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New Guidelines for Used Oil Collection Agents in India

An illustration of oil barrels leaking oil, highlighting the need for new guidelines to manage used oil responsibly



The Ministry of Environment, Forest & Climate Change in India has released new guidelines for the collection, handling, transportation and storage of used oil by Collection Agents. These guidelines come under the Extended Producer Responsibility (EPR) framework, introduced in the Hazardous and Other Wastes (Management and Transboundary Movement) Second Amendment Rules, 2023. This blog post will 
summarize the key points of these guidelines for stakeholders.

Purpose of the Guidelines:

These guidelines aim to ensure the safe and environmentally sound handling of used oil. This includes regulatory requirements, standardised practices, and the minimal requirements for facilities involved in the collection, transportation, and storage of used oil [1].

EPR Framework and Role of Collection Agents:

The EPR framework makes producers of base and/or lubrication oil, and importers of used oil, responsible for managing used oil [2, 3]. They fulfil this obligation by purchasing EPR certificates from registered recyclers. Collection Agents play a crucial role in this framework. They collect used oil from various generators (industrial, commercial, and automotive) and deliver it to registered recyclers [4]. This ensures the effective collection and aggregation of used oil, contributing to a circular economy for base oils and lubrication oils [1].

Categorisation of Collection Agents:

The guidelines categorise Collection Agents into two levels based on their scale of operations:

  • Collection Agent Level-1 (CA-1): These agents collect and transport used oil but do not have a dedicated storage facility. They can temporarily store collected oil in drums or containers mounted on their vehicles [5, 6].
  • Collection Agent Level-2 (CA-2): These agents collect, store, and transport used oil. They must have adequate storage facilities that comply with the guidelines [5, 7].

Regulatory Requirements:

  • Consent and Authorisation: CA-2 agents must obtain Consent to Establish and Consent to Operate from the State Pollution Control Board (SPCB) / Pollution Control Committee (PCC) before registering on the EPR portal. They also need authorisation under the Hazardous and Other Wastes (Management and Transboundary Movement) (HOWM) Rules, 2016 [8]. CA-1 agents self-register on the EPR portal with validation from the SPCB/PCC [9].
  • Record & Returns Filling: Collection agents must maintain records of the type and quantity of used oil collected, stored, and transferred. They are also required to file quarterly and annual returns through the EPR portal [10, 11].
  • Packaging and Labelling: Used oil must be packaged in containers suitable for safe handling, storage, and transportation. Labelling should comply with Form 8 of the HOWM Rules, 2016. Labels must include details like waste code, type, origin, hazardous properties, and emergency contact numbers [12-14].
  • Handling of Used Oil and Minimal Requisite Facility: The guidelines specify requirements for the used oil reception area, including equipment for unloading, transferring, and spill containment [14].
  • Transportation of Used Oil: Vehicles transporting used oil must comply with the Motor Vehicles Act, 1988. They should be equipped with GPS, spill-proof containers, and safety features like emergency kits and TREM cards [15-17]. The guidelines also detail requirements for driver qualifications and training [18]. The transportation process must follow the manifest system outlined in the HOWM Rules, 2016 [17, 19].
  • Storage of Used Oil: CA-2 agents must have designated storage facilities with features like spill containment, separate storage for different types of used oil, and adequate fire safety measures [20-22].
  • Traceability: The Collection agent shall comply with Manifest system (Movement Document) for hazardous waste, under HOWM Rules, 2016 as follows:

Copy 1 (White): Copy 1 (White) To be forwarded by the sender to the State Pollution Control.

Copy 2 (Yellow): To be retained by the sender after taking signature on it from the transporter and the rest of the five signed copies to be carried by the transporter.

Copy 3 (Pink): To be retained by the receiver (actual user or treatment storage and disposal facility operator) after receiving the waste and the remaining four copies are to be duly signed by the receiver.

Copy 4 (Orange): To be handed over to the transporter by the receiver after accepting waste.

Copy 5 (Green): To be sent by the receiver to the State Pollution Control Board.

Copy 6 (Blue): To be sent by the receiver to the sender.

Copy 7 (Grey): To be sent by the receiver to the State Pollution Control Board of the sender in case the sender is in another State.

Responsibilities of Other Stakeholders:

  • Producers and Bulk Generators: These entities are encouraged to set up collection points for used oil in collaboration with municipalities and local bodies [23].
  • SPCB/PCC: These bodies are responsible for facilitating the setup of collection points by collection agents [23].

These new guidelines provide a comprehensive framework for managing used oil in an environmentally sound manner. They emphasize the roles and responsibilities of various stakeholders, including Collection Agents, in ensuring the safe collection, handling, transportation, and storage of used oil. The implementation of these guidelines will be crucial in achieving circularity in the used oil sector and minimizing its environmental impact.


Disclaimer: Above content does not constitute any legal advice and is only provided for educational purpose.

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