Step-by-Step Guide to EPR Registration for Used Oil in India (2026 Update)

Step-by-Step EPR Registration for Used Oil in India (2026 Update) — Stay fully compliant with CPCB rules, meet recycling targets, and avoid penalties with expert guidance from PSR Compliance.

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Every day, millions of litres of used oil are generated across India from cars, trucks, factories, generators, and industrial machines. This used oil contains dangerous chemicals like lead, benzene, cadmium, and arsenic. When it is dumped carelessly into drains, soil, or water bodies, it causes serious harm to the environment and human health. One litre of used oil can contaminate up to one million litres of drinking water. Left unmanaged, this waste becomes a silent environmental disaster.

To fix this problem, the Government of India introduced EPR Extended Producer Responsibility for Used Oil. This means that the companies and people who manufacture, import, or deal in oil products are now legally responsible for ensuring that the used oil they put into the market gets properly collected and recycled. The Ministry of Environment, Forest and Climate Change (MoEFCC) amended the Hazardous Waste Management Rules and made EPR Registration for Used Oil mandatory starting 1st April 2024. Businesses that deal in base oil, lubricating oil, or used oil must now register on the CPCB EPR Portal, meet recycling targets, and submit regular reports or face heavy penalties.

What is EPR for Used Oil?

EPR stands for Extended Producer Responsibility. It is a policy where the producer of a product is held responsible not just for making the product, but also for managing the waste it creates after use. For used oil specifically, this means that if a company sells lubricating oil or base oil in India, it must take responsibility for ensuring that the oil once used is collected and sent for proper recycling or re-refining.

This policy was brought in through the Hazardous and Other Wastes (Management and Transboundary Movement) Second Amendment Rules, 2023. It came into force on 1st April 2024.

What is "Used Oil"? (Simple Definition)

Used oil is any oil that was originally made from crude oil or synthetic sources and has been used and is now suitable for reprocessing. This includes:

  • Used engine oil (from cars, trucks, generators)
  • Gear oil
  • Hydraulic oil
  • Turbine oil
  • Compressor oil
  • Industrial gear oil
  • Heat transfer oil
  • Transformer oil
  • Tank bottom sludges from any of the above

Used oil must meet certain quality parameters set in Part A of Schedule V of the Hazardous Waste Management Rules 2016 to qualify for recycling. These parameters check the levels of harmful substances like Polychlorinated Biphenyls (PCBs), Lead, Arsenic, Cadmium, Chromium, Nickel, and Polyaromatic Hydrocarbons.

Note : "Used oil" and "waste oil" are different. Waste oil is too contaminated to be recycled. Used oil can be re-refined and reused.

Who Needs EPR Registration for Used Oil?

EPR Registration is mandatory for four types of entities :

1. Producers

Anyone who sells base oil or lubricating oil anywhere in India under their own brand or another brand is a Producer. This includes :

  • Companies that manufacture and sell domestic base oil or lubricating oil under their own brand
  • Companies that sell lubrication oil under their own brand using imported base oil
  • Companies that import base oil or lubrication oil and sell it in the Indian market

2. Importers of Used Oil

Any business that imports already-used oil from other countries for the purpose of re-refining it in India.

3. Recyclers

Companies that take used oil and process it through re-refining or energy recovery to produce base oil or recover usable energy. They must follow CPCB's Standard Operating Procedures (SOPs) and guidelines.

4. Collection Agents

Businesses or individuals who collect used oil from generators (like factories, garages, power plants) and supply it to registered producers or recyclers.

Note :

Each entity must register separately for each role it performs. If a company is both a producer and a recycler, it must obtain two separate registrations.

Which Sectors and Products Require EPR Registration?

EPR for Used Oil covers a wide range of industries and products. If your business generates or deals with any of the following, you likely need to register:

Sectors that require EPR Registration :

  • Automobile and vehicle servicing industry
  • Aviation and airport operations
  • Steel and metal manufacturing
  • Cement and construction
  • Chemical and petrochemical industry
  • Power generation (thermal plants, generators)
  • Pharmaceuticals and healthcare (industrial equipment oil)
  • Food processing (industrial machinery oil)
  • Logistics and transportation companies
  • Mining and heavy equipment operations
  • Electronics and electrical equipment manufacturing
  • Import-export businesses dealing in lubricants or base oils

Products covered :

  • Engine oil (petrol and diesel)
  • Gear oil
  • Hydraulic fluid
  • Turbine and compressor oil
  • Transformer oil
  • Heat transfer oil
  • Cutting and metalworking fluid
  • Industrial lubricants and greases
 

Benefits of EPR Registration for Used Oil

Environmental Benefits :

  • Used oil contains benzene, lead, zinc, cadmium, and other toxic chemicals. Proper recycling prevents these from contaminating soil, water, and air
  • Recycling used oil reduces greenhouse gas (GHG) emissions significantly, as refining used oil requires only one-third of the energy needed to refine crude oil
  • Reduces the carbon footprint of the oil industry across the entire ecosystem
  • Conserves petroleum reserves by reducing the demand for fresh crude oil
  • Prevents illegal burning and unsafe dumping of used oil

Economic Benefits :

  • Refining used oil uses only one-third of the energy needed for crude oil refining, reducing costs significantly
  • Creates a market for re-refined base oil which can be used in manufacturing lubricants
  • Supports the growth of a recycling industry and creates employment opportunities
  • Helps businesses avoid hefty penalties that come with non-compliance

Business and Compliance Benefits :

  • Legal protection registered businesses can operate without fear of regulatory action
  • Builds credibility and trust with customers, investors, and regulators
  • Puts you ahead in sustainable business practices
  • Access to the CPCB portal dashboard to track your EPR liabilities and certificates in real time
  • Demonstrates commitment to India's Circular Economy and Sustainable Development Goals

National and Social Benefits :

  • Moves India closer to achieving its Sustainable Development Goals (SDGs)
  • Supports India's goals of reducing oil import dependence
  • Protects public health by reducing exposure to hazardous waste
  • Contributes to building a circular economy where waste becomes a resource

What is an EPR Certificate for Used Oil?

An EPR Certificate is a digital document generated on the CPCB portal by a registered recycler after successfully re-refining a certain quantity of used oil. Here is how the system works:

  • A producer supplies used oil to a registered recycler for recycling
  • The recycler processes the oil and generates an EPR Certificate on the CPCB portal
  • This certificate mentions the quantity of oil recycled
  • The producer purchases this certificate to prove that they have met their recycling obligation
  • The CPCB portal records every transaction and adjusts the producer's EPR liability accordingly

Documents Required for EPR Registration for Used Oil

Keep the following documents ready before starting your application :

For All Entities :

  • ID and Address Proof of Authorised Persons
  • Business Registration documents (CIN, Memorandum of Association, Partnership Deed, MSME certificate, etc.)
  • PAN Card and GST Registration details
  • Latest audited balance sheet
  • Electricity bill (for address proof of premises)
  • Compliance undertaking

For Producers and Importers additionally :

  • Import Export Code (IEC)
  • Board Resolution or Authorization letter
  • Details of base oil or lubricating oil placed in the market in the previous financial year
  • Product details and invoices
  • BIS (Bureau of Indian Standards) licence, if applicable
  • EPR Plan to fulfil recycling targets
  • Details regarding annual returns
  • Data regarding the generation of used oil

For Collection Agents additionally :

  • SPCB (State Pollution Control Board) Authorization
  • Contracts with producers or recyclers

For Recyclers additionally :

  • SPCB Authorization
  • Consent to Establish (CTE) and Consent to Operate (CTO) from SPCB
  • Compliance certificates under Hazardous Waste Rules
  • Plant capacity details and process description
  • BIS specification of Re-Refined Base Oil (RRBO)
  • Details of re-refining process as per CPCB guidelines

Step - by - Step EPR Registration Process for Used Oil

Step 1 : Assessment and Documentation

First, identify which category applies to your business Producer, Importer, Recycler, or Collection Agent. Gather all required documents. Make sure everything is accurate and error-free to avoid delays.

Step 2 : Register on the CPCB EPR Portal

Go to the official CPCB Used Oil EPR Portal (eprusedoil.cpcb.gov.in) and create your account. Select your entity type during sign-up. If your company has multiple roles, you can register all entities under one GST number by selecting all applicable roles during registration but each entity will have an independent profile, compliance module, and transaction record.

Step 3 : Fill and Submit the Application

Complete the online application form with accurate information. Upload all required supporting documents. Pay the applicable registration fee online.

Step 4 : CPCB Review

CPCB will review your application. If there are any issues or missing information, CPCB will send a query. You must respond within the given time. If you do not submit the corrected application on time, a late fee may be charged.

Step 5 : EPR Authorization Issued

Once the application is approved and all requirements are met, CPCB will issue your EPR Registration Certificate. Your EPR targets and obligations will then appear on your dashboard. Normal processing time is 15 working days from the date of complete submission.

Step 6 : Start Fulfilling EPR Obligations

After registration, you must begin meeting your recycling targets, purchasing EPR certificates from registered recyclers, and filing quarterly and annual returns.

Understanding EPR Recycling Targets

For Producers and Importers of Base Oil and Lubricating Oil :

The EPR target is based on the quantity of oil you sold in the previous financial year. The target starts at 10% and increases every year until it reaches 60% :

Financial YearRecycling Target
2024–202510% of 2022–2023 sales or import
2025–202620% of 2023–2024 sales or import
2026–202730% of 2024–2025 sales or import
2027–202840% of 2025–2026 sales or import
2028–202950% of 2026–2027 sales or import
2029–203060% of 2027–2028 sales or import

Important adjustment : CPCB accounts for oil lost during manufacturing operations. Your target will be reduced by a factor for this operational loss.

For New Units (established after 1st April 2024) :

EPR obligations start after two years from the end of the financial year in which the unit was established.

For Importers of Used Oil (direct import for re-refining) :

The EPR obligation is 100% meaning you must recycle the entire quantity of used oil imported in the previous financial year. Also, import of used oil is only permitted for re-refining purposes. Any other use of imported used oil can lead to cancellation of registration and legal action.

Products Exempted from EPR Targets (but still need registration) :

Manufacturers of white oils, process oils, and certain specialty lubricants and greases :

Manufacturers of white oils, process oils, and certain specialty lubricants and greases that do not generate recyclable used oil may be exempted from EPR recycling targets. However, they must still register on the CPCB portal to confirm their exemption. CPCB may also review and relax their targets if the declared oil does not add to used oil stock.

Export-oriented units :

If a company only exports its products and does not sell base oil or lubricating oil in the domestic Indian market, it is exempt from EPR targets but must still register on the portal.

Post-Approval Compliance Requirements

Getting the EPR Registration Certificate is just the beginning :

Getting the EPR Registration Certificate is just the beginning. After approval, every registered entity must fulfill ongoing compliance requirements throughout the year:

For All Entities :

  • File quarterly returns on the CPCB portal (every three months)
  • File annual returns on the CPCB portal before the deadline
  • Deal only with other CPCB-registered entities buying from or selling to unregistered parties is strictly prohibited
  • Maintain proper records of all transactions related to used oil

For Producers :

  • Purchase EPR certificates from registered recyclers to fulfill annual targets
  • Arrange for collection, transport, and storage of used oil in a safe and compliant manner
  • Share contact details on your website or other public platforms to make it easy for consumers and generators to return used oil
  • Conduct and support awareness campaigns to educate the public about used oil recycling

For Collection Agents :

  • Register on the CPCB portal and keep registration updated
  • Collect used oil from generators and supply it only to registered recyclers or producers
  • Upload all collection and supply information on the CPCB portal for verification
  • Ensure safe storage and transportation of used oil as per hazardous waste handling standards

For Recyclers :

  • Process used oil strictly as per CPCB Standard Operating Procedures and guidelines
  • Issue EPR certificates to producers for every batch of oil recycled
  • Submit quarterly and annual reports on recycling activities
  • Maintain comprehensive records of all used oil received, processed, and recycled
  • Avoid any damage to the environment during processing and dispose of residues safely

For Importers of Used Oil :

  • Register on the CPCB portal and keep registration updated
  • Ensure 100% recycling of the previous year's imported used oil
  • File annual returns
  • Use imported used oil only for re-refining; any other use is a violation

Penalties and Environmental Compensation

If you do not follow the EPR rules for Used Oil :

If you do not follow the EPR rules for Used Oil, CPCB can take serious action against you. Here is what can happen:

When will you face penalties?

  • You did not fulfil your EPR recycling targets
  • You did not register on the CPCB portal even though you were required to
  • You provided false or incorrect information to get registration
  • Your EPR certificates are based on untrue or fabricated information
  • You issued false EPR certificates as a recycler
  • You used fake or invalid EPR certificates as a producer
  • You violated any other condition set under the Hazardous Waste Management Rules

What is Environmental Compensation?

Environmental Compensation is a financial penalty imposed by CPCB on any entity that fails to comply with EPR rules. Think of it as a fine for polluting or allowing pollution to happen through inaction.

Important points about Environmental Compensation :

  • Paying compensation does NOT free you from your EPR obligation. You still have to meet your recycling target even after paying the fine
  • CPCB keeps this money in a dedicated escrow account
  • This fund is used to collect, recycle, and dispose of unattended or uncollected used oil
  • If you later fulfill your pending EPR obligation, CPCB will refund a portion of the compensation you paid but the portion decreases the longer you take to comply

Other penalties include :

  • Suspension or cancellation of EPR registration
  • Enforcement action under the Environment (Protection) Act, 1986
  • Legal proceedings and reputational damage
  • Prohibition from conducting business in the oil sector

EPR Registration Fees for Used Oil

The registration fee for EPR for Used Oil is based on the quantity of base oil or lubricating oil sold annually (in Metric Tonnes Per Annum or MTPA) :

Sale of Base Oil / Lubrication OilRegistration Fee
More than 1,00,000 MTRs. 10,00,000
50,001 to 1,00,000 MTRs. 5,00,000
10,001 to 50,000 MTRs. 2,00,000
5,000 to 10,000 MTRs. 50,000
Less than 5,000 MTRs. 25,000

Note : Annual maintenance charges are also levied by CPCB. If an entity plays more than one role, separate fees apply for each role.

Validity of EPR Certificates :

EPR certificates are valid for two years from the end of the financial year in which they were issued. After that, they are automatically archived on the portal.

Limit on Purchasing EPR Certificates :

A producer can buy EPR certificates up to their current year's liability plus any unfulfilled obligation from previous years, plus an additional 10% of the current year's liability. You cannot buy more than this limit. Certificates are not tradable between producers or importers.

Renewal of EPR Registration 

Producers must submit their renewal application along with required documents at least 60 days before their current registration expires. CPCB completes renewal processing within 15 working days of receiving a complete application.

EPR Obligation Adjustment : How It Works Year on Year

Every year, CPCB recalculates your EPR obligation based on three things :

  • Your unfulfilled EPR obligation from the previous year (if any)
  • Your new sales or imports from the last financial year
  • The EPR certificates you purchased in the previous year

Example :

If your obligation for Year 1 was 20 units and you fulfilled only 14 units by purchasing EPR certificates, you still have 6 units unfulfilled. In Year 2, if your new obligation is 25 units, your total obligation for Year 2 becomes 6 + 25 = 31 units.

This rolling calculation means that unfulfilled obligations do not disappear; they carry forward every year.

Key Things to Remember

  • EPR Registration for Used Oil is mandatory from 1st April 2024 for Producers, Importers, Recyclers, and Collection Agents
  • Registration is done online on the CPCB EPR Portal at eprusedoil.cpcb.gov.in
  • Fees range from Rs. 25,000 to Rs. 10,00,000 depending on the quantity of oil you sell
  • Recycling targets start at 10% in 2024–2025 and rise to 60% by 2029–2030
  • Importers of used oil must recycle 100% of their previous year's imports
  • EPR certificates are the proof of compliance purchase them from registered recyclers
  • File quarterly and annual returns on the CPCB portal without fail
  • Non-compliance leads to Environmental Compensation, registration cancellation, and legal action
  • Even if you are exempt from targets (export-only or certain specialty oils), you must still register on the portal
 

Ready to get your EPR Registration for Used Oil sorted? Stay compliant, avoid penalties, and manage your obligations with ease.

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Written by

Raju Karn

Raju Karn

SEO Team Lead · PSR Compliance

5+ Years Experience

Raju Karn has 5+ years of experience writing compliance content covering CPCB, CDSCO, BIS, EPR, FSSAI, WPS, PESO and various small and large business registrations, licenses and certifications across India.

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Frequently Asked Questions

Yes. Anyone who sells base oil or lubricating oil in India  whether they manufacture it or not  is considered a Producer under EPR rules and must register.

Yes. You can register for multiple roles under one GST number during sign-up. However, each role will have its own independent profile, compliance records, and transactions on the portal.

You are exempt from EPR recycling targets if you do not introduce the product into the Indian domestic market. However, you must still register on the CPCB portal

Yes, you must still register. However, CPCB may exempt you from EPR recycling targets after reviewing your product. Registration is mandatory regardless of whether your product generates recyclable used oil.

No. EPR certificates are not tradable between registered producers or importers. They can only be purchased directly from registered recyclers.

EPR certificates are valid for two years from the end of the financial year in which they were issued.

For units established after 1st April 2024, EPR obligations begin after two years from the end of the financial year in which the unit was established.

No. Import of used oil is permitted only for re-refining purposes. Using imported used oil for energy recovery or any other purpose is a violation of the rules.

At first, the target is calculated based on oil quantities you have placed in the market. It can be adjusted dynamically on the portal as other registered producers confirm they received material from you to place on the market.

No. Paying the fine does not replace your obligation. You must still meet your recycling targets even after paying Environmental Compensation.

Submit your renewal application on the CPCB portal at least 60 days before expiry, along with updated documents. CPCB will process it within 15 working days.

You can only buy up to your current year's unfulfilled obligation plus 10% of your current year's liability. The portal automatically tracks this and will not allow excess purchases beyond this limit.

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