New procedures for managing used oils

Since January 2022, waste oils have fallen under the EPR scheme. Holders must comply with new sorting, collection, and traceability rules to ensure they are managed in accordance with regulations.

Marie Faucon
Consultante HSE
Publication : 
28.04.2022
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Please note: This article concerns French legislation. The requirements described may not apply in other countries.

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The management of waste oils has been included in the scope of EPR (Extended Producer Responsibility) schemes since January 1, 2022 via the mineral or synthetic, lubricating, or industrial oil sector. Producers of these oils—meaning those who place them on the market—must join an eco-organization, which will be responsible for organizing the collection and treatment of the oils.

In this context, changes (1) have been made to the requirements for managing and collecting waste oils. These changes affect the producers of this waste, i.e., the holders of waste oils.

Note: This article does not cover the obligations of producers ("those who place products on the market") regarding this new EPR scheme.

Which oils are covered?

Those capable of generating waste oils, which fall under the following uses:

  • for internal combustion engines and turbines,
  • for gears,
  • for movements,
  • for compressors,
  • multifunctional,
  • for hydraulic systems and shock absorbers,
  • for electrical uses,
  • for heat treatment,
  • non-soluble for metalworking,
  • used as heat transfer fluids.

Please note that soluble oils are not included in this list.

Used oils are those that have become unfit for their original intended use.

Who is authorized to collect used oils?

The terms "collector" and "collector-consolidator" have replaced the term "gatherer."

A used oil collector is any professional engaged in the collection of used oils from holders, without consolidating them, for the purpose of handing them over to a used oil collector-consolidator.

A used oil collector-consolidator is any professional engaged in the collection of used oils from holders and who consolidates them for the purpose of treatment.

As of January 1, 2022, collectors and collector-consolidators no longer require official approval. They must be registered with an eco-organization as of July 1, 2022, and must declare their collection and transport activities to the prefect.

Note: Collectors and treatment facilities must still maintain appropriate ICPE classification.

Which eco-organization?

CYCLEVIA is accredited (2) as an eco-organization until December 31, 2027, for the management of mineral or synthetic, lubricating or industrial waste oils.

What are the obligations for holders of used oils?

As a holder of such oils, you must:

  • organize the separate sorting of different types of oils and other waste that could hinder their regeneration or recycling;
  • have your oils collected by a collector or collector-consolidator who will provide you (as before) with a collection receipt. This receipt specifies, among other things, the quantity and quality of the oils collected.

Note: As of January 1, 2024, the receipt will be an electronic waste tracking slip (BSD) generated via Trackdéchets.

Double sampling before mixing

A double sample of the oils is taken by the collector-aggregator before any mixing of the collected oils occurs.

One is intended for the collector-aggregator.

The other is kept either by the producer (if the collection is carried out by a collector-aggregator) or by the collector.

Note: We recommend that you keep this sample until the final disposal of the oils. It allows you to verify their quality in the event of an issue.

Conclusion

In practice, we recommend that you:

  • Hand over your used oils to a collector or a collector-aggregator;
  • Ensure they are registered with the eco-organization Cyclevia as of July1 st, 2022;
  • Obtain their prefectural receipt for the collection and transport of waste from your collector/collector-aggregator;
  • Obtain a collection receipt for each pickup and enter this information into your waste register ;
  • If you use a collector-aggregator, obtain a sample for each batch of used oils to be kept until the batch is disposed of.

(1) Decree No. 2021-1395 of October 27, 2021, regarding the management of used oils and the extended producer responsibility for mineral or synthetic, lubricating, or industrial oils [Official Journal of October 29, 2021]

(2) Order of February 24, 2022, approving an eco-organization for the extended producer responsibility sector for mineral or synthetic, lubricating, or industrial oils [Official Journal of March 23, 2022]

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Photo credit: 223952285 @Love the wind