The Central Pollution Control Board (CPCB) has published a guidance document that outlines the process for Extended Producer Responsibility (EPR) adjustments for registered producers on the Used Oil EPR Portal in India.[1] The EPR obligation applies to producers and importers of base oil and lubrication oil to ensure proper management and recycling of waste oil.
Applicability:
Producers (importers) of base oil and lubrication oil in India are subject to EPR obligations because these oils generate waste that can harm the environment if not properly managed. When oils are transferred between registered producers, the EPR obligation shifts to the receiving party, provided the recipient confirms the transfer on the CPCB EPR portal. This mechanism prevents duplication of obligations and ensures that each quantity of oil is accounted for once under national compliance rules.
The Ministry of Environment, Forest and Climate Change in India has mandated EPR registration for used oil under Rule 3 of the Hazardous Waste Management Rules, 2016. All entities involved in the used oil chain, including producers, collection agents, recyclers, and importers, must obtain EPR certification through an online registration process with the CPCB.
This document applies exclusively to producers registered on the EPR portal for used oil management. Once registered, these producers can initiate EPR target adjustments for each financial year based on submitted sales data. Adjustments can only be made with other producers who are also registered on the portal.
EPR Adjustment Module Structure
The EPR Adjustment Module consists of two main sections:
- Request Sent by Sender Industry: This section is for the producer initiating the adjustment.
- Acceptance or Rejection of Requests by Receiver Industry: This section is for the producer who receives the adjustment request.
A producer may act as both a sender and a receiver, depending on their business model.
Types of Adjustments:
The system supports two primary types of adjustments:
- Adjustment for Operational Loss: Under Rule 27(3) of the Used Oil EPR regulations, a producer’s EPR target can be reduced by a factor prescribed by the CPCB to account for operational losses of base oil during processing. These operational loss values may be revised if they do not align with industry norms, with CPCB benchmarking used as a reference after stakeholder consultations.
- Adjustment Based on Business-to-Business Transactions: When base oil is transferred from one registered producer to another, EPR obligations on the transferor are excluded once receipt is confirmed by the receiver.
This adjustment is reflected only after acceptance by the receiving producer on the portal.
Process for Sending Adjustment Requests by Sender Producer:
Producers can initiate adjustments starting from Financial Year (FY) 2024-25. Sales data for each financial year, such as the type of oil, quantity sold domestically, company details, and GST numbers, are auto-fetched from uploaded Excel templates submitted during producer registration. Adjustments must be carried out year-by-year as enabled by the system.
There are two scenarios for sending requests:
- Requests for Quantities Sold to Other Producers (Manufacturing Own Brands or Selling Directly): The sender producer’s EPR target is reduced only when the receiver producer accepts the request. The receiver producer’s target remains unchanged. The sender cannot modify auto-fetched information. The sender must provide the registration ID of the receiver, which the portal verifies before sending. Requests may be auto-rejected if: The quantity sold exceeds the quantity procured by the receiver; Cumulative accepted requests exceed procured quantities. The receiver has not procured that particular oil.
- Requests for Quantities Sold to Co-Branding Partners: Adjustments can only be made if the co-branding share was not reported in the sales data during registration or annual returns. Either co-branding partner may initiate the request. EPR targets of both sender and receiver partners adjust according to the mutually agreed percentage share upon receiver acceptance. The sender must enter their percentage share (ranging from 1–99%) when sending the request. Requests may be auto-rejected if the requested quantity is less than the quantity recorded by the receiver for the specific oil.
Intimating and Tracking Requests:
Intimation to Receiver: Upon sending a request, the sender may optionally inform or remind the receiver to accept it. Requests automatically appear in the receiver’s “Accept Request” section under the “EPR Adjustment” sidebar.
EPR Send Request History: All sent requests are saved in this tab for record and tracking. Dashboard Data: Upon acceptance, the tentative, adjusted, and final targets update on the sender’s dashboard. In co-branding cases, both sender and receiver dashboards get adjusted. The cumulative adjusted targets reflect on dashboards and annual returns, and producers must fulfill EPR obligations based on these final adjusted targets.
Process for Accepting Requests by Receiver Producer
Requests appear for acceptance under “EPR Adjustments.” There are two acceptance scenarios based on the type of oil sold:
- Requests Received for Quantities Sold to Producers (Manufacturing Own Brands or Selling Under Own Brands): The receiver verifies details and accepts only valid requests for quantities procured from the sender. Acceptance does not change the receiver’s EPR target; only the sender’s target is reduced. The receiver may accept or reject the request, with rejection requiring remarks. Requests may auto-reject if sent quantities exceed procured quantities, if cumulative accepted requests exceed procured quantity, or if the oil was not procured by the receiver.
- Requests Received for Quantities Sold to Co-Branding Partners: The receiver verifies sender details and confirms procurement. The receiver checks the requested percentage share. Upon acceptance, the receiver selects the relevant co-branding unit from a dropdown based on sales data. The EPR targets of both partners adjust according to the accepted percentage share. Rejection requires entry of rejection remarks. The system may auto-reject if the requested quantity is less than the recorded quantity as per sales data.
History and Compliance:
EPR Receive Request History: The history of accepted requests is saved in this tab. Any wrongful sending or acceptance of EPR adjustment requests will be deemed a violation of applicable rules, and appropriate action may be initiated.
[1] Central Pollution Control Board, Ministry of Environment, Forest and Climate Change, ‘Guidance Document for EPR Adjustment Module for Registered Producers at Used Oil EPR Portal’ (August 2025) https://media.licdn.com/dms/document/media/v2/D561FAQGIQrsYD5Xdag/feedshare-document-pdf-analyzed/B56ZlXvsV.KMAY-/0/1758113748941?e=1759363200&v=beta&t=XUT9nEG9Bq_khu6NBy1XlDvYuCIIg4100kFSq2r-Ac8