India consumes over 3 million metric tonnes of lubricating and base oil every year, and a significant share of that volume — along with the base oil itself — is supplied by foreign manufacturers and importers. Since April 2024, every entity that produces or imports base oil and lubricating oil into India has a binding legal obligation under the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, as amended in 2023: Extended Producer Responsibility (EPR) for used oil. If your company manufactures base oil overseas and exports it into India, or imports used oil as a recycling input, this obligation applies to you directly — not just to your Indian distributor. Missing this registration, or failing to meet annual EPR targets, can result in your products being flagged for non-compliance at the point of customs clearance and exposes your business to penalties under the Environment (Protection) Act, 1986. This guide explains exactly what EPR for used oil means, who it applies to, how the CPCB registration and target system works, and how foreign manufacturers can stay compliant without disrupting their India supply chain. 1. What Is EPR for Used Oil? Extended Producer Responsibility (EPR) for used oil was introduced through the Hazardous and Other Wastes (Management and Transboundary Movement) Second Amendment Rules, 2023, which added Chapter VII specifically covering used oil. The rules came into force on April 1, 2024, and are administered by the Central Pollution Control Board (CPCB) through a dedicated online portal. Under this framework, every producer of base oil or lubricating oil — and every importer of used oil — is assigned an annual EPR target. This target represents the volume of used oil that must be collected and sent for environmentally sound recycling, in proportion to the volume of fresh oil the producer or importer sold or imported into the Indian market that year. Producers do not need to physically collect and recycle the oil themselves. Instead, the rules establish a certificate-based trading mechanism: producers buy EPR certificates from CPCB-registered recyclers, who have demonstrably collected and recycled the equivalent volume of used oil. This is the same certificate-trading model CPCB uses for plastic, e-waste, battery, and tyre EPR — but used oil has its own dedicated portal, its own registration category, and its own compliance calendar. Key principle: If your company sells base oil or lubricants into the Indian market — whether you manufacture in India, export finished oil into India, or supply bulk base oil to Indian blenders — you are a “Producer” under these rules and carry EPR liability, regardless of where your factory is located. 2. Who Needs to Register? The Used Oil EPR Rules define four categories of registered entities, and a foreign manufacturer’s obligation typically falls into one or both of the first two: Producers of Base Oil or Lubricating Oil: Any entity that manufactures base oil or finished lubricating oil and places it on the Indian market, whether manufactured domestically or imported in bulk and sold under the producer’s brand. Importers of Used Oil: Entities that import used oil into India as a feedstock for re-refining or recycling operations. Collection Agents: Entities engaged in collecting used oil from generators (workshops, industrial users, fleet operators) for delivery to recyclers. Recyclers: CPCB-authorised facilities that process used oil and issue EPR certificates to producers and importers who purchase them to meet their targets. For a foreign manufacturer exporting base oil, finished lubricants, or industrial oils into India, registration as a “Producer” is mandatory before the product can be legally sold in the Indian market. This applies whether you sell directly to Indian industrial buyers, supply through a distributor, or have your oil blended and packaged locally under your brand name. Indian importers and distributors who simply resell a foreign manufacturer’s oil under that manufacturer’s own brand are not automatically the “Producer” for EPR purposes — the obligation generally sits with the brand owner. This makes it essential for foreign oil manufacturers to register directly or appoint a registered Indian entity to manage the obligation on their behalf, rather than assuming the Indian buyer has already taken care of it. 3. The CPCB Registration Process Step What Happens Portal sign-up Create an account on the CPCB Used Oil EPR Portal (eprusedoil.cpcb.gov.in) as a Producer or Importer of Used Oil Entity details Submit company registration documents, GST, PAN/TAN of the Indian entity or authorised representative, and product category details Volume declaration Declare the volume of base oil/lubricating oil sold or imported into India in the relevant financial year Target allocation CPCB allocates an annual EPR recycling target based on declared volumes and category-wise norms Certificate procurement Producer purchases EPR certificates from CPCB-registered recyclers via the portal’s trading mechanism to meet the allocated target Quarterly/annual returns File periodic returns declaring procurement data, sales data, and EPR certificates acquired against the target Compliance verification CPCB reviews submitted returns and certificate purchases against the producer’s target for the financial year Producers are required to begin filing annual returns starting from the FY 2024-25 cycle, and the portal mandates registration before the relevant sales or import volumes can be legally placed in the market for a compliant entity. 4. Documents Required for EPR Used Oil Registration 5. EPR Targets and the Certificate Trading Mechanism Once registered, a producer’s annual EPR target is calculated as a percentage of the previous year’s declared sales or import volume of base oil/lubricating oil. The producer must then acquire EPR certificates equal to or exceeding that target from CPCB-registered recyclers through the portal’s adjustment and trading mechanism. A few mechanics are important for foreign manufacturers to understand: This certificate-based system means a foreign manufacturer does not need to set up physical collection infrastructure in India — but does need accurate volume reporting and timely certificate procurement, both of which require ongoing portal management rather than a one-time filing. 6. Risks of Non-Compliance 7. PCN India Global: EPR Used Oil Compliance for Foreign Manufacturers PCN India Global helps foreign manufacturers and importers