target could be assessed at first based on the sum of oil brought into the market by Registered Producer. However, the EPR target can be dynamically modified (adjusted) after the Registration (i.e. when the registered Producer chooses the Other registered producers on the Portal, that had got the material(lubrication oil/base oil) for placing on the market on his own brand). Charts will be adjusted after the remaining registered Producers confirms receipt of the Material on the portal.