Under the used oil EPR framework, producers and importers are assigned targets based on the base oil and lubrication oil they sold in the financial year 2022-23, which determines their EPR obligation for FY 2024-25. For units established after April 1, 2024, the EPR obligation begins two years from the end of the financial year in which the unit was established, providing new entrants time to set up their operations before compliance requirements kick in. Importantly, producers of oils exempted from used oil EPR targets still need to register on the portal and submit details to confirm their exemption, and CPCB may relax targets upon review if the declared oil does not contribute to the stock of used oil requiring management. Export-oriented entities not introducing base oil, lubrication oil, or used oil into the domestic market are exempt from EPR targets but must still register for regulatory oversight and accountability purposes.
Recyclers follow CPCB guidelines strictly for recycling used oil and issue EPR certificates to producers specifying the recycled quantity and compliance details. Used oil must be packaged in durable, spill-proof containers and properly labeled as per Form 8 of the HOWM Rules, including details like waste type, source, and hazardous properties. Collection agents must have specialized facilities to prevent spills during unloading and transfer, and maintain comprehensive records of all operations. The Environmental Compensation mechanism for non-compliance can be levied under Rule 39(3) of the 2023 regulations, ensuring that entities operating without registration, providing false information, or wilfully concealing material facts face financial penalties. Payment of Environmental Compensation, however, does not absolve producers of their EPR obligations, which means unfulfilled targets are carried forward to subsequent years, creating cumulative liability.
Our consultancy specializes in helping businesses navigate the nascent but rapidly evolving used oil EPR regime in India. We assist producers and importers in understanding their specific obligations, calculating targets based on historical sales data, and identifying exemptions if applicable. For collection agents, we provide guidance on obtaining necessary approvals, meeting packaging and labeling requirements, and establishing compliant storage and handling facilities. We help recyclers register on the CPCB portal, ensure their processes meet prescribed guidelines, and generate EPR certificates that can be sold to producers needing compliance credits. Given that this framework is relatively new and many stakeholders are still registering, we provide timely updates on CPCB circulars and enforcement actions, helping you stay ahead of compliance deadlines. Whether you need assistance with initial registration, understanding the two-tier collection agent system, or sourcing EPR certificates for used oil, our team offers comprehensive solutions that ensure regulatory compliance while supporting the environmental benefits of used oil recycling, which consumes only one-third the energy required to refine crude oil.
