Lubricant Oils: EPR Requirements and Recycling

The Department of Forestry, Fisheries, and the Environment (DFFE) introduced EPR (extended producer responsibility) for lubricant oils in 2023. Under the new regulations, all lubricant oil producers must collect and recycle used oils to prevent pollution and conserve resources.

The comprehensive guide below provides more information about EPR for lubricant oils, their effects on the environment, and how to dispose of them responsibly. It also outlines the types of oils covered by EPR and which lubricants are excluded from the current legislation.

What are Lubricant Oils?

Lubricant oils are used to prevent friction between moving mechanical parts. When you use a lubricant on machinery, it forms a thin greasy layer between the components that protects them against damage from prolonged metal-on-metal contact. Lubricant oils also reduce heat transfer between moving parts to prevent machinery from overheating.

Uses and Examples of Lubricant Oils

Motor oil – found in the engines of cars, trucks, forklifts, etc.
Grease – used on bicycle chains, gate hinges, wheel bearings, etc.
Brake fluid – transfers pressure from the brake pedals to your wheels.
Hydraulic fluid – powers cranes, car lifts, bulldozers, and other heavy machinery.
Sewing machine oil – clear lubricant for delicate machinery.
Penetrating oils – used to fix “stuck” bolts and hinges. Brands like Q20, WD-40, etc.
Gun oil – greases and protects the moving parts inside a firearm.

The Environmental Impact of Lubricant Oils

Are lubricant oils bad for the environment? They can be without proper management and disposal. Many lubricant oils contain additives that are toxic to humans and animals. Even without these additives, pollution from lubricant oils is a threat to our soil and drinking water.

Impact During Production

Many lubricants are made from crude oil, which is a fossil fuel and non-renewable resource. Drilling for oil destroys habitats and damages the soil. It also uses a lot of energy and can create unstable underground pressure systems that lead to sinkholes and earthquakes.

Once extracted, crude oil must be refined to make lubricants. The process is energy-intensive and produces chemical waste that can contaminate nature when not properly managed. Refineries also produce air pollution in the form of VOCs and sulphur dioxide.

Impact During Use

Accidental oil spills and chronic leaks from machinery are not uncommon. Lubricant oils can have devastating effects on ecosystems when they contaminate the environment. Oil does not mix with water; instead, it forms a sticky film on the surface. This can block sunlight and reduce oxygen in lakes, dams, and oceans, suffocating fish and other aquatic creatures.

Impact During Disposal

Mineral-based lubricant oils are made up of hydrocarbons. Some hydrocarbons are carcinogenic, meaning they can damage DNA. When lubricants are dumped, these hydrocarbons end up in the soil where plants and microorganisms can absorb them. This is how toxic compounds get into the food chain.

Used lubricants may also contain heavy metals and debris from machinery. All of this has the potential to end up in our soil and water. For this reason, it is crucial that we recycle lubricant oil instead of dumping it.

The Environmental Impact of Lubricant Oils

South Africa mandates extended producer responsibility for lubricant oils. That means producers (manufacturers, importers, etc.) are held liable for lubricant waste in our country. Producers must run used lubricant oil recycling programmes and encourage responsible disposal.

Types of Lubricant Oils Covered by EPR

The EPR regulations provide the following official definition for lubricant oils:

“All virgin and re-refined mineral and synthetically based lubricants, with or without additives, that are used for lubrication within heat transfer, load transfer, insulation, or any other application and can be recovered after use.”

This definition includes mineral-based oils (made from crude oil) and synthetic oils (made in a lab from petroleum by-products). All the examples listed above are included in EPR.

Oils That are Excluded From EPR

Extended producer responsibility does NOT apply to the following types of oils:

technical and medicinal white oils
vegetable oils
greases
waxes
petrolatums
two stroke oils
chainsaw cutter bar lubricants
rockdrill lubricants
water-based fluids with less than 80% oil content
phosphate esters
pesticidal and fungicidal agricultural spray base oils
process oils where the lubricant is compounded into a solid
marine engine oils
rolling oils
drawing oils
rust preventatives
mould release oils
wire rope & open gear dressings
shock absorber oils

What About Eco-Friendly Lubricants?

Bio-based lubricants are often marketed as sustainable or eco-friendly alternatives to traditional mineral or synthetic lubricant oils.

A bio-based oil is made from renewable resources like vegetable oil.
Does not contain any toxic additives or heavy metals.
Is non-bioaccumulative, meaning it does not absorb and collect in the bodies of living organisms.

Bio-based oils are not included in EPR legislation. They are not subject to extended producer responsibility, unlike lubricant oils made from crude oil and its synthetic alternatives.

EPR Obligations for Lubricant Oil Producers

All lubricant oil producers must have an extended producer responsibility scheme. An EPR scheme is a strategy for dealing with waste lubricant oils to reduce pollution in the industry.

Producers have two options for compliance:

Start their own EPR scheme and register it with the DFFE.
Join an existing, DFFE-compliant EPR scheme run by a producer responsibility organisation (PRO).

As part of the EPR scheme, producers must set up collection systems for used lubricant oil. Recycling, reuse, and recovery rates must be reported to the DFFE and SAWIC every year.

Who Qualifies as a Lubricant Oil Producer?

Producers are businesses or individuals that place lubricant oils on the South African market. The following are examples of producers liable for EPR:

Local lubricant manufacturers
Importers of foreign lubricant oils
Wholesalers that sell lubricant oils under their own brand
Agents that sell lubricants to South African customers remotely
Refurbishers that sell recycled or recovered oils

Lubricant Oil Recycling Targets for EPR

The DFFE provides recycling targets for lubricant oil producers and PROs. You should follow these targets for the first five years of your EPR scheme. They are written below as a percentage of the total amount of oil producers put on the market.

Year	Collection Target (%)	Recycled into Fuel (%)	Re-Refined Into Base Oil (%)
1	50	95	5
2	60	92.5	7.5
3	65	90	10
4	70	87.5	12.5
5	75	85	15

EPR Waste Association of South Africa

Environmentally Sound

Waste Management

Joining eWASA puts a leading environmental services association in your corner. We help you set up recycling systems for your products to ensure complete EPR compliance for your business. As a member, you join our professional community and gain access to networking events, educational resources, and participation in environmental lawmaking.

About the Lubricant Oil Recycling Process

In South Africa, most used lubricant oils that are recycled become industrial fuels for factory furnaces, kilns, and boilers. Recycling oil into fuel is a simple and accessible way to keep lubricant waste out of the environment.

Used oil is filtered to remove large impurities.
Water is removed from the oil by placing it in settling tanks.
Oil that has been reconditioned into fuel is not suitable for reuse as a lubricant.

The DFFE plans to develop the oil recycling industry to gradually recycle less oil into fuel and more into new lubricants. This process is called “re-refining” and produces a product known as re-refined base oil (RRBO). RRBO can be used to make the same high-quality lubricants as virgin oils.

Used oil is filtered and water is removed
Oil goes through propane de-asphalting to separate out bituminous elements
Clean oil is heated and vacuum distilled to remove soluble impurities

Environmental Benefits of Lubricant Oil Recycling

Recycling used lubricant oils is good for the environment because it reduces the risk of pollution to our soil and ground water. It also conserves precious resources by reducing the amount of crude oil we need to extract from the earth. In a nutshell, the environmental benefits of recycling oil are:

Prevents contamination of water sources
Reduces pollution risks that threaten fish and seabirds
Prevents soil contamination that can happen in landfills
Uses less energy to re-refine used oil than it does to extract virgin oil
Preserves our natural crude oil reserves

Economic Benefits of Lubricant Oil Recycling

Recycling lubricants can also be good for the economy. When you open an oil recycling business in South Africa, you have the opportunity to create jobs and uplift communities. Teaching people about the lubricant oil recycling process also contributes towards skills development in our country.

Creates jobs and upskills workers
Advances technological innovation
Develops new types of exports based on recycled products
Creates opportunities for entrepreneurship in the recycling space
Ensures the economy can keep running during natural resource shortages

Oil Recycling in South Africa

South Africa has a strong lubricant oil recycling industry with a reported national recovery rate of 70%. Before EPR became mandatory in 2023, most producers recycled lubricant oils voluntarily. This was largely done through the ROSE Foundation (Recycling Oil Saves the Environment).

Today, there are a wide range of producer responsibility organisations (PROs) for lubricant oils in South Africa. PROs connect producers with accredited oil recyclers and refiners to help them collect, store, transport, and recover used lubricants from end-users.

Find Used Oil Recycling Companies in South Africa

The following businesses recycle oil in South Africa. This list is not exhaustive, please contact eWASA for more information or to add your company to the directory.

Oilkol
Oil Savers
Enviroserv
Oil R Us
FFS Refiners
Fortune petroleum
Phambili Services (Pty)Ltd
Sela Waste Management
Use It Waste Beneficiation (RF) NPC

Best Practices for Collecting and Storing Used Lubricant Oils

Whether collecting used lubricant oils is your business or you’re a producer liable for EPR, lubricants are considered hazardous waste by law, and must be handled safely. Even tiny spills can contaminate water and harm birds and animals. Always keep waste oil in a controlled environment.

Storage

Put used oil in clean containers or drums with a sealable lid.
Clearly label the containers as “used lubricant oil”.
Keep your collection in a clean, dry room separate from other chemicals.

Transportation

Only work with DFFE-registered waste oil transporters
Make sure your transporter fills out a Hazardous Waste Manifest
Make sure the vehicle has the correct signage (dangerous goods placards and orange warning symbols)

Joining a Producer Responsibility Organisation for Lubricant Oils

The easiest way for lubricant oil producers to remain EPR compliant is to join a producer responsibility organisation (PRO) such as eWASA. A PRO is a not-for-profit company that runs an EPR scheme together as a group. It is made up of producers and recyclers from the industry.

A PRO can help you:

Manage extended producer responsibility lubricant oils
Submit waste information to SAWIC
Report on EPR performance to the DFFE
Find used oil recycling companies in South Africa
Run take-back schemes for used lubricant oils

Joining a PRO has many benefits for producers – it helps you stay on top of compliance, manage the admin side of EPR, and network with other stakeholders in your industry. All PROs in South Africa must be registered with the DFFE.

Join the eWASA EPR Scheme for Lubricant Oils

eWASA is a registered PRO for lubricant oils. Our EPR scheme (9/7/7/L/PRO/20240429/053) is fully compliant with the latest waste legislation and offers producers a stress-free way to fulfil their environmental obligations. We have over 15 years of experience in the EPR space and represent over 100 major South African producers across EPR-liable industries.

Please contact us for more information about eWASA, our fee structure, or how to recycle lubricant oil and other hazardous waste.

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