Used Oil
Lubricating oil that has become unsuitable for its original purpose due to contamination or degradation and must be collected, recycled, or re-refined in accordance with regulatory requirements.
Used Oil EPR Compliance
Used oil is a regulated waste stream under India’s Extended Producer Responsibility (EPR) framework due to its hazardous nature and environmental impact. ReCirculytics provides end-to-end compliance support under the Used Oil EPR provisions of the Hazardous and Other Wastes Management Rules, enabling businesses to meet regulatory obligations through structured collection, authorised processing, and audit-ready reporting.
We help organisations manage used oil EPR with clarity, traceability, and compliance confidence.
Understanding Used Oil EPR
Used oil refers to lubricating oils and industrial oils that become unsuitable for their original purpose due to contamination or degradation. Under the EPR framework, entities introducing lubricating oils into the Indian market are responsible for ensuring the environmentally sound collection, recycling, and re-refining of used oil generated post-consumption.
Types of Used Oil Covered
Used Oil EPR applies to waste generated from:
Category I
Automotive lubricating oils
Oils used in vehicles to reduce engine wear and friction, requiring regulated collection and recycling after use.
Category II
Industrial & machinery oils
Lubricants used in industrial equipment and machinery to ensure smooth operation and prevent mechanical damage.
Category III
Hydraulic oils
Fluids used in hydraulic systems to transmit power, which must be managed carefully after use due to contamination risks.
Category IV
Gear oils & compressor oils
Specialized oils used in gearboxes and compressors to withstand high pressure and temperature during operation.
Who Needs to Comply
Used Oil EPR is applicable to:
- Producers and manufacturers of lubricating oils
- Importers of lubricating oils
- Brand owners placing lubricating oils in the Indian market
- Entities selling lubricating oils under their own brand name
Applicability is determined by the quantity of lubricating oil placed on the market, irrespective of where it is manufactured.
EPR Obligations & Targets
Obligated entities must:
- Register on the CPCB EPR portal for used oil
- Declare quantities of lubricating oil placed in the market
- Meet annual EPR targets for collection and recycling/re-refining
- Engage only with authorised used oil recyclers or re-refiners
- Procure and utilise valid EPR certificates
- Submit periodic and annual compliance reports
Non-compliance may attract environmental compensation, penalties, and regulatory action.
Regulatory Registration & Documentation
Used Oil EPR compliance requires accurate and timely regulatory submissions, including:
- CPCB Used Oil EPR registration
- Quantity declarations and category-wise reporting
- EPR certificate documentation
- Periodic and annual compliance returns
- Amendments, renewals, and regulatory correspondence
ReCirculytics ensures all documentation is consistent, verifiable, and audit-ready.
How ReCirculytics Supports Used Oil EPR Compliance
We provide comprehensive compliance support across the used oil lifecycle:
- Used oil EPR applicability assessment
- Lubricating oil quantity analysis and target calculation
- Development of compliant collection and fulfilment strategies
- Coordination with authorised recyclers and re-refiners
- Validation and management of EPR certificates
- Periodic reporting and CPCB submissions
- Audit, inspection, and regulatory notice support
Our solutions are designed to align regulatory intent with practical execution.
Our Approach to Used Oil EPR Compliance
Failure to meet targets or reporting requirements can lead to penalties, restrictions, and increased regulatory scrutiny.
Assess
We evaluate your lubricating oil footprint, regulatory exposure, and compliance obligations.
Design
We develop a tailored EPR strategy aligned with business operations and regulatory requirements.
Execute
We support compliant collection, recycling, documentation, and reporting.
Monitor & Improve
We track EPR targets, regulatory updates, and continuously optimise compliance performance.
Common Used Oil Compliance Challenges
Businesses commonly face challenges such as:
- Inaccurate declaration of lubricating oil quantities
- Shortfall in EPR target fulfilment
- Engagement with unauthorised recyclers
- Invalid or non-traceable EPR certificates
- Delays or inconsistencies in regulatory reporting
ReCirculytics mitigates these risks through structured compliance systems and proactive oversight.
Driving Responsible Used Oil Management
Beyond regulatory compliance, our work supports:
- Environmentally sound recycling and re-refining of used oil
- Prevention of soil and water contamination
- Reduced regulatory and reputational risk
- Transparent and defensible compliance reporting
- Contribution to circular economy objectives
We help organisations move from reactive compliance to responsible and sustainable used oil management.
Frequently Asked Questions
Yes. Used Oil EPR is mandatory for all applicable producers, importers, and brand owners under the applicable waste management rules.
Targets are based on the quantity of lubricating oil placed in the market in previous years, as prescribed by regulatory guidelines.
Yes. Obligations can be fulfilled using valid EPR certificates issued by authorised recyclers or re-refiners.
Non-compliance may result in environmental compensation, penalties, suspension of registration, or regulatory action.
Stay Compliant. Stay Responsible.
ReCirculytics helps you manage Used Oil EPR with clarity, accountability, and regulatory confidence—ensuring compliance today and environmental responsibility for the future.
Start your Used Oil EPR compliance journey with ReCirculytics.