In 2016, when the government first introduced EPR for e-waste, few anticipated just how impactful it would become. By 2021, EPR was extended to plastic waste management, further demonstrating its effectiveness in addressing waste generation. In 2022, the Ministry of Environment, Forest, and Climate Change (MoEFCC) implemented EPR obligations for battery and tire manufacturing, importing, and recycling. During this period, the concept of a circular economy had been gaining momentum for nearly two decades, and India's commitment to sustainable manufacturing and waste management practices was becoming increasingly clear. Recycling across various industries revealed the potential to mitigate global climate change by reducing the extraction of raw materials and lowering fossil fuel consumption in manufacturing processes.

On May 2, 2023, the MoEF introduced EPR obligations for the oil and lubricant industry, recognizing the environmental and economic benefits of re-refining used lubricants. Through EPR for Waste Oil, the government aims to drive the circular economy forward, minimize the environmental impact of oils and lubricants, enforce the 'polluter pays' principle, and hold producers accountable for the entire lifecycle of their products.

Objective of EPR for Waste Oil

The advantages of Extended Producer Responsibility (EPR) for waste tyres extend beyond simply obtaining EPR certification or searching for EPR certificates for rubber and waste tyres. These benefits are crucial for the entire nation:

The new regulations will apply to all entities involved in the production, import, and recycling of base oil or lubrication oils. The Central Pollution Control Board (CPCB) will establish an online portal where entities must register, submit quarterly and annual returns, and generate EPR certificates. EPR registration is now mandatory for the following oil manufacturing and refining stakeholders:

Highlights of the HWM Amendments Rules, 2023

Through the 2023 draft notification, the following terms have been defined.

Base Oil	Oil that is used for the manufacture of finished lubrication oil
Collection point and agent	The facilities and points where the permitted collection agent would gather the waste oil.
Environmentally sound management of Used oil	Ensuring that Waste oil is handled in a way to protect health and the environment from any adverse effects that may result during the gathering, transportation, and recycling of Waste oil in accordance with the established guidelines.
Extended Producer Responsibility	Duty of any waste oil or lubrication oil manufacturer or importer to satisfy recycling targets solely through licenced recyclers to ensure environmentally sound management of old oil in accordance with the rules of subparagraph (2) of paragraph 3 of the schedule.
Re-refining	Any environmentally sound method of re-refining old oil to create base oil or lubricating oil that has the facilities detailed in the standard operating procedure (SOP) or standards established by the Central Pollution Control Board.
Recycling	Any procedure that purges unwanted impurities from old oil to produce base oil or lubricating oil as the final product.
Used Oil	Any oil as defined under sub-rule (36) of Rule 3 of Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016.

Who are Producer, Importers and Recyclers?

Modalities of the EPR Portal for Waste Oil

The Central Pollution Control Board (CPCB) will soon launch a centralized online system to facilitate the registration of entities, submission of quarterly data, annual returns, issuance of EPR certificates, and tracking of oil quantities produced or generated by stakeholders. Entities that fall into multiple categories must complete separate registrations for each category.

EPR Targets and Implementation for Waste Oil

To achieve EPR targets, producers and waste oil importers will be permitted to acquire EPR certificates from registered recyclers. These registered recyclers can issue EPR certificates upon completing the recycling of waste oil at their facilities. The draft notification outlining the EPR targets for producers is detailed in Schedule X, Rule 3(2).

S.No.	Year	EPR Targets
(a)	2024-25	10% of the imported or sold base or lubricating oil in the years 2022–2032.
(b)	2025-26	20% of the imported or sold base or lubricating oil in the years 2023–2024.
(c)	2026-27	30% of the imported or sold base or lubricating oil in the years 2024–2025.
(d)	2027-28	40% of the imported or sold base or lubricating oil in the years 2025–2026.
(e)	2028-29	50% of the imported or sold base or lubricating oil in the years 2026–2027.
(f)	For the years 2029–2030 (Y) and later, the EPR of collection and recycling target will be 60% of the base oil/lubrication oil sold or imported in the year.
(g)	For units established after 1st April 2024, the EPR obligation will commence after two years from the year in which the unit is established and will have to follow the target specified above.

Targets for Used Oil Importers under EPR for Waste Oil:

The EPR obligation for used oil importers in a given year 'Y' will be set at 100% of the used oil imported during the previous year, 'Y-1'. It is crucial to note that the import of used oil will only be allowed for re-refining purposes.

Registration Process for EPR for Waste Oil

Registration on the portal will open once the detailed guidelines are released. The general steps to follow include:

Step 1: Application Submission
The applicant must sign up on the portal under the applicable category. After successful signup, they will need to upload the required documents and submit the application.

Step 2: Application Review
The CPCB will review the submitted documents and notify the applicant if any issues are identified in the application. Any queries will be communicated to the applicant via the registered email address.

Step 3: EPR Registration for Waste Oil
If the application is complete or all issues raised by the Board are resolved, the applicant will be registered, and a registration number will be issued by the CPCB. The registration will be valid for 2 years, and the applicant must renew it in their category every 2 years.

Documents Required for EPR for Waste Oil:

Responsibilities of Producers

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

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