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  • Assistance in the EPR registration process for oil and lubricant producers, importers and recyclers
  • Documentation for registration in all applicable categories
  • Legal assistance for queries raised during the registration.
  • Timely assistance for any issues with the application

Registration Process for EPR for Waste Oil

After introducing EPR on Electronic waste (e-waste) and Plastic Waste, and more recently on tyre waste and battery waste in the country, the MoEFCC, on 2nd May 2023, released a draft notification in which it amended rule 9, after sub-rule 4 of theHazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 (HOWM rules) and introduced Extended Producer Responsibility or EPR for Waste Oil. These rules were brought in the form of HOWM Amendment Rules 2023 and will come into force from the 1st of April 2024 and cover those entities that deal with the manufacturing, recycling and import of base oil or lubrication oils. TheCentral Pollution Control Board (CPCB) will establish an online portalfor this purpose wherein the identified entities will have to register and file quarterly and annual returns, generate EPR certificates. The portal will become operational within 6 months and the CPCB/SPCB will be able to trace quantities ofoil produced or waste oil generated by creating a  database wherein the material balance of the oil and lubricants introduced by producers and used oil importers into the country can be tracked, and penalties in the form of environmental compensation can be issued to those that fail to register, fall short of fulfilling their target, fail to submit quarterly/ annual return or deal with unregistered entities in the recycling and management of waste oil.

Municipalities and Local Bodies will facilitate Producers, Bulk generators and collection agents to set up collection points for that will be auctioned or sold to the authorised recyclers only. BIS or the Bureau of Indian Standards will issue the necessary standards for redefined oil, which could be used as the base oil for producers of lubrication oil to aid in the process of EPR for Waste Oil.Verifying all the compliance with the rules meant for producers, collection agents, recyclers and bulk generators will be done through inspection and periodic audits by CPCB.

Provisions for the entities of oil and lubricant manufacturers

Through the 2023 amendments, the following terms have been defined

Base oil: means oil used for the production of finished lubrication oil

Bulk generators: these include the automobile industry, defence establishments, railways, transport companies, power transmission companies, industrial unitsetc., which generate more than 100 Metric Tonnes per annum of used oil

Collection points: Those areas were identified where the authorised collection agent would collect the used oil. Additionally, the Collection agent will be any registered person or entity who collects used oil and supplies it to the registered recycler.

Producer: any person or entity who

  • Manufacturers and offers to sell base oil or lubrication oil domestically under their own brand; or
  • Offers to sell lubrication oil domestically under its own brand, using the base oil manufactured by other manufacturers or suppliers; or
  • Offers to sell imported base oil or lubrication oil domestically; or irrespective of the selling technique used, such as dealer, retailer, e-retailer, etc.;

What are EPR Targets and how will EPR for Waste Oil be implemented

EPR or Extended producer responsibility' means the responsibility of any producer of base oil or lubrication oil or importer of used oil in accordance with the provisions given in the Hazardous and Other Wastes Amendment Rules, 2023. This regime will come into effect from 1st April 2024, where the identified entities will have to recycle a percentage weight of the waste oil introduced by them in the Indian market by means of manufacturing or importing. To meet recycling targets, the entities with EPR Targets will be allowed to transact in EPR certificates. These certificates will be generated by registered oil recyclers after they recycle the proportionate amount of waste oil in their facilities. Producers mustmeet the following EPR obligations only through registered recyclers with a registered facility and recycling capacity to ensure environmentally sound management of used oil.


Target applicable on Producers for EPR for Waste Oil

EPR obligation of the Year (x)

Percentage of Waste oil to be recycled (by weight)

Year 2024-25

10% of the base oil or lubrication oil sold or imported in the Year 2022-23

Year 2025-26

20% of the base oil or lubrication oil sold or imported in the year 2023-24

Year 2026-27

30% of the base oil or lubrication oil sold or imported in the year 2024-25.


Year 2027-28

40% of the base oil or lubrication oil sold or imported in the year 2025-2

Year 2028-29

50% of the base oil or lubrication oil sold or imported in the year 2026-27

EPR of collection and recycling target for the year 2029-30 (Y) onwards will be 60% of the base oil or lubrication oil sold or imported in the year (Y-2)

For units established after 1 st 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 and will be as per the target prescribed above

Targets applicable on Waste Oil Importers for EPR for Waste Oil

The extended producer responsibility obligation for used oil importers in any year (Y) will be 100% of the used oil imported in the previous year (Y-1). It is crucial to note that the import of used oil will bepermitted for the purpose of re-refining only.

Registration Process for EPR for Waste Oil

The amendment has made registration compulsory for the following stakeholders.

  • Producers
  • Collection agents
  • Recyclers
  • Used Oil importers

Registration Process for all the above stakeholders will be done on the centralised EPR Portal. While the CPCB will be coming up with the specific guidelines in due time, the following general steps will have to be followed.

Stage 1: Registration and Submission of Application

The applicant will need to sign-up in the portal to get login Credentials, which will be shared with the company's email ID.

Stage 2: Scrutiny of Application and Query Resolution

CPCB will examine documents submitted by the applicant on the online portal and intimate the applicant in case of any shortcomings that will be conveyed to the applicant

Step 3: Final Registration for EPR for Waste oil

The applicant will be registered in case of the complete application, and CPCB will issue a registration number within a stipulated time. The validity of registration will be two years. Applicants will have to renew the registration in their specific categories after every two years.

Additional Information Section

Responsibilities of the Stakeholders

The responsibilities of the concerned stakeholders have been identified and elaborated in the new rules. The key areas have been tabulated below.


Registration on the Portal

Need to Fulfil EPR targets

Filing returns

On CPCB Portal

Additional Roles

producers of base oil or lubrication oil


Yes (as per sub-para (2) of para 3)


Creating awareness through media, publications, advertisements, posters.

Used Oil importer


Yes (as per sub-para (2) of para 3)


Creating awareness through media, publications, advertisements, posters.

Collection agent


Not Applicable

Quarterly and Annual

Upload information related to the collection of used oil from generators to the registered recycler or producer on the CPCB portal.



Not Applicable

Quarterly and Annual

Comply with the HWM Rules and the CPCB’s SOP and Guidelines on used oil recycling.

Bulk generators

Not Applicable

Not Applicable

Not Applicable

set up collection points for registered collection agents to facilitate the collection process.

How will Enterclimate Assist You?

One stop for Assistance for your Business

Enterclimate provides one-stop support for all your legal requirements concerning the setup registration and post-compliance needs. Our team consists of experts from domains like EPR,Pollution NOC, Hazardous Waste Management Authorisation etc. and can assist you with any legal requirements for your business.

Comprehensive solution for specific business needs

Enterclimate provides all-inclusive assistance through customised plans that will suit the specific needs of your business. Tell us your requirements, and let our expert create the best strategy for a timely and cost-effective solution. Rest assured, and focus on growing your business while leaving your legal obligations to start your business with us.

Precise and Prompt Assistance

Our experts have a proven track record of successful and timely delivery of services. Our personalised client supportensures that the clients remain updated with recent developments that concern their business.We ensure that our client communication is always prompt, positive and seamless.


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