Why does a recycler earn only a quarter of the used oil producer responsibility credit for burning used oil as fuel compared with re-refining it?
Under India's used oil rules, extended producer responsibility (EPR) certificates are the tonnes of end product x a conversion factor x a weightage. The weightage is 1.0 for re-refined base oil or lubricant and 0.25 for used oil burnt for energy, so burning earns a quarter of the credit per tonne.
The formula and the two weights
- Certificate quantity = quantity of end product x conversion factor x weightage.
- Re-refined base oil or lubricant: weightage 1.0.
- Co-processing, utilisation or energy recovery for used oil not suitable for recycling: weightage 0.25, with the maximum permissible percentage to be prescribed by the Central Pollution Control Board (CPCB).
- The conversion factor is the quantity of inputs needed for one unit of output. CPCB lays it down; I did not confirm the basis it uses.
Why the gap
The rules rank the two routes: producing re-refined base oil or lubricant first, energy recovery second. They define energy recovery as using used oil as a fuel that is not suitable for recycling. The rules do not explain the 0.25. My reading is that it pushes recyclers toward re-refining, and it is a policy weight, not an emission factor.
What the certificate does and does not say
- It is valid for two years from the end of the financial year in which it was generated, then it lapses.
- It comes in denominations of 100, 200, 500, 1,000 and 10,000 kilograms, or as CPCB later lays down.
- It says nothing about carbon dioxide (CO2). Burning a tonne of used oil releases the same CO2 whatever the weightage printed on its certificate.
For a lubricant brand buying certificates
Ask the recycler which route sits behind the certificates. The weightage shapes supply: at the same conversion factor, a recycler earns four times as many certificates per tonne of end product from re-refining as from energy recovery. This is Senseible guidance, not rule text: your carbon records may need the route too, because a buyer of re-refined base oil may count the re-refiner's figure while burnt oil is a fuel.
One recycler, 100 tonnes of end product, same conversion factor
- Re-refined oil: 100 x 1.5 x 1 = 150.0 tonnes of certificates (an example conversion factor of 1.5, not confirmed as printed in the rule)
- Energy recovery at the same factor: 100 x 1.5 x 0.25 = 37.5 tonnes (my arithmetic)
- 37.5 / 150.0 = 0.25, a quarter
The 1.5 conversion factor is an example, not a CPCB-fixed factor for any product.
What Senseible does here
Senseible reads fuel invoices and electricity bills into records, so the diesel and power your site uses are on file. These rules are filed on government portals, outside Senseible's records.
- Used oil recycling targets for lubricant sellers
- Re-refining used engine oil: the emissions
- Burning waste oil in a furnace: CO2 factor
- BRSR reporting
Last reviewed 2026-11-05. Weightages and the denominations are as printed in 2023; CPCB can review them. The maximum share allowed for energy recovery is left to CPCB, so check its current notice.