What is Extended Producer Responsibility (EPR) for Used Oil?
Extended Producer Responsibility (EPR) for used oil in India refers to the obligation of producers, including manufacturers and importers of base oil or lubrication oil, as well as importers of used oil, to meet specific recycling targets. This responsibility is fulfilled by purchasing re-refining or energy recovery certificates from registered recyclers. The aim is to ensure the environmentally sound management of used oil, as mandated by the Hazardous and Other Wastes (Management and Transboundary Movement) Second Amendment Rules, 2023.
What is Base Oil?
Base oil serves as the fundamental component of lubricant oils. It is derived either from crude oil during the refining process or from synthetic sources. Beyond its use in lubricants, base oil is essential in producing oils for various industrial applications, such as hydraulic oils for transmitting force and transformer oils for heat transfer. Once these oils have served their intended purpose, they may become used oils, necessitating environmentally safe handling, re-refining, energy recovery, or disposal.
What is Lubrication Oil?
Lubrication oils are widely used in transportation and industrial machinery to minimize friction between interacting surfaces, thereby reducing heat generation. After their use, these oils may degrade into used oils, which require appropriate management, including re-refining, energy recovery, or disposal to prevent environmental harm.
Defining Used Oil
Used oil is any oil derived from crude oil or synthetic mixtures, including spent engine oil, gear oil, hydraulic oil, turbine oil, and other industrial oils. If these oils meet the specifications outlined in Part A of Schedule-V of the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016, they are considered suitable for reprocessing. However, waste oil, as defined by the same rules, is excluded from this category.
Who Qualifies as a ‘Producer’?
A ‘Producer’ under the EPR framework encompasses any individual or entity, regardless of the sales method used, that:
- Manufactures and sells base oil or lubrication oil domestically under its brand.
- Sells lubrication oil domestically under its brand using base oil produced by others.
- Sells imported base oil or lubrication oil domestically.
The EPR Portal categorizes producers into various types, such as manufacturers and sellers of base oil, importers of base oil, and those who sell re-refined or recycled oils under their brand.
Do Original Equipment Manufacturers (OEMs) Qualify as Producers?
Original Equipment Manufacturers (OEMs) do not fall under the ‘Producer’ category unless they procure base oil or lubrication oil domestically or through imports and sell it under their brand within the country.
EPR Obligations for Different Entities
Entities such as producers and importers of used oil are required to meet specific recycling targets under the EPR framework. This is achieved by purchasing EPR certificates from registered recyclers, ensuring that used oil is managed in an environmentally responsible manner.
Oils Exempted from EPR Targets
Certain oils, like white oil, process oils used in manufacturing, and greases that do not generate residual used oil, are exempt from EPR obligations. However, producers of these oils must still register on the EPR Portal.
Registration Requirements on the Used Oil Portal
Entities required to register on the CPCB’s Used Oil Portal include:
- Producers of base oil, lubrication oil, or related products.
- Recyclers of used oil.
- Importers of used oil.
- Collection agents responsible for gathering used oil.
Registration for Exempted Oils
Even producers of oils exempted from EPR targets must register on the Used Oil Portal. They must submit details to verify their claim, and the CPCB may grant exemptions if the oil does not contribute to used oil generation.
EPR Targets for Export-Oriented Units
Export-oriented units that do not introduce base oil, lubrication oil, or used oil into the domestic market are not subject to EPR targets. However, they must still register on the Used Oil Portal.
Defining EPR Targets
EPR targets are specific recycling quotas based on the quantity of base oil or lubrication oil sold or imported two years prior. These targets are progressively increasing, starting at 5% in 2024-25 and reaching 50% by 2030-31 for producers of base oil or lubrication oil. Importers of used oil must meet 100% recycling targets based on the previous year’s imports.
EPR Targets for New Units Established After April 2024
For units established after April 1, 2024, EPR obligations commence two years after the end of the financial year in which the unit was established, following the prescribed targets.
Responsibilities of Producers under EPR Rules
Producers are required to:
- Register on the CPCB portal.
- Fulfill EPR obligations by purchasing certificates from registered recyclers.
- Submit annual returns by June 30 following the relevant financial year.
- Provide accessible contact information to consumers for support and inquiries.
- Raise public awareness through various communication channels.
Responsibilities of Used Oil Importers
Used oil importers must register on the CPCB portal, meet EPR targets, and file annual returns as specified.
Responsibilities of Collection Agents
Collection agents are responsible for:
- Registering on the portal.
- Collecting used oil from generators and delivering it to registered recyclers or producers.
- Submitting quarterly and annual returns on the portal.
Responsibilities of Recyclers
Recyclers must:
- Register on the CPCB portal.
- Ensure compliance with environmental regulations during the recycling process.
- Safely manage the storage, transportation, and recycling of used oil.
- Dispose of residues generated during recycling in an environmentally sound manner.
- Submit quarterly and annual returns as required.
Who Are Bulk Generators?
Bulk generators are entities, such as automobile industries, railways, defense establishments, transport companies, industrial units, power transmission companies, and large hotels or restaurants, that generate more than 100 metric tonnes of used oil annually.
Responsibilities of Bulk Generators
Bulk generators must:
- Establish collection points to facilitate the collection and transportation of used oil by agents.
- Ensure that used oil is only handed over to registered recyclers, producers, or collection agents.
Registration for Entities Engaged in Multiple Activities
Entities engaged in multiple activities, such as producing, recycling, collecting, or importing used oil, must register separately for each activity on the CPCB portal. This ensures compliance with the EPR framework and promotes environmentally responsible management of used oil.
