From 1 April 2024, manufacturers and importers of base oil and lubrication oil are producers under Schedule X of the Hazardous and Other Wastes Rules and must meet rising used-oil collection and re-refining targets through EPR certificates. We register you on the CPCB used-oil EPR portal, compute your target from placed-on-market data and connect you with registered re-refiners and collection agents.
Legal basis: Schedule X (Extended Producer Responsibility for Used Oil) of the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, inserted by the Second Amendment Rules notified 18 September 2023 and effective 1 April 2024
Who needs it
- Manufacturers of base oil and lubricating oil, including blenders selling under their own brand
- Importers of base oil or finished lubricants
- Automotive OEMs and brands marketing lubricants manufactured by third parties under their label
- Bulk generators of used oil — fleets, workshops, industrial plants — who must channel used oil to registered collection agents or recyclers
- Used oil recyclers (re-refiners) and collection agents who register to generate or handle certificates
Common in:Manufacturing & Industrial UnitsRecyclers & Waste ProcessorsImporters & Brand Owners
Documents required
- 1Certificate of Incorporation / Partnership Deed and PAN
- 2GST registration certificate and IEC, for importers
- 3Quantity of base oil and lubricating oil manufactured or imported, by financial year, in tonnes
- 4Product list with grades and packaging
- 5Consent to Operate and Hazardous Waste Authorisation, for manufacturers and blenders
- 6Chartered Accountant certificate of quantities placed on the market
- 7Existing arrangements with used oil collectors or re-refiners
- 8Authorised signatory and registered office address proof
Missing something? We help you obtain or regularise supporting documents before filing.
How we get it done
- 1
Applicability and data scoping
Day 1–4We confirm your producer status, identify the reference-year quantities Schedule X uses and define what data your finance and supply teams need to pull.
- 2
Quantity certification
Day 5–10Placed-on-market data is compiled and certified by a Chartered Accountant.
- 3
Portal registration
Day 11–13The application is filed on the CPCB used-oil EPR portal with the government fee.
- 4
Queries and certificate
Day 14–35CPCB clarifications are resolved and the registration certificate with annual targets is issued.
- 5
Re-refiner tie-ups and returns
Day 36–40We help you contract with registered re-refiners and collection agents for certificates and set up the 30 June annual return.
If you don’t comply
Failure to register or to meet used-oil EPR targets attracts Environmental Compensation under Schedule X read with Rule 20 of the HOWM Rules, in line with CPCB's compensation guidelines, and penalties under Section 15 of the Environment (Protection) Act, 1986. Used oil is itself a hazardous waste, so handing it to unregistered collectors is a separate violation for generators.
Why MYDA Group
Specialists, not generalists
Environmental compliance is our only practice, so your file is handled by people who do this every day.
Fixed fee, written scope
You know the professional fee and the statutory fees before we start. No surprise add-ons.
Inspection and audit-ready
We prepare your site and team for the board visit or certification audit and attend it with you.
Lifetime reminders
Every condition, return and renewal goes into your compliance calendar with alerts.
Frequently asked questions
What are the used-oil EPR targets?
Schedule X sets the collection and recycling target at 10% of the base oil and lubricating oil placed on the market for FY 2024–25, rising by ten percentage points each year through the decade. Because the trajectory is steep, producers who build re-refiner relationships early will find certificates easier to secure.
Who can generate used-oil EPR certificates?
Registered recyclers — re-refiners producing re-refined base oil, and other permitted recycling processes — generate certificates on the portal for the used oil they process, backed by GST invoices and SPCB authorisation. Collection agents aggregate used oil but do not generate certificates themselves.
We are a transport fleet generating used oil. What applies to us?
You are a bulk generator, not a producer. You must store used oil properly, hand it only to registered collection agents or recyclers and maintain records, which your Hazardous Waste Authorisation and Form 4 return also require. We can set this up as part of your hazardous waste compliance.
Does this overlap with Hazardous Waste Authorisation?
Yes. Used oil is Schedule I hazardous waste (category 5.1), so manufacturers and recyclers need both SPCB hazardous waste authorisation and CPCB EPR registration. We make sure the quantities declared in both regimes reconcile.