USED OIL EPR GUIDE
Used Oil EPR in India
Used oil EPR is the Indian rule that makes the business which places base oil or lubricating oil on the market responsible for the environmentally sound recycling of used oil at end of life, through registered recyclers. It runs under Chapter VII of the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, in force since April 2024, is administered by the Central Pollution Control Board on a live online portal, and places the obligation on the producer and on the importer of used oil. This guide sets out what is in scope, who registers, how registration works, the compliance calendar, the recycling target ramp, the certificates, and how environmental compensation applies.
On this page
Used oil EPR at a glance
Used oil EPR is administered by the Central Pollution Control Board under Chapter VII of the Hazardous and Other Wastes Rules, 2016, in force since April 2024, and measured through online registration and tradable EPR certificates.
What used oil EPR is
Extended Producer Responsibility for used oil holds the producer of base or lubricating oil, and the importer of used oil, responsible for the environmentally sound recycling of used oil through registered recyclers, on the polluter-pays principle.
Used oil EPR is a statutory obligation under Chapter VII, titled Extended Producer Responsibility for Used Oil and comprising Rules 25 to 43, of the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. Chapter VII was inserted by the Second Amendment Rules, 2023, notified by G.S.R. 677(E) on 18 September 2023, and came into force on 1 April 2024, so obligations run from the financial year 2024-25. The rules are made under the Environment (Protection) Act, 1986, and were further amended by G.S.R. 177(E) on 12 March 2024.
Under the regime the Central Pollution Control Board (CPCB) runs a live online portal on which the obligated and registrable entities register, and the obligation is discharged with EPR certificates generated by registered recyclers. A compliant year is one where the obligated entity holds certificates against its target and has filed its returns.
The obligation rests on two parties: the producer of base oil or lubricating oil, which includes an importer that sells base or lubricating oil, and separately the importer of used oil. The next sections set out exactly what is in scope, who registers, and how the target is computed.
The commercial side, where a consultant registers a business, computes its target, sources the certificates and files the returns, sits on the used oil EPR service page. This guide holds the how-it-works detail.
Used oil, not waste oil
The single most important distinction in this regime is that it covers used oil and not waste oil. The two are separate statutory categories and must never be conflated.
Used oil is in scope. Used oil, defined in rule 3(36) of the 2016 Rules, means any oil derived from crude oil or from mixtures containing synthetic oil, including spent engine oil, gear oil, hydraulic oil, turbine oil, compressor oil, industrial gear oil, heat-transfer oil and transformer oil and their tank-bottom sludges, that is suitable for reprocessing and meets the specification in Schedule V Part A. The scheme also reaches the base oil and lubricating oil placed on the market that this used oil arises from.
Waste oil is out of scope. Waste oil, defined separately in rule 3(39), means oil that includes crude-oil spills, emulsions, tank-bottom sludge and slop oil from petroleum refineries, installations or ships, usable as fuel for energy recovery under Schedule V Part B. The definition of used oil expressly does not include waste oil, so the two categories carry different rules and must not be treated as one.
The obligation is met by having used oil recycled by registered recyclers, in priority order: first, re-refining it into fresh base or lubricating oil, and second, energy recovery. The next section sets out who registers.
Who needs used oil EPR
Rule 26 requires four classes of entity to register: producers, collection agents, recyclers and used-oil importers. A bulk generator is defined but does not register.
Four classes register on the CPCB portal, each separately if an entity falls in more than one, and a registered entity may not deal with an unregistered one.
| Class | What it covers |
|---|---|
| Producer | Manufactures or sells base or lubricating oil under its own brand, or sells imported base or lubricating oil, including a dealer, retailer or e-retailer. Carries the recycling target. |
| Used-oil importer | Imports used oil; a distinct obligated party. Used oil may be imported only for re-refining. |
| Recycler | Re-refines used oil or recovers energy from it; registers as a recycler or co-processor and generates the EPR certificates producers buy. |
| Collection agent | Collects used oil and supplies it to a recycler. Registered vehicle scrapping facilities register in this class. |
The bulk generator is defined but does not register. A bulk generator, meaning an entity such as the automobile industry, railways, defence establishments, a transport company, industrial units, a power-transmission company, a hotel or a restaurant that generates more than 100 metric tonnes of used oil a year, has duties under the rules but is not one of the four registrable classes.
A business that owes used oil EPR often has other environmental compliance running alongside it, which the full EPR guide covers across the CPCB streams.
How to register on the CPCB portal
Used oil EPR registration is fully online on the CPCB used oil portal at eprusedoil.cpcb.gov.in. Registration is mandatory before doing business, with no fixed expiry, subject to fees and an annual maintenance charge.
- Open the CPCB used oil portalRegistration is on the dedicated CPCB used oil portal at eprusedoil.cpcb.gov.in, with a login created through a one-time password sent to the company and authorised-person email.
- File the entity applicationThe entity applies in its class, producer, collection agent, recycler or used-oil importer, and assembles GST, PAN, the Importer Exporter Code, the Company Identification Number and the tax identifiers, with the authorised-person details.
- Pay the fee and receive the registrationA registration fee tiered by volume completes the registration, alongside an annual maintenance charge set at a quarter of the registration fee. The registration has no fixed expiry and continues while the entity does business, subject to those charges.
- Compute the target and buy certificatesThe producer computes its recycling target from the base or lubricating oil placed on the market in the lagged base year, and discharges it by purchasing EPR certificates from registered recyclers, proportionately each quarter.
- File returns and keep the recordProducers and used-oil importers file an annual return; recyclers and collection agents file quarterly and annual returns. Records are kept for audit.
Registration is live on the CPCB portal. The exact current client sequence and the live notices are confirmed against the portal at scoping.
Compliance calendar and key dates
Two calendars govern used oil EPR: a recurring filing rhythm that differs by role, and the rollout of the rulebook from the 2023 notification to the 2026 environmental compensation guidelines.
Part A. The recurring compliance calendar
Once registered, the filing rhythm differs by role.
| Filing | Due |
|---|---|
| Producer annual return | On or before 30 June following the financial year |
| Used-oil importer annual return | On or before 30 June following the financial year |
| Recycler returns | Quarterly, by the end of the month after each quarter, plus an annual return by 30 June |
| Collection agent returns | Quarterly, plus an annual return by 30 June |
Part B. The regulatory rollout
- 2 May 2023The draft notification (G.S.R. 338(E)) is published for a 60-day public comment period.
- 18 Sep 2023Chapter VII is inserted by the Second Amendment Rules, 2023 (G.S.R. 677(E)), creating used oil EPR.
- 12 Mar 2024The 2024 amendment (G.S.R. 177(E)) inserts the certificate exchange price band and a return-timeline relaxation.
- 1 Apr 2024The rules come into force; obligations run from the financial year 2024-25.
- 18 Mar 2026The environmental compensation guidelines are finalised and issued to the state boards.
- FY2030-31The producer recycling target reaches its 50 per cent steady state.
The annual return default is 30 June following the financial year. The first compliance cycle was the financial year 2024-25, for which the CPCB relaxed the filing window by administrative order; the operative date for any given cycle is confirmed against the current CPCB portal notice rather than assumed.
Your used oil EPR targets
Used oil EPR carries a recycling target that ramps to 50 per cent, computed on the base or lubricating oil placed on the market two years earlier. Importers of used oil carry a separate, flatter obligation, and there is no recycled-content mandate.
The producer recycling target ramps to 50 per cent. The producer must ensure that a percentage of the base or lubricating oil it placed on the market in the base year is recycled through registered recyclers. The percentage phases in on a statutory schedule.
| Year | Target |
|---|---|
| FY2024-25 | 5% |
| FY2025-26 | 10% |
| FY2026-27 | 20% |
| FY2027-28 | 20% |
| FY2028-29 | 40% |
| FY2029-30 | 40% |
| FY2030-31 onward | 50% |
The target is a percentage of the base or lubricating oil sold or imported two financial years earlier (year Y minus 2), reduced by an operational-loss factor set by the CPCB. A producer unit established after 1 April 2024 begins two years after the end of the financial year of establishment.
Importers of used oil, and the absence of a recycled-content mandate
An importer of used oil carries a flat 100 per cent obligation, computed on the quantity of used oil imported in the previous year (Y minus 1), and used oil may be imported only for re-refining. Unlike the plastic, battery and non-ferrous streams, used oil EPR imposes no recycled-content mandate: it is a recycling-volume obligation only, met through certificates, with no minimum share of re-refined base oil required in new lubricants.
EPR certificates and the price band
A producer meets its target by buying EPR certificates generated by registered recyclers. Each certificate is valid for two years, is weighted by recycling route, and is not tradable between producers.
EPR certificates are the instrument that discharges the target. The CPCB generates them in favour of a registered recycler from the recycled end-product, using the formula QEPR = QP x CF x WP, where QP is the quantity of end-product, CF is a CPCB-set conversion factor, and WP is the weightage. The weightage is 1.0 for re-refining used oil into base or lubricating oil and 0.25 for co-processing or energy recovery of used oil not suitable for recycling, which steers recycling toward re-refining.
Validity, denominations and limits. A certificate is valid for two years from the end of the financial year in which it was generated, after which it is automatically extinguished. Certificates are issued in denominations of 100, 200, 500, 1000 and 10,000 kilograms. A producer or importer may buy up to its current-year liability plus any carried-over liability plus a further ten per cent, purchasing proportionately each quarter, and each certificate is auto-adjusted against the earliest liability first. Certificates are not tradable between producers or importers.
The certificate price is a regulated band. Under the 2024 amendment, the CPCB fixes a ceiling and a floor for the exchange of EPR certificates, at 100 per cent and 30 per cent respectively of the environmental compensation rate per tonne. The specific rupee prices sit inside that band and move with a compensation figure the CPCB sets, so this guide states the mechanism and does not quote a rupee figure.
Penalties: environmental compensation
Non-compliance is enforced through environmental compensation under Rule 39, a levy that does not cancel the underlying obligation, is held in a ring-fenced fund and refunded in part if the shortfall is cured in time.
Environmental compensation is the financial levy imposed under Rule 39 for non-fulfilment of the obligation, for transacting or using false certificates, or for operating unregistered, on the polluter-pays principle. It is levied on producers and importers, on recyclers that issue false certificates or false information, and on unregistered entities and those that aid or abet a violation.
Paying compensation does not extinguish the obligation. The unmet obligation is carried forward for up to three years, the funds are held by the CPCB in a separate escrow account for used-oil collection, recycling and end-of-life disposal, and the compensation is refunded on a sliding scale if the shortfall is cured in time, at 85 per cent, 60 per cent or 30 per cent where the obligation is met after the first, second or third year respectively, and forfeited after three years.
Enforcement. A recycler that over-generates certificates beyond five per cent of the quantity actually recycled has its registration revoked and pays non-returnable compensation, and a violation repeated three or more times results in permanent revocation. The environmental compensation guidelines for the regime were finalised and issued to the state boards on 18 March 2026.
The specific rupee rate of compensation is set by the CPCB through its guidelines rather than fixed in the rules, so this guide describes the mechanism and the refund logic rather than quoting an amount.
Used oil EPR questions, answered
Common questions on what the rule is, what is in scope, who registers, the target ramp, the certificates, the returns and non-compliance.
What is EPR for used oil?
Used oil EPR is Extended Producer Responsibility under Chapter VII of the Hazardous and Other Wastes Rules, 2016, inserted by G.S.R. 677(E) and in force since 1 April 2024. It makes the producer of base or lubricating oil, and the importer of used oil, responsible for the environmentally sound recycling of used oil through registered recyclers, administered by the Central Pollution Control Board on a live online portal and discharged through EPR certificates.
What is the difference between used oil and waste oil?
Used oil, under rule 3(36), is reprocessable oil derived from crude or synthetic oil, such as spent engine, gear, hydraulic and transformer oil that meets Schedule V Part A, and it is what used oil EPR covers. Waste oil, under rule 3(39), is a separate category of refinery spills, tank-bottom sludge and slop oil under Schedule V Part B, used for energy recovery, and it is out of scope. The definition of used oil expressly does not include waste oil, so the two must not be conflated.
Who needs used oil EPR registration?
Four classes register: producers of base or lubricating oil, importers of used oil, recyclers, and collection agents. A producer includes a dealer, retailer or e-retailer that sells base or lubricating oil under its own brand, or sells imported base or lubricating oil. A bulk generator that produces more than 100 metric tonnes of used oil a year is defined but does not register.
What is the used oil EPR target?
The producer recycling target ramps from 5 per cent for FY2024-25 to 10, 20, 20, 40 and 40 per cent, reaching 50 per cent from FY2030-31, computed on the base or lubricating oil placed on the market two years earlier and reduced by an operational-loss factor. An importer of used oil carries a flat 100 per cent obligation on the used oil imported in the previous year. There is no recycled-content mandate.
How do EPR certificates work for used oil?
The CPCB generates certificates to registered recyclers using QEPR equals QP times CF times WP, with a weightage of 1.0 for re-refining into base or lubricating oil and 0.25 for energy recovery. A producer buys certificates to meet its target. Each certificate is valid two years from the end of the financial year of generation, is issued in denominations of 100, 200, 500, 1000 and 10,000 kilograms, and is not tradable between producers.
When are used oil EPR returns due?
Producers and importers of used oil file an annual return on or before 30 June following the financial year. Recyclers and collection agents file quarterly returns, by the end of the month after each quarter, plus an annual return by 30 June. The first compliance cycle was FY2024-25, for which the CPCB relaxed the filing window by order, so the operative date is confirmed against the current portal notice.
Is there a recycled-content mandate for lubricants?
No. Used oil EPR is a recycling-volume obligation met through certificates, with no requirement for a minimum share of re-refined base oil in new lubricants. This is a difference from the plastic, battery and non-ferrous streams, which do carry recycled-content duties.
What happens on non-compliance with used oil EPR?
The CPCB levies environmental compensation under Rule 39. Paying it does not cancel the obligation: the shortfall is carried forward for up to three years, part of the compensation is refunded on a sliding scale if the obligation is met within one to three years, and a recycler that over-generates certificates or repeats violations can have its registration revoked. The compensation guidelines were issued on 18 March 2026.
Primary sources
The rules cited in this guide come from the Central Pollution Control Board and the Government of India notifications.
Scope a used oil EPR registration
This guide sets out how used oil EPR works; a short scoping applies it to a specific portfolio. A few structured questions about the base or lubricating oil placed on the market, or the used oil imported, turn into a clear picture of the registration, the target and the certificates that apply. The used oil EPR service page sets out the full engagement.
Reviewed 24 July 2026