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Since January 1, 2022, the management of used oils has been included within the scope of EPR (Extended Producer Responsibility) schemes, via the mineral or synthetic lubricating or industrial oils sector. Producers of these oils, i.e. those who place them on the market, must join an eco-organization, which will be responsible for organizing the collection and processing of these oils.
In this context, changes (1) have been made to waste oil management and collection obligations. These changes affect the producers of this waste, i.e. the holders of used oils.
Note: this article does not deal with the obligations of producers ("marketers") in relation to this new EPR channel.
Which oils are concerned?
Those likely to generate waste oils, which are used for the following purposes:
- for heat engines and turbines,
- for gears,
- for movements,
- for compressors,
- multifunctional,
- for hydraulic systems and shock absorbers,
- for electrical use,
- for heat treatment,
- for metalworking,
- used as heat transfer fluids.
Note that soluble oils are not included in this list.
Used oils are those that have become unsuitable for the use for which they were originally intended.
Who can collect used oil?
The notions of collector and collector-grouper replace that of collector.
A used oil collector is any person engaged in the professional activity of collecting used oils from holders, without regrouping them, with a view to handing them over to a used oil collector-grouper.
A used oil collector-grouper is any person engaged in the professional activity of collecting used oils from holders and grouping them together for processing.
As of January 1, 2022, collectors and collector-regroupers no longer require approval. From July 1, 2022, they must be registered with an eco-organization and declared to the prefect for this collection and transport activity.
Note: Collectors and processing plants must always have the appropriate ICPE classification.
Which eco-organization?
CYCLEVIA has been approved (2) as an eco-organization until December 31, 2027, for the management of waste mineral or synthetic lubricating or industrial oils.
What are the obligations of used oil holders?
As the owner of such oils, you must :
- Organize separate sorting of different types of oil and other waste that could hinder their regeneration or recycling;
- have your oils collected by a collector or a collector-grouper, who will issue you (as before) with a collection slip. This slip indicates the quantity and quality of the oil collected.
Note: from January 1, 2024, the voucher will be an electronic BSD generated in Trackdéchets.
Double sampling before blending
A double sample of the oils is taken by the collector-regrouper before any mixing of the collected oils.
One is for the collector-grouper.
The other is kept either by the producer (if collection is carried out by a collector-grouper) or by the collector.
Note: we advise you to keep this sample until the final disposal of the oils. It will enable you to prove their quality in the event of a problem.
Conclusion
In practice, we recommend :
- Take your used oil to a collector or a collector-grouper;
- Ensure that it is registered with the Cyclevia eco-organization as of July1, 2022;
- Ask your collector/collector-grouper for their prefectoral waste collection and transport permit;
- For each collection, obtain a collection slip and enter this information in your waste register ;
- If you use the services of a collector-grouper, collect a sample of each batch of used oil to keep until the batch is disposed of.
(1) Decree no. 2021-1395 of October 27, 2021 on the management of used oils and the extended responsibility of producers of mineral or synthetic lubricating or industrial oils [JORF of October 29, 2021].
(2) Arrêté du 24 février 2022 portant agrément d'un éco-organisme de la filière à responsabilité élargie du producteur des huiles minérales ou synthétiques, lubrifiantes ou industrielles [JORF du 23 mars 2022].
Photo credit: 223952285 @Love the wind