CPCB Notice on GST-Linked EPR Certificates for Used Oil Recyclers and Producers

Introduction to the EPR Framework for Used Oil

The Ministry of Environment, Forest and Climate Change (MoEF&CC) has already notified the Hazardous and Other Wastes (Management and Transboundary Movement) Second Amendment Rules, 2023, on 18 May 2023. These Rules mainly came into force on 1 April 2024 and introduced the Extended Producer Responsibility (EPR) framework for used oil management in India.

First, let us understand what all is actually covered under this framework:

• Used Oil Recyclers were required to generate EPR Certificates through the EPR Used Oil Portal.
• Producers are required to fulfill their EPR obligations by purchasing these EPR Certificates.

However, in order to strengthen transparency as well as to prevent misuse of the EPR mechanism, the Central Pollution Control Board (CPCB) has now issued a new notice introducing stricter requirements related to GST-linked invoicing for EPR Certificate generation.

Key Changes You Should Know

A. GST-Linked Invoices Now Mandatory for EPR Certificate Generation

• CPCB has mainly clarified that recyclers who are generating EPR Certificates must maintain records of sales of recycled products through invoices that are linked to GST.
• The generation of EPR Certificates must be supported by genuine sales transactions that will be documented through GST-compliant invoices.

B. Recyclers Must Register for GST E-Invoicing

• Recyclers that do not currently have arrangements for GST-linked e-invoicing have been advised to immediately register for GST e-invoicing systems.
• This is necessary in order to ensure continued eligibility for EPR Certificate generation on the Used Oil EPR Portal.

C. Non-GST E-Invoices Will Not Be Accepted After 30 June 2026

• After 30 June 2026, EPR Certificates that will be generated based on recycled product sales invoices and that are not linked to GST e-invoicing will not be considered valid.
• This means only GST-linked sales invoices will be accepted for generating EPR Certificates going forward.

D. Invalid Certificates May Be Treated as Non-Compliance

CPCB has further clarified that EPR Certificates that will be generated using non-GST-linked invoices after the specified deadline may be treated as:

• False certificates / Invalid certificates
• Non-compliance under the Hazardous and Other Wastes (Management and Transboundary Movement) Second Amendment Rules, 2023

E. Producers Must Accept Only GST-Linked Invoices

• The notice also places major responsibility on Producers who are registering for an EPR.
• Moreover, producers must ensure that recycled products purchased from used oil recyclers are supported by GST-linked sales e-invoices.

What is the Date of Implementation?

The original rules have been effective from 1 April 2024; however, this notice frames the deadline for GST-linked E-invoicing compliance to be 30th June 2026. 

Note: From 1 July 2026 onwards, EPR Certificates that are generated using non-GST-linked invoices may not be considered valid.

Benefits of this Order for the Businesses

The latest CPCB notice is basically expected in order to strengthen the credibility as well as transparency of the Used Oil EPR system. Here are some of the key benefits of this new enforcement for businesses:

• Improved traceability of recycled product sales.
• Enhanced authenticity of EPR Certificates.
• Reduction in fraudulent certificate generation.
• Greater confidence for Producers purchasing EPR Certificates.
• Better regulatory oversight and compliance monitoring.
• Stronger alignment between GST records and EPR transactions.
• Increased transparency across the used oil recycling sector.

Now, What to Do?

Used Oil Recyclers as well as Producers should immediately review their current invoicing and EPR compliance practices in order to ensure compliance with the new enforcement guidelines. Here is what each business entity should consider:

For Recyclers:

• Ensure GST registration is active and compliant.
• Implement GST-linked e-invoicing systems without any delay.
• Maintain proper records of recycled product sales.
• Verify that all future EPR Certificate claims are supported by GST-compliant invoices.
• Review existing documentation processes before the 30 June 2026 deadline.

For Producers:

• Verify the authenticity of EPR Certificates before purchase.
• Ensure recycled products procured from recyclers are backed by GST-linked invoices.
• Strengthen internal due diligence procedures for EPR compliance.

At Brand Liaison, we assist recyclers, producers, as well as waste management stakeholders in navigating evolving EPR regulations. Our team helps businesses review compliance systems, assess documentation requirements, streamline EPR registrations, and reduce compliance risks.