Extended Producer Responsibility (EPR) for Used Oil Management in India: FAQs-Based Article(Environment Protection and Healing Climate Change)

[YAGAY andSUN]

As India strengthens its commitment to sustainable waste management, Extended Producer Responsibility (EPR) for Used Oil has emerged as a critical regulatory framework. Laid out under the Hazardous and Other Wastes (Management and Transboundary Movement) Second Amendment Rules, 2023, EPR for Used Oil ensures that producers, importers, and recyclers manage oil waste responsibly. Here's a comprehensive article based on Frequently Asked Questions (FAQs) to guide stakeholders through this system.

1. What is Extended Producer Responsibility (EPR) for Used Oil in India?

EPR is the obligation of producers (manufacturers/importers of base or lubrication oils) and importers of used oil to ensure its environmentally sound management. This is fulfilled by purchasing EPR certificates from registered recyclers to verify that the used oil has been re-refined or utilized for energy recovery.

2. Key Terminologies

• Base Oil: A fundamental ingredient in lubricant oils, derived from crude or synthetic sources, used in hydraulic systems, heat transfer fluids, etc.
• Lubrication Oil: Minimizes friction in machinery, commonly used in automotive and industrial sectors.
• Used Oil: Oil that has been contaminated through use. It includes spent engine oil, hydraulic oil, gear oil, and more, provided it meets the specification in Schedule-V of the HOWM Rules, 2016.

3. Who is Considered a 'Producer'?

A producer includes anyone who:

• Manufactures and sells base or lubrication oil under their own brand.
• Imports such oils for domestic sale.
• Uses base oil from others to create branded lubrication oil.

Producers are classified (P1–P9) on the EPR portal based on their specific activities.

4. Do OEMs Have EPR Obligations?

Only if they sell lubrication or base oil under their own brand, OEMs (like vehicle manufacturers) are considered producers under EPR.

5. Who Must Meet EPR Targets?

• Producers as defined above.
• Importers of used oil. They must fulfill targets by purchasing EPR certificates from recyclers.

6. Exemptions from EPR Targets

Products like white oil, greases, or process oils that don’t generate used oil are exempt but still must register on the EPR portal to claim exemption.

7. Who Needs to Register on the EPR Portal?

• Producers
• Recyclers
• Importers of Used Oil
• Collection Agents

Each must register under their specific category and, if involved in multiple roles, must sign up for each.

8. What are the EPR Targets?

For producers:

• 2024–25: 5% of oil sold/imported in 2022–23
• 2025–26: 10% of 2023–24
• Up to 50% by 2030–31

For importers of used oil:

• 100% of used oil imported in the previous year

New units (post-April 2024) get a 2-year grace period.

9. What Are the Responsibilities of Different Stakeholders?

Producers:

• Register and buy EPR certificates
• File annual returns
• Consumer outreach and awareness

Importers:

• Register and fulfill EPR targets
• File annual returns

Collection Agents:

• Register, collect, and transfer used oil to recyclers
• File quarterly and annual returns

Recyclers:

• Register and operate as per CPCB guidelines
• Generate EPR certificates
• Ensure safe disposal of residues

Bulk Generators (e.g., transport companies, industries):

• Must hand over used oil to registered recyclers or agents only

10. EPR Certificates: What, How, and How Much?

• What? Certificates issued by registered recyclers for used oil processed.
• How? Producers buy them from recyclers via the EPR portal.
• Formula:
  QEPR = QP × CF × WP
  Where:
  • QP = Quantity of product
  • CF = Conversion factor
  • WP = Weightage (1.0 for re-refined oil, 0.25 for energy recovery)
• Limits: A producer can purchase certificates up to their annual obligation + 10%.

11. Fees and Charges

Registration Fee (Based on Oil Volume or Capacity):

• Producers: ₹25,000 to ₹10,00,000
• Importers: ₹25,000 to ₹10,00,000
• Recyclers: ₹25,000 to ₹75,000
• Collection Agents: ₹500 to ₹10,000

Annual Processing Charge: 25% of the registration fee.

12. Penalties and Compensation

• Environmental Compensation (EC): Levied for non-compliance, false certificates, or unregistered activities.
• Price Regulation: CPCB fixes minimum (30% of EC) and maximum (100% of EC) prices for EPR certificate exchange.

13. Frequently Clarified Scenarios

• Can EPR certificates be traded among producers? No.
• Is there a cap on certificate purchase? Yes, current year target + leftover + 10%.
• Validity of EPR certificates? 2 years from end of financial year.
• Late Fee? Applicable if delay in re-submitting incomplete applications (details awaited).

Conclusion

India's EPR for Used Oil is a pivotal move towards circular economy goals, promoting responsible recycling and resource management. While the system may appear complex, its structured framework ensures clarity, traceability, and accountability for all players in the oil lifecycle—from production to recycling.

For further information or registration, stakeholders should visit the CPCB EPR Used Oil Portal.

Note: This article is based on FAQs and legal rules available as of April 2025. Stakeholders are advised to consult the official CPCB guidelines and amendments for the most updated information.