Guideline for Used Oil Collection, Handling, and Storage under the Extended Producer Responsibility

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The Central Pollution Control Board (CPCB) has introduced new guidelines on January 9, 2025, to establish a structured approach for the safe and environmentally responsible management of used oil. These guidelines, part of the Used Oil Extended Producer Responsibility (EPR) framework, focus on the role of Collection Agents, outlining best practices for the collection, handling, transportation, and storage of used oil.

Key Objectives and Responsibilities

The main goal of these guidelines is to ensure standardized practices for Collection Agents involved in handling used oil from industrial, commercial, and automotive sectors. As per the EPR framework under the Hazardous and Other Wastes (Management and Transboundary Movement) Second Amendment Rules, 2023, Collection Agents are responsible for:

-Safely collecting used oil from generators, including large-scale sources.

-Supplying the collected used oil to registered recyclers as per regulatory requirements.

-Adhering to the Hazardous and Other Wastes (Management and Transboundary Movement) (HOWM) Rules, 2016, given the hazardous nature of used oil. This involves maintaining proper records, implementing spill-prevention strategies, and ensuring material traceability.

-Transporting used oil using registered vehicles.

-Ensuring authorized collection sites are equipped with spill containment systems.

-Storing used oil according to the guidelines and providing it exclusively to authorized recyclers or producers.

-Registering on the CPCB-developed portal and sharing operational details such as collection capacity, vehicle types, storage facilities, and transfer arrangements.

-Filing quarterly and annual returns through the CPCB portal.

Categorization of Collection Agents

The guidelines divide Collection Agents into categories based on their operations, size, and transport methods:

-Collection Agent Level-1 (CA-1): Agents focused only on collecting and transporting used oil without storage facilities.

-Collection Agent Level-2 (CA-2): Agents responsible for collecting, storing, and transporting used oil, with sufficient storage infrastructure.

Regulatory Compliance and Facilitation

Collection Agents must comply with various environmental regulations, including:

-The Water (Prevention and Control of Pollution) Act of 1974.

-The Air (Prevention and Control of Pollution) Act of 1981.

-The Environment Protection Act of 1986.

The EPR framework also designates responsibilities for Municipalities and Local Bodies, tasked with creating used oil collection points in their areas. The collected oils can then be auctioned or sold to authorized recyclers. Additionally, State Pollution Control Boards (SPCBs) and Pollution Control Committees (PCCs) are expected to assist in setting up collection points for these agents.

Advantages of EPR Authorization for Used Oil Management

Obtaining EPR (Extended Producer Responsibility) Certification for used oil offers a range of environmental and economic advantages for producers, collection agents, recyclers, and used oil importers.

Environmental Protection: Used oil contains harmful substances such as benzene, lead, zinc, and cadmium. Improper disposal can lead to soil and water contamination, which threatens ecosystems and poses health risks to humans.

Reduction in Greenhouse Gas Emissions: The production and consumption of oil are major contributors to greenhouse gas emissions. By encouraging the recycling of used oil, the need for new oil production is reduced, helping to lower GHG emissions and minimize environmental damage.

Climate Change Mitigation: Reducing the environmental impact of oil production and disposal is vital for mitigating global climate change and reducing the carbon footprint across ecosystems.

Resource Conservation: Re-refining used oil helps conserve petroleum reserves, reducing reliance on crude oil and preserving natural resources for future generations.

Circular Economy Promotion: The collection, processing, and reuse of used oil supports a circular economy by ensuring that valuable resources are recycled and reused rather than discarded.

Sustainable Development: Implementing environmentally-friendly practices for managing used oil not only reduces its environmental footprint but also aligns with Sustainable Development Goals, fostering a more sustainable industrial landscape.

Economic Efficiency: Refining used oil uses only a third of the energy required to process new crude oil, leading to significant energy savings and economic benefits for industries.

Regulated Waste Management: EPR certification for used oil ensures structured and efficient management of industrial waste, promoting responsible disposal practices and compliance with regulations.

Compliance and Accountability: EPR certification establishes a robust framework for ensuring that producers, recyclers, and other stakeholders are accountable for the proper handling and disposal of used oil.

Public Health Safety: Proper disposal and management of hazardous waste oil help protect public health by minimizing the risks associated with improper oil disposal. 

Role of EPR Registration for Used Oil

The Government of India has introduced an Extended Producer Responsibility (EPR) policy for used oil to enhance its management and regulate the stakeholders involved. This is the fifth policy of its kind, following similar frameworks for e-waste, plastic waste, tyre waste, and battery waste. The main objective of the EPR for used oil is to promote effective disposal and recycling practices, safeguard the environment, and achieve sustainable economic and environmental goals. Under this policy, producers, recyclers, collection agents, and importers of used oil must comply with strict EPR guidelines to ensure responsible management.

Entities Required to Register for EPR for Used Oil

If your business involves the sale of base or lubricating oil, the manufacture, production, or import of industrial waste oil, or any related activities within India, you are eligible to apply for EPR registration.

The following entities are required to obtain EPR registration:

-Producers: Those engaged in selling base or lubricating oil within India.

-Recyclers: Entities that recycle used oil.

-Collection Agents: Agents responsible for collecting used oil and supplying it to registered recyclers.

-Importers: Entities importing used oil for reprocessing purposes.

Documents Required for EPR Registration for Used Oil

To successfully complete the EPR registration process, applicants must provide several key documents. These documents facilitate the registration of the unit, the acquisition of an EPR certificate, compliance with waste oil disposal regulations, and timely filing of returns. Below is the list of necessary documents for EPR registration:

1. ID and Address Proof of Authorized Persons

2. Business Registration Documents: (e.g., CIN, MoA, Partnership Deed, MSME, etc.)

3. PAN and GST Details

4. Import-Export Code

5. Manufacturing Details

6. EPR Plan: A plan to meet the required targets for used oil management.

7. Details Regarding Manufacturing Processes

8. Annual Returns Information

9. Data on Used Oil Generation 

Renewal of Online EPR Registration for Used Oil in India

The Central Pollution Control Board (CPCB) has streamlined the process for obtaining and renewing the Extended Producer Responsibility (EPR) registration for used oil. Producers can expect to receive their initial EPR registration or renewal within 15 working days, provided all necessary documentation is correctly submitted.

Key Highlights:

-Renewal Timeline: Producers must submit their renewal application with the required documentation at least 60 days before the expiration of their current registration.

-Efficient Processing: CPCB guarantees a quick review and processing of new registrations and renewals, completing assessments within 15 working days. 

EPR Registration Process for Used Oil

The process for obtaining the EPR registration for used oil in India follows these steps:

1. Assessment and Documentation The applicant must ensure that all necessary information for the EPR certificate is complete and accurate. Any errors or missing details may cause delays in processing.

2. Submission of EPR Registration Form The completed registration form, along with the correct documentation, must be submitted through the online EPR registration portal to the CPCB.

3. CPCB Evaluation of Application The CPCB will review the online EPR application. If any discrepancies are found, the applicant will be notified for corrections to comply with the regulatory requirements.

4. Issuance of EPR Authorization Once the application meets all regulatory conditions and is approved, the CPCB will issue the EPR authorization, authorizing the producer to undertake tasks associated with the management of used oil under the EPR framework. 

Frequently Asked Questions

1. What are EPR guidelines? 

Ans. EPR guidelines are a set of regulations that require Producers, Importers, Brand Owners, and Manufacturers (PIBOMs) to take responsibility for managing the end-of-life disposal or recycling of their products. These guidelines promote the development of durable and recyclable products, aligning with the principles of a circular economy.

2. What is the principle of Extended Producer Responsibility (EPR)? 

Ans. EPR is a waste and pollution management concept that encourages companies to design products that are more sustainable, recyclable, and environmentally friendly. It shifts the responsibility for product disposal or recycling to producers, ensuring they manage the product lifecycle from creation to post-consumer stages.

3. What are Extended Producer Responsibility (EPR) policies? 

Ans. EPR policies assign producers responsibility for their products throughout the entire lifecycle, including post-consumer waste. These policies aim to promote recycling and waste reduction while helping to achieve environmental targets by holding companies accountable for the waste they generate.

4. What are the key principles of EPR? 

Ans. EPR principles include the obligation for producers to manage their products throughout their entire lifecycle, particularly during disposal or recycling. The focus is on reducing waste, increasing recycling rates, and encouraging sustainable product design. Producers are incentivized to create products that are easier to recycle or reuse.

5. What does EPR mean for sustainability? 

Ans. In sustainability, EPR is an environmental policy that holds producers accountable for the entire lifecycle of their products, including the disposal stage. This responsibility encourages companies to design more environmentally friendly products and reduce waste, contributing to a circular economy.

6. What is the function of EPR? 

Ans. The function of EPR is to ensure that producers are responsible for managing the waste and environmental impact of their products after they are used. This includes both financial and operational responsibility, driving businesses to design more sustainable products and systems for recycling or disposal.

7. What are the aims of EPR? 

Ans. The main aim of EPR is to make producers financially and operationally responsible for the management of packaging waste. By doing so, producers are incentivized to use recyclable materials and increase the use of recycled content in their packaging, reducing the burden on taxpayers and promoting sustainability.

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