What recycling target must a lubricant or base oil seller meet under India's used oil extended producer responsibility rules?
Under the used oil chapter added to India's hazardous waste rules in 2023, a lubricant or base oil seller must recycle used oil equal to a share of what it sold or imported two years earlier. Only 5% for 2024-25 and 50% from 2030-31 were confirmed; the steps between are 10%, 20%, 20%, 40% and 40% as described.
The targets, year by year
The chapter on extended producer responsibility (EPR) for used oil sits in the Hazardous and Other Wastes (Management and Transboundary Movement) Second Amendment Rules, 2023, in force from 1 April 2024. Every target looks back two years, so the 2026-27 figure of 20% is already fixed by what you sold or imported in 2024-25.
- 2024-25: 5% of the base oil or lubricant sold or imported in 2022-23.
- 2025-26: 10% of what was sold or imported in 2023-24 (not confirmed against the gazette table).
- 2026-27: 20% of 2024-25. 2027-28: 20% of 2025-26.
- 2028-29: 40% of 2026-27. 2029-30: 40% of 2027-28.
- 2030-31 onwards: 50% of the quantity sold or imported two years earlier.
Who counts as a producer
- Anyone who makes base oil or lubricant and offers it for sale in India under its own brand.
- Anyone who sells lubricant under its own brand using base oil made by others.
- Anyone who offers imported base oil or lubricant for sale in India.
- The rules say this holds whatever the selling method, such as dealer, retailer or e-retailer.
What can change your number
- The Central Pollution Control Board (CPCB) lays down a factor that reduces the target for operational loss of base oil.
- A unit established after 1 April 2024 starts its obligation two years after the end of the financial year in which it was established, then follows the same table.
- Used oil importers have a separate rule: 100% of the used oil imported in the previous year, and the rules permit such imports for re-refining only.
How you meet it
- Register on the CPCB portal as a producer.
- Buy EPR certificates online from registered recyclers only. The rules say the lower figure counts if your record and the recycler's record differ.
- You may buy up to this year's liability, plus any leftover liability from earlier years, plus 10% of this year's liability. The rules ask for proportionate purchases each quarter.
- File the annual return on or before 30 June after the financial year.
- A shortfall carries forward for up to three years, and environmental compensation can be levied.
Where this meets your carbon records
The rule ranks two routes for used oil: re-refined base oil or lubricant first, energy recovery second. The certificate is a compliance record. It does not change your own Scope 1 or Scope 2 figure. If you also burn used oil in your own heater or boiler, that burning is a separate Scope 1 entry.
A lubricant brand in 2026-27, example numbers
- Sold or imported in 2024-25 (example): 8,000 tonnes
- 2026-27 target: 20% x 8,000 = 1,600 tonnes, before any operational loss reduction
- Most certificates it may buy: 1,600 + 0 leftover + 10% x 1,600 = 1,600 + 160 = 1,760 tonnes
- If 200 tonnes are still short at year end, they carry forward and compensation can be levied
The sales figure is an example. The percentages and the 10% limit are the rules' own.
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.
- Re-refining used engine oil: the emissions
- Workshop used oil: when it counts
- Do lubricants count in Scope 1
- How to fill the waste categories in BRSR
- BRSR reporting
Last reviewed 2026-11-05. Only the 5% for 2024-25 and the 50% from 2030-31 were confirmed; check the 10%, 20% and 40% steps in the gazette table. Targets are as described in the 2023 amendment. CPCB sets the operational loss factor and conversion factors; check its portal for your year before you plan purchases.