EPR FOR USED OIL
At Silvereye Certifications, we understand that navigating through the EPR Used Oil Certificate process can be very difficult to manage, especially if you are unfamiliar with the requirements. That is why our experienced team is here to simplify it for you. From gathering the necessary documents to completing the certification process, we handle everything, ensuring you stay stress-free at every step.
We pride ourselves on our commitment to providing timely and reliable services. No delays, no hidden costs—just straightforward, professional guidance to help you achieve compliance quickly and efficiently. Let us take the stress out of the process so you can focus on what matters most: “Growing your Business”.
WHAT IS EPR FOR USED OIL?
The Ministry of Environment, Forest and Climate Change amended the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 vide notification G.S.R 677(E) dated 18th September 2023 as “The Hazardous and Other Wastes (Management and Transboundary Movement) Second Amendment Rules, 2023; where instrument of EPR (Extended Producer Responsibility) has been introduced for the management of Used Oil in the Country.
As per the provisions of the said rules, every Producer of Base Oil or Lubrication Oil and Importer of Used Oil has the obligation for Extended Producer Responsibility (EPR) on the basis of quantity of Base Oil or Lubrication Oil placed in the market and quantity of Used Oil imported.
The Producers shall fulfil their EPR obligations by purchasing Extended Producer Responsibility Certificates from registered recyclers. Producers, Collection Agents, Recyclers and Used Oil Importers are required to registered on the EPR portal developed by CPCB.
This document outlines the Standard Operating Procedures for the Registration of Producers as defined under the rules in line with the “The Hazardous and Other Wastes (Management and Transboundary Movement) Second Amendment Rules,2023.
WHO SHOULD GET AN EPR FOR USED OIL
Producer means any person or entity, irrespective of the selling technique used such as dealer, retailer, e-retailer, who, –
MANUFACTURERS
Manufactures offers to sell base oil or lubrication oil domestically under its own brand; or
BRAMD OWNER
Offers to sell lubrication oil domestically under its own brand, using the base oil manufactured by other manufacturers or suppliers; or
IMPORTERS
Offers to sell imported base oil or lubrication oil domestically.
TYPES OF PRODUCERS
| Code | Producer Type | Explanation |
|---|---|---|
| P1 | Manufactures and Sells Base Oil | A Producer who is involved in manufacturing of Base Oils at production facility and sells manufactured Base Oils in the market. |
| P2 | Importer of Base Oil | A Producer who is involved in import of Base Oil. |
| P3 | Manufactures Base Oil & Sells Lubrication Oil under its brand/Co-brand | A Producer who is involved in manufacturing of Base Oils at production facility and sells lubrication oil manufactured from Base Oil under its own brand name or with co-brand name. |
| P4 | Importer of Lubrication Oil | A Producer who is involved in import of Lubrication Oil. |
| P5 | Procures Base Oil domestically and sells Base Oil & its products under its brand /Co-brand | A Producer who procures Base Oil domestically and sells Base Oil and products derived from Base Oil under its own brand name or with co-brand name. |
| P6 | Procures Lubrication Oil domestically and sells under its brand/Co-brand | A Producer who procures Lubrication Oil domestically and sells under its own brand name or co-brand name. |
| P7 | Procures Base Oil domestically and sells Lubrication Oil under its brand/ Co-brand | A Producer who procures Base Oil domestically and sells Lubrication Oil manufactured from Base Oil under its own brand name or co-brand name. |
| P8 | Procures Redefined/Recycled Base Oil domestically and sells Lubrication Oil under its brand/ Co-brand | A Producer who procures Re-refined/Recycled Base Oil domestically and sells Lubrication oil manufactured from Re-refined/Recycled Base Oil under its own brand name or co-brand name. |
PROBLEMS OF USED OIL
Used oil, which is oil that has been contaminated with impurities or has degraded during use, poses several environmental, health, and economic problems. Here are some of the key issues associated with used oil:
ENVIRONMENTAL PROBLEMS
SOIL CONTAMINATION:
When used oil is improperly disposed of, it can seep into the ground and contaminate the soil. This can affect plant life and reduce soil fertility.
WATER POLLUTION:
Used oil can contaminate groundwater and surface water, making it unsafe for human consumption and harming aquatic ecosystems. Even a small amount of oil can pollute large quantities of water.
AIR POLLUTION:
When used oil is burned as fuel without proper emissions controls, it can release harmful pollutants into the air, including heavy metals and polycyclic aromatic hydrocarbons (PAHs).
HARM TO WILDLIFE:
Used oil can be toxic to wildlife if it enters natural habitats. It can coat the feathers of birds, reducing their insulating ability and buoyancy, and can be ingested by animals, leading to poisoning.
HEALTH PROBLEMS
EXPOSURE TO TOXINS:
Rigid Plastic which includes PET bottles.
OCCUPATIONAL HAZARDS:
Flexible Plastic which includes flexible plastic packaging.
ECONOMIC PROBLEMS
CLEANUP COSTS:
Contamination from used oil can lead to significant cleanup costs for governments and businesses. Remediation of polluted soil and water can be both challenging and expensive.
REGULATORY PENALTIES:
Improper disposal of used oil can result in fines and legal actions against individuals and companies, leading to financial losses.
RESOURCE WASTE:
Used oil can often be recycled and re-refined into new oil products. Improper disposal wastes a valuable resource and increases the demand for virgin oil production, which has its own environmental and economic impacts.
BENEFITS OF USED OIL MANAGEMENT
Proper management of used oil brings numerous benefits, both environmentally and economically. Here are the key advantages:
POLLUTION PREVENTION:
Proper disposal and recycling of used oil prevent soil and water contamination, protecting ecosystems and reducing pollution.
CONSERVATION OF RESOURCES:
Recycling used oil conserves natural resources by reducing the need for new oil extraction and refining, which can have significant environmental impacts.
REDUCTION IN GREENHOUSE GAS EMISSIONS:
Recycling and re-refining used oil typically consume less energy than producing new oil from crude. This reduces greenhouse gas emissions and helps combat climate change.
WILDLIFE PROTECTION:
Preventing used oil from contaminating natural habitats helps protect wildlife from the toxic effects of oil pollution.
ECONOMIC BENEFITS
COST SAVINGS:
Company should have a copy of all the necessary documents required for registration on hand in the form of pdf, jpg, or png before complete the application.
JOB CREATION:
The used oil recycling industry creates jobs in collection, transportation, processing, and re-refining, contributing to economic growth.
REDUCED CLEANUP COSTS:
Proper management of used oil reduces the risk of environmental contamination, thereby minimizing the costs associated with cleaning up polluted sites.
REGULATORY COMPLIANCE:
Adhering to regulations regarding used oil disposal and recycling helps businesses avoid fines and legal penalties.
HEALTH BENEFITS
IMPROVED PUBLIC HEALTH:
Proper management of used oil reduces the risk of exposure to hazardous substances, protecting public health and reducing healthcare costs associated with pollution-related illnesses.
SAFER WORK ENVIRONMENTS:
Proper handling and recycling of used oil can create safer working conditions for employees in industries that generate and manage used oil.
RESOURCE EFFICIENCY
SUSTAINABLE PRACTICES:
Recycling used oil promotes sustainable practices by creating a closed-loop system where oil is continually reused, reducing the demand for new oil production.
ENERGY EFFICIENCY:
The process of recycling and re-refining used oil is often more energy-efficient compared to the production of new oil, leading to energy savings.
COMMUNITY BENEFITS
ENHANCED COMMUNITY HEALTH AND SAFETY:
Proper used oil management ensures that local communities are not exposed to the hazards associated with oil pollution, leading to healthier living environments.
PUBLIC AWARENESS AND EDUCATION:
Effective used oil management programs often include educational initiatives that raise public awareness about the importance of recycling and environmental stewardship.
INDUSTRIAL BENEFITS
RELIABLE SUPPLY OF OIL:
Recycling used oil can provide a steady supply of re-refined oil products, helping to stabilize prices and ensure availability for various industrial applications.
BRAND REPUTATION:
Companies that implement and promote sustainable used oil management practices can enhance their brand reputation and appeal to environmentally conscious consumers and investors
DOCUMENTS REQUIRED FOR EPR FOR USED OIL
Before to begin with the process of application for the EPR for used oil it is important to have all the required documents so that the process could be done smoothly.
COMPANY GST CERTIFICATE
The certificate is issued by the Central Board of Indirect Taxes and Customs (CBIC). The GST certificate is proof of registration under the GST system and is mandatory for businesses to obtain before they can start trading and collecting taxes
PAN CARD OF THE COMPANY
A business PAN card refers to a permanent account number (PAN) specifically issued for businesses or entities in India. Business PAN cards are typically required for tax filing, opening bank accounts, legal compliance, claiming tax deductions, and conducting other financial activities on behalf of the business entity.
IEC CERTIFICATE
An Importer -Exporter Code (IEC) is a key business identification number which mandatory for export from India or Import to India. No export or import shall be made by any person without obtaining an IEC unless specifically exempted.
CIN DOCUMENT
A Corporate Identification Number (CIN) is a unique identification number that is assigned by the Registrar of Companies (ROC) to the companies registered in India. The ROC gives the CIN to the companies while issuing their Registration Certificate.
TIN DOCUMENT
The Taxpayer Identification Number (TIN) is an 11-digit unique alphanumeric code assigned to individuals and businesses registered under the VAT regime in India. It helps the tax authorities in identifying and tracking taxpayers to ensure efficient tax administration.
PAN CARD OF AUTHORIZED PERSON
Permanent Account Number or PAN is a means of identifying various taxpayers in the country. Pan Card is a 10-digit unique identification alphanumeric number (containing both alphabets and numbers) assigned to Indians, mostly to those who pay tax.
PROCESS OF FILLING THE APPLICATION
Before to begin with the process of application for the EPR for used oil it is important to have all the required documents so that the process could be done smoothly.
BUSINESS REGISTRATION CERTIFICATE:
Proof of legal registration of your business.
PRODUCT INFORMATION:
Detailed descriptions of the oil products you produce, including quantities and composition.
MATERIAL SAFETY DATA SHEETS (MSDS):
Safety information for the oil products.
EPR PLAN:
A comprehensive plan detailing how you will manage the collection, recycling, and disposal of used oil.
DEVELOP AN EPR IMPLEMENTATION PLAN
Create a detailed EPR implementation plan that includes:
COLLECTION STRATEGY:
How you will collect used oil from consumers (e.g., collection points, partnerships with waste management companies).
RECYCLING AND TREATMENT PROCESSES:
Methods and facilities for recycling or safely disposing of used oil.
PARTNERSHIP AGREEMENTS:
Contracts with third-party service providers, if applicable.
SUBMIT APPLICATION
PREPARE APPLICATION PACKAGE:
Compile all required documents, including the EPR implementation plan, financial guarantees, and proof of payment of any required fees.
SUBMIT TO REGULATORY AUTHORITY:
Submit your application package to the relevant regulatory authority overseeing EPR compliance for used oil.
APPLICATION REVIEW
REGULATORY REVIEW:
The regulatory authority will review your application to ensure it meets all requirements. They may request additional information or clarification during this process.
SITE INSPECTION (IF APPLICABLE):
Some regulatory bodies may conduct site inspections to verify the information provided in your application and to ensure compliance with EPR requirements.
APPROVAL AND ISSUANCE OF EPR CERTIFICATE
APPROVAL
If your application meets all regulatory requirements, it will be approved by the regulatory authority.
ISSUANCE OF EPR CERTIFICATE:
Upon approval, you will receive your EPR certificate, which confirms your compliance with the EPR regulations for used oil.
REGISTRATION FEES
The entity shall pay the registration fees as per the details given below along with the application for registration:
| S No.. | SALE OF BASE OIL/LUBRICATION OIL (MTPA) | REGISTRATION FEES AMOUNT (INR) |
|---|---|---|
| 1 | > 1,00,000 MT | 10,00,000 |
| 2 | > 50,000 - 1,00,000 MT | 5,00,000 |
| 3 | > 10,000 - 50,000 MT | 2,00,000 |
| 4 | 5000-10000 MT | 50,000 |
| 5 | < 5000 MT | 25,000 |
REGISTRATION FEES
Amendment refers to the process of making changes to the registration details of Producers.
For any amendments within 21 days after submitting the form for registration no charges will be applicable, however for any amendments after the 21 days, CPCB charges Rupees 10,000 for processing and implementing each requested amendment to registration documents.
CPCB shall review amendment requests and may require additional documentation or verification before approving changes to the registration.
