India’s used-oil EPR system is moving from rules to enforcement.
Binding law, CPCB implementation, quality standards and announced projects are kept separate. Sources were rechecked on 31 July 2026.
CURRENT PRODUCER TARGET20%
FY 2026–27
Oil sold or imported in FY 2024–25
COMPLIANCE POSITION
100% importer obligationUsed-oil importers are responsible for the previous year’s imported quantity, and imports are permitted only for re-refining.
Re-refining has priorityThe rules place re-refined base oil or lubrication oil ahead of energy recovery in the EPR hierarchy.
Certificates need a registered chainProducers fulfil obligations by buying portal certificates from registered recyclers, with GST e-invoice evidence now required.
STATUTORY TARGET LADDER
Producer EPR obligations rise to 50%.
Percentages apply to base oil or lubrication oil sold or imported in the stated calculation year. New units starting after 1 April 2024 begin after the two-year statutory lead-in.
India used-oil EPR target schedule under G.S.R. 677(E)
Compliance year
Target
Calculation base
2024–25
5%
Oil sold or imported in FY 2022–23
2025–26
10%
Oil sold or imported in FY 2023–24
2026–27CURRENT
20%
Oil sold or imported in FY 2024–25
2027–28
20%
Oil sold or imported in FY 2025–26
2028–29
40%
Oil sold or imported in FY 2026–27
2029–30
40%
Oil sold or imported in FY 2027–28
2030–31 onward
50%
Oil sold or imported in year Y−2
LEGISLATION & IMPLEMENTATION
What has changed, and what each change actually does.
Rules are binding. CPCB directions, guidance, portal notices, official data and BIS standards have different legal and technical functions.
CPCB PORTAL STATUS
Used-oil EPR certificate transfer is operational again
CPCB's official portal states that EPR-certificate transfer has resumed and is operational. This confirms the transfer function, not a separate price-discovery marketplace.
WHAT IT MEANS
Registered entities should use the portal record for transfers and retain transaction evidence. The public status does not establish certificate prices or market liquidity.
CPCB DIRECTION
GST e-invoices now support used-oil EPR certificate generation
CPCB directed recyclers to maintain GST-linked sales records. From 1 July 2026, certificates supported by recycled-product sales invoices other than GST e-invoices are not to be considered.
WHAT IT MEANS
Recyclers need invoice-level traceability for recycled-product sales, and producers should verify the linked evidence before accepting certificates.
POLICY COLLABORATION
A dedicated RECEIC working group examines used-oil circularity
MoEFCC's 2025–26 annual report identifies Circularity in Used Oil as one of five working groups under the Resource Efficiency and Circular Economy Industry Coalition, with FICCI as secretariat.
WHAT IT MEANS
This is ongoing industry-policy collaboration and technical deliberation. It is not legislation, a funded national programme or evidence of completed infrastructure.
CPCB ENFORCEMENT
States asked to review implementation and report action taken
CPCB issued an implementation-review communication to State Pollution Control Boards and Pollution Control Committees and requested Action Taken Reports under the used-oil EPR framework.
WHAT IT MEANS
Registration alone is not the end of compliance. State-level verification, action reporting and facility oversight are part of the operating framework.
FINAL CPCB GUIDELINE
CPCB issues environmental-compensation guidelines for used-oil EPR
CPCB published final guidance for imposing environmental compensation under the 2023 used-oil EPR rules. The guideline should be read with the governing rules and entity-specific facts.
WHAT IT MEANS
Non-fulfilment, false certificates and other contraventions can create financial exposure in addition to registration, audit and prosecution consequences.
GOVERNMENT SNAPSHOT
Parliament receives the first national implementation snapshot
The Government reported 103 registered recyclers, 19,000 tonnes recycled and 2,000 tonnes of EPR certificates generated as at 5 March 2026.
WHAT IT MEANS
These are point-in-time administrative figures, not a national used-oil generation, collection-rate, installed-capacity or utilisation series.
FILING UPDATE
FY 2024–25 annual-return extension expires
The 23 January 2026 office memorandum extended only the FY 2024–25 used-oil EPR return deadline, from 31 December 2025 to 31 March 2026. That relief has expired.
WHAT IT MEANS
No later official extension for FY 2025–26 was located. The statutory 30 June filing deadline therefore remains the operative reference unless a later order is issued.
The guidance explains the portal-registration route for collection agents that collect, store and transport used oil under the CA-2 model.
WHAT IT MEANS
Portal registration sits alongside the consent, authorisation, storage and traceability controls in CPCB's January 2025 collection guideline.
CPCB ENFORCEMENT
Physical verification becomes an explicit implementation control
CPCB directed State Boards and Pollution Control Committees on physical verification under the used-oil EPR framework.
WHAT IT MEANS
Declared capacity, process, material movement and authorisations should withstand facility-level verification, not only portal review.
RVSF CLARIFICATION
Vehicle-scrapping facilities enter the collection-agent chain
MoEFCC clarified that Registered Vehicle Scrapping Facilities collecting used oil are collection agents under the used-oil EPR framework.
WHAT IT MEANS
RVSFs must register on the used-oil EPR portal and pass collected oil only to registered recyclers.
REGISTRATION ENFORCEMENT
CPCB directs rapid onboarding of regulated entities
CPCB asked State Boards and Pollution Control Committees to require producers, used-oil importers, recyclers and collection agents to apply for portal registration within 15 days.
WHAT IT MEANS
The letter recorded that only 77 producers and 33 recyclers had applied after the portal launched on 24 June 2024, signalling an early formalisation gap.
COLLECTION GUIDANCE
CPCB defines two collection-agent operating models
CPCB's guideline distinguishes CA-1 collection and transport from CA-2 collection, storage and transport. CA-2 facilities require relevant consent and authorisation, and the guideline sets a maximum 90-day storage period.
WHAT IT MEANS
Collection design must match the registered activity, storage infrastructure, traceability, vehicle, spill-control and return requirements.
BIS QUALITY BENCHMARK
IS 18722 (Part 1):2024 establishes a mineral base-oil specification
The standard covers virgin mineral base oils in Groups I to III, but its re-refined mineral base-oil coverage is limited to Group I. No published Part 2 or mandatory Quality Control Order was located.
WHAT IT MEANS
Use it as a quality benchmark within its stated scope. It is not a finished-lubricant approval and must not be presented as proof that all RRBO groups are covered.
BINDING AMENDMENT
2024 amendment creates a certificate price-band mechanism
G.S.R. 177(E) permits platform controls for certificate exchange and ties the allowed price range to environmental compensation: 30% at the lower bound and 100% at the upper bound.
WHAT IT MEANS
The rule creates the legal pricing framework. It does not by itself prove that a separate price-discovery marketplace is currently operating.
GOVERNING RULE
India's used-oil EPR framework enters the hazardous-waste rules
G.S.R. 677(E) inserts Chapter VII for producers, collection agents, recyclers and used-oil importers, with portal registration, certificate-based fulfilment, returns, traceability and environmental-compensation provisions.
WHAT IT MEANS
The framework took effect on 1 April 2024, gives re-refining priority over energy recovery and prohibits registered entities from dealing with unregistered entities within the covered chain.
INDIA PROJECT WATCH
Momentum is visible, but most capacity is still announced.
MoUs, pilots and company-reported products are included for market intelligence. None is counted as operating national capacity without commissioning and output evidence.
ANNOUNCED PILOT
Tata Motors and Castrol start a Karnataka collection pilot
The companies announced a pilot using authorised commercial-vehicle service touchpoints as collection points and registered recyclers for onward processing.
WHAT IT MEANS
The filing does not disclose collected volume, recycler identity, RRBO output, pilot duration or a national rollout timetable.
ANNOUNCED PILOT
HPCL and Tata Motors announce a traceable used-oil pilot
The partners announced a model for collection, storage, recycling and conversion to RRBO from automotive service operations.
WHAT IT MEANS
No public capacity, rollout geography, capital commitment, recycler identity or commissioning evidence was disclosed.
ANNOUNCED PROJECT
IndianOil and Re Sustainability set collection and RRBO facility targets
The partners announced an SPV targeting 100 KTA of used-lubricant collection and a 50–100 KTA RRBO facility within three years.
WHAT IT MEANS
These are forward targets, not commissioned capacity. The release also uses inconsistent Group I, Group II and Group II+ descriptions, so the eventual product slate requires confirmation.
ANNOUNCED PILOT
UltraTech and HPCL announce an industrial used-oil circularity pilot
The parties plan to route used oil from selected plants to HP Green R&D Centre for reprocessing and explore RRBO-containing finished lubricants.
WHAT IT MEANS
No collection volume, RRBO yield, finished-oil qualification, capital expenditure or commissioning timetable was published.
FEASIBILITY MOU
HPCL and Castrol agree to assess an Indian RRBO ecosystem
The memorandum covers potential used-oil collection, re-refining and incorporation of RRBO into lubricants.
WHAT IT MEANS
This is a feasibility collaboration, not evidence of a commissioned plant, contracted capacity or qualified finished products.
COMPANY-REPORTED PRODUCT
Castrol reports commercialising an India engine oil with local RRBO
Castrol India's 2025 annual report says an engine oil using locally sourced re-refined base oil was commercialised in India.
WHAT IT MEANS
The report does not disclose RRBO percentage, base-oil slate, product volume, tests, approvals or sales. Those evidence gaps prevent a broader performance or scale claim.
EVIDENCE GAPS
What the public record still does not establish.
01
No verified public national series was located for used-lubricating-oil generation, formal collection, installed re-refining capacity, plant utilisation or RRBO output.
02
Portal dashboard counters and the 5 March 2026 Parliament snapshot cannot be reconciled without definitions and reporting-period notes.
03
Certificate transfer is operational, but no primary-source evidence was located that a separate price-discovery marketplace is live.
04
Most 2026 projects are MoUs, targets or pilots. Announced capacity is not counted as operating capacity.
USE WITH CARE
This tracker is technical and editorial information, not legal advice. Always check the current Gazette text, CPCB portal, applicable State Board requirements and product-specific qualification evidence before acting.
FULL KNOWLEDGEBASE
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Circularity succeeds or fails across the complete chain. This centre examines collection systems, feedstock contamination, process choices, product consistency, market acceptance and the evidence behind environmental claims.
CORE COVERAGE
ULO collection and chain of custody
India used-oil EPR and CPCB implementation
Water, fuel, glycol, solvent and metal contamination
Re-refining process families
RRBO quality and consistency
Finished-lubricant formulation
Regulation, economics and lifecycle evidence
10-ARTICLE RESEARCH SERIES
From ULO collection to credible RRBO performance.
10 practical research articles covering collection design, custody, contamination, re-refining technology, product qualification, regulation, economics and environmental evidence.
Coverage is maintained through verified explainers, comparisons, practitioner contributions and updated source registers.
01
Collection quality
Practical analysis of source segregation, storage, transport, contamination controls and traceability.
02
RRBO qualification
How volatility, oxidation stability, viscosity index, sulphur, colour and batch consistency affect formulation decisions.
03
Circularity claims
Clear boundaries for recycled content, mass balance, recovery yield and lifecycle comparisons.
PRACTICAL RESOURCES
Tools designed for disciplined decisions.
RRBO mass balance & screening calculator
Model ULO input, contamination, residues, recovered co-products, RRBO recovery and finished-product incorporation while exposing every assumption and data gap.
Create a collection-to-refinery control record covering load identity, segregation, sampling, acceptance evidence, exceptions and authorised disposition.