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Overview of EPR for Waste Oil

In 2016 when the government introduced EPR for e-waste, little did anyone know how effective it would prove to be. Then came 2021, and the government came up with EPR for plastic waste management showing that EPR is an effective way to manage waste generation. In 2022, the MoEFCC introduced EPR obligations for battery and tyre manufacturing, import and recycling. By this time, the concept of the circular economy had been gaining momentum for the last two decades, and India's vision for sustainable manufacturing and waste management practices was visible. Recycling in many sectors showed the potential to reduce the rate of global climate change by reducing the extraction of new resources and the amount of fossil fuels that was being burnt in the manufacturing processes of these sectors.

On 2nd May 2023, MoEF introduced EPR obligations for entities in the oil and lubricant industry as well, considering the benefit from re-refining of used lubricants for both environment and economy. Through EPR for Waste Oil, the government aims to work towards advancing the circular economy, decreasing the impact of oils and lubrication products and promoting the principle of "polluter pays", and making the producer accountable for the product's entire lifecycle.

Objective of EPR for Waste Oil

The government has provided time for the manufacturers, importers and recyclers to implement the waste oil collection and recycling network and deal with the challenges in the used oil re-refining. Therefore, the said amendments in the HWM Rules will be applicable from 1st April 2024. The framework has been designed to promote the use of sustainable and eco-friendly products, lower waste generation, increase recycling capacity etc. The objectives of EPR for Waste Oil, as identified from the rules, are as follows:

  1. To Integrate the environmental costs of recycling
  2. To develop a traceable waste management system
  3. Reduction of un-scientific disposal of waste oil and lubrication products
  4. Reduction of burden on municipalities
  5. To promote the development of environmentally sound products

The new rules will cover all those entities that deal with the production, import and recycling of base oil or lubrication oils. The Central Pollution Control Board (CPCB) will establish an online portal wherein the entities will need to register on the portal, upload file quarterly and annual returns, and generate EPR certificates. The amendment has made EPR registration compulsory for the following oil manufacturing and refining stakeholders.

  1. Producers
  2. Collection agents
  3. Recyclers
  4. Used Oil importers

Highlights of the HWM Amendments Rules, 2023

Through the 2023 draft notification, the following terms have been defined.

Base Oil

Oil that is used for the manufacture of finished lubrication oil

Collection point and agent

The facilities and points where the permitted collection agent would gather the waste oil.

‘Environmentally sound management of Used oil

Ensuring that Waste oil is handled in a way to protect health and the environment from any adverse effects that may result during the gathering, transportation, and recycling of Waste oil in accordance with the established guidelines.

Extended Producer Responsibility

Duty of any waste oil or lubrication oil manufacturer or importer to satisfy recycling targets solely through licenced recyclers to ensure environmentally sound management of old oil in accordance with the rules of subparagraph (2) of paragraph 3 of the schedule.

Re-refining

Any environmentally sound method of re-refining old oil to create base oil or lubricating oil that has the facilities detailed in the standard operating procedure (SOP) or standards established by the Central Pollution Control Board.

Recycling

Any procedure that purges unwanted impurities from old oil to produce base oil or lubricating oil as the final product.

Used Oil

Any oil as defined under sub-rule (36) of Rule 3 of Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016.

Who are Producer, Importers and Recyclers?

Producer: as per the notification, any person or entity who,

  • Regardless of the selling method employed, such as dealer, retailer, e-retailer, etc.,
  • Manufacturers of base oil or lubrication oil domestically under its brand.
  • Provides to trade lubrication oil locally under its own brand, utilising the base oil produced by other producers or suppliers; iii. provides to sell imported base oil or lubrication oil in the country.

Recycler: any individual or organisation involved in the used oil recycling process

Modalities of EPR Portal under EPR for Waste Oil

The CPCB will soon be releasing a centralised online system by the CPCB for registration of entities, submission of quarterly data, annual returns, issuance of EPR certificates and the tracking the quantity of oil produced or generated by stakeholder entities. Any entity that fits into more than one of the aforementioned categories must register under each one separately.

EPR Targets and their implementation under the provisions of EPR for Waste Oil

To meet EPR targets, the producers and waste oil importers with EPR Targets will be allowed to purchase EPR certificates from registered recyclers. Registered oil recyclers can generate EPR certificates after they recycle waste oil in their facilities. The Draft notification defining EPR targets for producers has been elaborated under Schedule X Rule 3(2).

S.No.

Year

EPR Targets

(a)   

EPR Targets obligation of the Year 2024-25

10% of the imported or sold base or lubricating oil in the years 2022–2032.

(b)   

EPR Targets obligation of the Year 2025-26

20% of the imported or sold base or lubricating oil in the years 2023–2024.

(c)    

EPR Targets obligation of the Year 2026-27

30% of the imported or sold base or lubricating oil in the years 2024–2025.

(d)   

EPR Targets obligation of the Year 2027-28

40% of the imported or sold base or lubricating oil in the years 2025–2026.

(e)   

EPR Targets obligation of the Year 2028-29

50% of the imported or sold base or lubricating oil in the years 2026–2027.

(f)     

For the years 2029–2030 (Y) and later, the EPR of collection and recycling target will be 60% of the base oil/lubrication oil sold or imported in the year.

(g)   

For units established after 1st April 2024, the EPR obligation will commence after two years from the year in which the unit is established and will have to follow the target specified above.

Targets for Used Oil Importers under EPR for Waste Oil

The EPR obligation for used oil importers in a particular year 'Y' will be 100% of the used oil imported by the importer in the previous year, i.e. Y-1. It is important to note that importing used oil will only be permitted for the purpose of re-refining.

Registration Process for EPR for Waste Oil

Registration at the portal will commence in due time when the detailed guidelines following general steps will have to be followed

Step 1: Submission of Application

The applicant will need to signup as per the applicable category on the portal. After successful signup, the applicant will have to upload relevant Documents and submit the application.

Step 2: Scrutiny of Application

CPCB will examine the Documents and intimate the applicant in case any issue is found in the application. The applicant will be intimated about the query through the registered e-mail id.

Step 3: Registration for EPR for Waste oil

In case of the complete application or resolution of all the queries raised by the Board, the applicant will be registered, and CPCB will issue a registration number. The validity of registration will be 2 years, and the applicant will need to renew the registration in their category after every 2 years.

Documents required for EPR for Waste Oil

  1. Submission of plant-wise manufacturing data (in Excel Format)
  2. PAN Card of the company
  3. GST Number of the company
  4. IEC number of the company (Only in case of import)
  5. CIN number of the company
  6. Aadhar Card of the Authorized Person
  7. Address of the head office of the company in the country.

Responsibilities of Producers

The responsibilities of the stakeholders have been identified and elaborated in the new rules. The key areas have been tabulated below.

Entity

Registration on the Portal

Need to Fulfil EPR targets

Filing returns

On CPCB Portal

Additional Roles

producers of base oil or lubrication oil

Yes

Yes

Annual

Creating awareness through media, publications, ads, posters etc.

Used Oil importer

Yes

Yes

Annual returns and quarterly submission of Data

Creating awareness through media, publications, ads, posters etc.

Collection agent

Yes

Not Applicable

Annual returns and quarterly submission of Data

Upload data on the collection of used oil from oil generators to the recycler or producer.

Recyclers

Yes

Not Applicable

Annual returns and quarterly submission of data

Comply with the Hazardous Waste Management Rules and CPCB’s Guidelines on used oil recycling.

Bulk generators

NA

NA

NA

Set up collection points for collection agents to facilitate the collection process.

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Frequently Asked Questions

The MoEFCC released a draft notification which amended rule 9, after sub-rule 4 of the Hazardous and Other Wastes Rules, 2016, which mandated the EPR for base Oil and lubricant producers and waste oil importers and mandated EPR registration for producers, importers and recyclers.

India's recycling sector has also realised the benefit and has integrated sustainable practices to use re-refined oil obtained from used oil for the manufacture of lubricants as it helps conserve precious petroleum reserves and dependence on foreign imports.

BIS will issue the necessary standards for redefined oil that could be used as the base oil for producers to aid in the process of EPR for Waste Oil.

Municipalities and ULBs will facilitate Producers, collection agents and Bulk generators to set up collection points that will be sold/ auctioned to the authorised recyclers only. Verification of Compliance with the rules for producers, recyclers, collection agents and bulk generators will be done by the CPCB.

The portal will become operational before November 2023, and the CPCB will be able to trace the quantities of oil produced or waste oil generated by creating a comprehensive database. Through this the material balance of products introduced by producers and importers into the country can be tracked and defaulters can be levied with environmental compensation if they fall short of fulfilling target, fail to submit quarterly/ annual return or deal with any unregistered entities in the recycling of waste oil.

The 2023 HWM Amendment Rules also empower the CPCB to cancel an entity's registration if they knowingly withhold necessary information for the registration, return, report or other information required under this schedule or if there are any other irregularities.

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