The used motor oil that is emptied after every oil change in a vehicle is a hazardous waste, but the failure to comply with pollution regulations at service stations for its disposal has worsened the pollution of air and water in India. At most roadside service stations in the informal sector, used oil is dumped into drains, which find their way into rivers and water bodies in cities like Guwahati without effluent treatment plants and pollute sources of fresh water A large number of service stations illegally sell used oil to industries for use as cooking oil without reprocessing or refining, which increases air pollution. The draft notification issued by the Ministry of Environment and Climate Change proposing extended producer responsibility (EPR) regulations for used oil offers a solution to the problem that is based on the concept of circular economy. The draft notification highlights that one liter of used oil can contaminate one million liters of fresh water, an annual supply for 50 people, as it contains toxic substances such as benzene, lead, zinc and cadmium , as well as impurities such as dirt, metal parts and water. With the country’s third largest and expanding road network, 323 million registered vehicles tell the story of the spectacular growth of the automobile industry. The growth story also points to the potential dangers of the increased volume of used oil and lube oil in the country, if the sources that generate it continue to violate pollution standards while they are being disposed of. The notification proposes to make the registration of producers, collection agents, used oil importers and recyclers mandatory on the Central Pollution Control Board (CPCB) portal. It also proposes a gradual increase in EPR targets for these stakeholders, starting with 10% in 2024-2025 and increasing by 10% annually to reach 50% of base oil or lubrication sold or imported in 2028-2029. For the management of used oil, the EPR regulation covers the production of refined base oil or lubricating oil and energy recovery. Refining is defined as any process of removing undesirable impurities from used oil and manufacturing the final product base oil or lubricating oil. The notification explains that refining used lubricants could bring both environmental and economic benefits. Refining used oil to make base oil saves more energy than reprocessing used oil for use as fuel. The energy required to make refined base oil from used oil is only one third of the energy required to refine crude oil to produce virgin base oil, which adds to and deepens the advantages of the economics approach circular for the disposal of used oil. oil The Management and Transboundary Movement of Hazardous and Other Wastes Rules, 2016 (HOWM Rule, 2016) under the Environment Protection Act, 1986 provide the legal framework to ensure a handling, generation, processing, treatment, packaging , safe storage and transport. , collection and disposal of hazardous and other waste. The National Inventory of Hazardous and Other Waste Generation and Management (2021-22) published by the CPCB in February 2023 highlights that there are 78,437 hazardous generating units, of which 71,961 have authorization and 15,970 are exempt from authorization, but only 53,487 units (ie 68%) submitted an annual statement on generation, storage, recycling, utilization, disposal, etc. of hazardous waste for the year 2021-22. The inventory data highlights that there are currently 2297 recyclers with an authorized capacity of 9.42 million MT in the country, with Maharashtra leading the chart with 411 recyclers, followed by Gujarat with 327 units and Uttar Pradesh with 232 units. However, by 2021-2022, only 17% of the authorized capacity, i.e. 1.63 million MT of hazardous waste, will have been recycled. These figures highlight the challenges of complying with the EPR or other regulatory rules aimed at reducing the carbon footprint and addressing pollution issues through a circular economy approach, such as that proposed in the draft notification . The fact that the CPCB or the state Pollution Control Board is not enforcing the ban on single-use plastics effectively speaks volumes about the challenges of monitoring with limited manpower. Achieving the goals of banning SUP or recycling e-waste or hazardous waste is critical to making the circular economy approach based on the 3R principle (reduce, reuse and recycle) the pivot of change mitigation climate by reducing environmental pollution and the carbon footprint. . Without strengthening the CPCB or SPCB with more trained personnel, overburdening the regulatory bodies with more monitoring and inspection duties, in addition to their routine inspections for enforcement of pollution norms, will not ensure the expected benefits of the ‘draft notification. Awareness among interested parties about the problems and available solutions. The increase in environmental pollution that exacerbates the impacts of climate change, despite the challenges of addressing them, is a harsh reality, and the only way to address it is through strict enforcement of pollution control standards. the pollution. Addressing systemic problems and structural challenges is the key to overcoming the challenges of circular economy solutions to environmental pollution.