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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.
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.
Used oil is any oil that was originally made from crude oil or synthetic sources and has been used and is now suitable for reprocessing.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 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.
EPR Registration is mandatory for four types of entities :
Anyone who sells base oil or lubricating oil anywhere in India under their own brand or another brand is a Producer. This includes :
Any business that imports already-used oil from other countries for the purpose of re-refining it in India.
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.
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.
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:
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:
Keep the following documents ready before starting your application :
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.
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.
Complete the online application form with accurate information. Upload all required supporting documents. Pay the applicable registration fee online.
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.
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.
After registration, you must begin meeting your recycling targets, purchasing EPR certificates from registered recyclers, and filing quarterly and annual returns.
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% :
Important adjustment : CPCB accounts for oil lost during manufacturing operations. Your target will be reduced by a factor for this operational loss.
EPR obligations start after two years from the end of the financial year in which the unit was established.
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.
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.
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.
Getting the EPR Registration Certificate is just the beginning. After approval, every registered entity must fulfill ongoing compliance requirements throughout the year:
If you do not follow the EPR rules for Used Oil, CPCB can take serious action against you. Here is what can happen:
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.
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) :
Note : Annual maintenance charges are also levied by CPCB. If an entity plays more than one role, separate fees apply for each role.
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.
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.
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.
Every year, CPCB recalculates your EPR obligation based on three things :
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.
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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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