Regulatory Updates: India is set to strengthen its management of used oil, transforming a linear system into a circular economy with the implementation of Extended Producer Responsibility (EPR) through the Hazardous and Other Wastes (Management and Transboundary Movement) Second Amendment Rules, 2023. These rules, building on existing frameworks, aim to create a more organized and environmentally sound system for managing used oil across the country.
Effective April 1, 2024, the regulations place obligations on manufacturers and importers of base oil and lubrication oil to meet recycling targets by purchasing EPR certificates from registered recyclers. The Central Pollution Control Board (CPCB) or any agency appointed by it will oversee the implementation and monitor compliance through a dedicated online portal.
The new framework mandates registration for all key stakeholders, including producers, importers, collection agents, and recyclers, on the CPCB’s EPR portal. These entities will be required to file quarterly and annual returns, providing detailed information on their activities related to used oil management. The portal will also facilitate the generation and transfer of EPR certificates, ensuring a transparent and traceable system.
The guidelines published in February, 2025, provide specific details for Collection Agents, categorizing them into Level-1 (CA-1) and Level-2 (CA-2) based on their scale of operations and outlining the infrastructure and procedures they must adhere to for the safe collection, handling, transportation, and storage of used oil. This includes requirements for designated storage spaces, spill containment systems, and proper labeling of containers.
The new rules align strongly with Environmental, Social, and Governance (ESG) principles. By promoting the collection and recycling of used oil, the framework reduces reliance on virgin resources and minimizes environmental pollution. The formalization of the used oil management sector can create new economic opportunities and improve the livelihoods of those involved in waste collection and recycling. The digital tracking system enhances transparency and accountability, enabling better data collection and compliance monitoring.
By establishing clear responsibilities and a market-based mechanism for used oil recycling, India is signaling its commitment to a circular economy. This framework is poised to transform the used oil sector from a source of pollution into a driver of resource efficiency, environmental stewardship, and economic opportunity.
