A lubricant producer can reach the end of a financial year believing its Used Oil EPR compliance is complete. The company is registered, certificates have appeared in its CPCB account and its finance team has prepared the sales figures. Then the annual return review begins and three numbers do not agree: the EPR target shown on the portal, the quantity supported by the Chartered Accountant’s records and the quantity of certificates that can actually be claimed.
That is where annual return filing becomes more than a portal exercise.
Under India’s Used Oil EPR framework, producers must meet their prescribed recycling obligations and file an annual return through the CPCB Used Oil EPR Portal. The normal statutory deadline is 30 June following the relevant financial year. Certificate procurement, sales and procurement records, adjustments and recycler transactions should therefore be reconciled before the return is finally submitted.
The Used Oil EPR framework was introduced through G.S.R. 677(E), dated 18 September 2023, by inserting Chapter VII into the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. The framework became effective from 1 April 2024.
For a producer, the annual return is effectively the year-end regulatory record connecting:
what was placed in the market → what EPR obligation arose → what valid certificates were procured → what compliance was finally achieved.
Rule 31 requires a producer of base oil or lubrication oil to register, fulfil its EPR target, undertake awareness activities and file the annual return in the portal format by the prescribed date.
This means that an active CPCB registration certificate by itself is not sufficient evidence that the year’s EPR obligation has been discharged.
The Used Oil EPR framework covers producers of base oil or lubrication oil as defined in the rules and also places specific obligations on used oil importers. Producers, collection agents, recyclers and used oil importers are required to register in their respective categories on the CPCB portal, and an entity falling in more than one specified category must register separately for the applicable categories.
For return filing, an important distinction is:
| Entity | Return position |
|---|---|
| Producer of base oil/lubrication oil | Annual return by 30 June following the relevant FY |
| Used oil importer | Annual return by 30 June following the relevant FY |
| Collection agent | Quarterly returns plus annual return |
| Recycler | Quarterly returns plus annual return |
The distinction matters because companies sometimes copy filing practices from another stakeholder category. The rules expressly require quarterly returns from collection agents and recyclers, while the producer’s Rule 31 return obligation is annual. At the same time, the producer’s EPR certificate fulfilment itself is required proportionately on a quarterly basis under Rule 29.
So, “annual return” and “quarterly EPR fulfilment” should not be treated as the same obligation.
For producers of base oil or lubrication oil, the statutory schedule increases the recycling target over time.
For FY 2026-27, the EPR obligation is:
20% of the base oil or lubrication oil sold or imported in FY 2024-25.
The schedule provides:
| EPR year | Target basis |
|---|---|
| FY 2024-25 | 5% of FY 2022-23 quantity |
| FY 2025-26 | 10% of FY 2023-24 quantity |
| FY 2026-27 | 20% of FY 2024-25 quantity |
| FY 2027-28 | 20% of FY 2025-26 quantity |
| FY 2028-29 | 40% of FY 2026-27 quantity |
| FY 2029-30 | 40% of FY 2027-28 quantity |
| FY 2030-31 onwards | 50% of quantity sold/imported in Y-2 |
For units established after 1 April 2024, the rules provide that EPR begins after two years from the end of the financial year in which the unit was established, subject to the prescribed target structure. Used oil importers have a separate target basis of 100% of used oil imported in the preceding year.
Suppose an existing lubricant producer placed 8,000 MT of covered base oil/lubrication oil in the Indian market during FY 2024-25.
For FY 2026-27:
8,000 MT × 20% = 1,600 MT
The preliminary target would therefore be 1,600 MT before considering any applicable CPCB-prescribed operational-loss adjustment or valid portal adjustments.
This example is illustrative, not a substitute for the target calculated for a particular producer on the CPCB portal.
The normal rule is straightforward: producers must file the return on or before 30 June following the financial year to which the return relates.
A special situation occurred for FY 2024-25. CPCB’s March 2026 notice recorded that the original 30 June 2025 filing timeline had been extended to 31 March 2026, and directed producers to complete both their FY 2024-25 obligation and annual return by that extended date.
That extension should not be treated as a permanent change to the normal filing rule.
Practical compliance recommendation: keep 30 June as the internal statutory deadline unless CPCB or MoEFCC issues a specific relaxation for the relevant year.
As of our review on 13 August 2026, CPCB’s live Used Oil portal continued to display the specific FY 2024-25 extension notice; no equivalent FY 2025-26 extension was identified in the notices reviewed.
CPCB issued a dedicated Guidance Document for Submission of Annual Return by Registered Producers at Used Oil EPR Portal in January 2026. It states that producers can proceed with annual filing only after successful portal registration and should first fulfil their EPR obligations through the available adjustment mechanism and transfer of certificates from registered recyclers.
The current filing sequence is:
CPCB’s January 2026 guidance also states that the annual processing charge is 25% of the registration fee, with the amount automatically captured by the portal. This figure comes from CPCB’s operational filing guidance and should be distinguished from the original statutory registration-fee provisions.
A producer should not begin with the portal. It should begin with a reconciliation file.
At minimum, the compliance team should have the current registration details, financial-year procurement data, financial-year sales data, applicable CA-certified statements, EPR target shown on the portal, certificates received from registered recyclers, adjustment-module records where relevant and awareness-program evidence ready for review. The CPCB filing guidance specifically requires CA-supported procurement and sales data and includes the awareness section in the annual-return workflow.
The practical objective is to ensure that the finance records, CA certificate and CPCB portal tell the same story.
Buying a certificate should not be treated as the final step.
The underlying rules contain several controls.
First, producers are to fulfil EPR through online purchase of certificates from registered recyclers. The information provided by the producer and recycler is subject to cross-checking on the portal, and where there is a difference, the lower figure is considered for fulfilment. Certificates may also be subject to environmental audit.
Second, a Used Oil EPR certificate is valid for two years from the end of the financial year in which it was generated, unless it is extinguished earlier under the rules.
Third, Rule 29 permits a producer to purchase certificates up to the current year’s liability, any leftover liability from preceding years and up to 10% of the current year’s liability. EPR obligation is to be met through proportionate certificate purchase on a quarterly basis. Once purchased, certificates are automatically adjusted against liability, with earlier liability receiving priority, and the adjusted certificate is extinguished.
These controls mean a certificate review should answer more than “Is it visible in the account?”
It should determine whether the certificate came from the correct registered recycler, remains valid, was transferred correctly and can actually be claimed against the producer’s liability.
This is now one of the most important checks in Used Oil EPR certificate compliance.
On 2 June 2026, CPCB issued a notice to Used Oil recyclers and producers stating that recyclers must maintain recycled-product sales records through invoices linked to GST for EPR certificate generation. Registered recyclers without GST e-invoicing arrangements were directed to register accordingly.
The notice states that EPR certificates generated from recycled-product sales invoices other than GST e-invoices will not be considered after 30 June 2026. It further says such non-GST-e-invoice-based certificates would be treated as false certificates/non-compliance and directs producers to accept GST-linked sales e-invoices for recycled products from Used Oil recyclers.
For producers, this changes certificate due diligence.
A certificate purchase decision should therefore include verification of the recycler’s portal registration and the underlying GST-linked recycled-product sales evidence applicable to the certificate-generation process.
The following is a Green Permits recommended control framework. It is a practical review tool, not a separate statutory form.
| Control point | Compare | Why it matters |
|---|---|---|
| Entity master | CPCB profile vs GST/legal records | Prevents entity and authorised-person mismatch |
| Sales data | ERP/GST/CA statement vs CPCB sales data | Drives target calculation |
| Procurement data | Purchase ledger/CA statement vs portal | Required in CPCB annual-return workflow |
| Reference year | Applicable statutory FY vs quantity used for target | Prevents wrong-year target calculation |
| EPR target | Portal target vs independent calculation | Identifies target anomalies before submission |
| Adjustments | Portal EPR Adjustment records vs commercial transfers | Avoids double counting or missed adjustment |
| Certificates | Recycler transfer records vs producer wallet | Confirms availability for compliance |
| Certificate validity | Generation FY vs two-year validity | Prevents reliance on expired certificates |
| GST e-invoice | Recycler sales evidence vs certificate generation | Important under CPCB’s June 2026 notice |
| Final compliance | Eligible certificates/adjustments vs EPR liability | Identifies remaining shortfall |
| Submission record | Final preview vs acknowledgement/download | Creates an audit trail |
The central idea is simple:
Do not start with the certificate quantity. Start with the legally correct target and work forward.
One of the easiest mistakes is saying, “The producer has to file four quarterly returns, so the annual return is simply their total.”
That is too broad.
Rule 31 expressly places an annual-return obligation on producers. Separately, Rule 29 requires the EPR obligation to be fulfilled through proportionate certificate purchases on a quarterly basis. CPCB’s producer filing interface also provides quarter/annual reporting selections as part of its operational workflow.
Recyclers, by contrast, have express quarterly and annual return responsibilities, which CPCB’s January 2026 recycler guidance also reflects.
This distinction should be maintained in compliance policies, internal calendars and consultant advice.
For FY 2026-27, an existing producer’s target is linked to FY 2024-25 quantities, not simply the immediately preceding year’s sales.
Certificate registration status, validity, portal adjustment and the underlying recycler transaction should be reviewed before the producer treats the quantity as compliant.
CPCB’s January 2026 guidance specifically tells producers to select the checkbox for certificates received from recyclers when claiming them in the annual return.
If procurement and sales data used for the return differ from books, GST-linked records or CA-certified statements, the discrepancy should be resolved before final submission.
For the post-30 June 2026 certificate-generation regime, relying on recycler sales transactions unsupported by the required GST e-invoice linkage can create certificate-compliance risk.
Because EPR fulfilment is structured on a quarterly proportionate basis, year-end certificate buying should not replace ongoing compliance planning.
The extension to 31 March 2026 was a specific relaxation for that return period.
Consider a lubricant producer whose FY 2024-25 covered quantity is recorded internally as 8,000 MT.
The FY 2026-27 statutory percentage is 20%, giving a preliminary EPR requirement of 1,600 MT.
Now suppose the CA-certified reconciliation identifies credit notes and transactions that cause the verified covered quantity to differ from the amount originally entered on the CPCB portal.
The correct response is not to buy certificates against whichever number is higher or lower without investigation.
The business should first establish the legally reportable sales/import quantity, reconcile CA records with portal records, confirm any eligible EPR adjustments, verify the certificate quantity and then establish the residual obligation.
This case is illustrative, but it demonstrates why annual-return work should start well before the submission date.
CPCB’s March 2026 producer notice warned that producers who did not fulfil their FY 2024-25 obligations could face environmental compensation for non-fulfilment and other violations under the Used Oil EPR framework.
The rules also allow regulatory action where registered entities provide false information or wilfully conceal required information, including registration revocation for up to five years after an opportunity to be heard, along with environmental compensation as applicable.
No business should therefore treat environmental compensation as an alternative method of completing EPR compliance.
The better approach is to identify the shortfall before filing and resolve the underlying target, certificate or data problem.
Before final submission, confirm that:
The normal statutory deadline for a producer is 30 June following the financial year concerned. FY 2024-25 received a specific extension to 31 March 2026.
For an existing producer, the FY 2026-27 target is 20% of the base oil or lubrication oil sold or imported during FY 2024-25.
No. The rules link producer fulfilment to certificates obtained online from registered recyclers through the EPR system.
The rules prescribe validity of two years from the end of the financial year in which the certificate was generated, unless extinguished earlier.
Yes, but the distinction matters. Rule 29 requires proportionate EPR certificate purchase on a quarterly basis, while Rule 31 sets out the producer’s annual-return obligation.
CPCB’s January 2026 producer guidance requires the user to enter financial-year procurement and sales data and upload CA-certified supporting information in the relevant sections.
CPCB’s 2 June 2026 notice states that certificates generated on the basis of recycled-product sales invoices other than GST e-invoices will not be considered after 30 June 2026, and it directs producers to accept GST-linked sales e-invoices for recycled products from Used Oil recyclers.
Used Oil EPR annual return filing is the final reconciliation of an entire year’s compliance. The return should connect the correct reference-year sales or import quantity, statutory EPR target, valid recycler certificates, applicable adjustments, CA-certified data and CPCB portal records.
For FY 2026-27, producers should pay particular attention to the 20% target linked to FY 2024-25 data, quarterly certificate fulfilment and the strengthened GST e-invoice control introduced for recycler certificate generation in June 2026.
The safest filing process is therefore not “login, enter data and submit.” It is reconcile, verify, correct and then submit.
📞 +91 78350 06182
📧 wecare@greenpermits.in
👉 Book a Consultation with Green Permits
