ATIEL & UEIL Joint Sustainability Committee
• Data Management: Tracking and reporting on EPR-related activities to ensure transparency and accountability.
• Organizing and Supervising: Coordinating and overseeing EPR operations to maintain compliance and operational efficiency.
Through EPR schemes, stakeholders, including producers, waste oil collectors, re-refining facilities, consumers, and local authorities, collectively contribute to a more responsible and sustainable approach to managing lubricating oils. However, while stakeholder engagement is vital, alone is not sufficient to ensure the success of robust EPR schemes. The effectiveness of these schemes depends significantly on the consistency and strength of national legislation. This includes establishing clear collection and recycling targets, enforcing the waste hierarchy, and deploying rigorous oversight tomonitor performance and verify compliance.
Beyond legislation, several other factors contribute to the successful operation of EPR schemes for waste oils. These include establishing efficient collection networks that ensure broad coverage, as well as promoting separate collection practices to avoid contamination and ensure the quality of waste oils for re-refining. Furthermore, education and awareness campaigns play a critical role in informing consumers about existing collection schemes and the hazards associated with improper waste oil management, thereby encouraging compliance with best practices.
Several well-established EPR schemes for waste oils are operational across Europe, serving as benchmarks for best practices. These initiatives have achieved high collection and recycling rates while significantly reducing the environmental impact associated with improper disposal or misuse of waste oils.
3.5 Cross-Border Shipping of Waste Oil
There is no single sentence in EU law that explicitly defines "cross-border shipment of waste oil." However, the shipment of waste oil is primarily governed by Regulation (EU) 2024/115715 16
on
shipments of waste, which provides a general definition of "shipment of waste" in Article 2. According to this regulation, a shipment of waste oil refers to the transport of oil waste destined for recovery or disposal, either across EU Member State borders or to/from non-EU countries. The regulation aligns with the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal and establishes procedures to protect human health, prevent environmental harm, and promote a circular economy while ensuring compliance with OECD rules.
The execution of a transboundary shipment of waste oil requires significant preparation, as prior consent from both sending and receiving authorities is needed through a notification process. Due to the hazardous nature of waste oil, strict documentation is required, including a commercial contract, detailed waste oil analysis, insurance coverage, declaration of return obligations, security payment, and transport details. All shipments must be electronically declared in advance and approved before transport. Additionally, waste oil recovery must occur at authorized facilities, and records must be kept for at least five years to ensure traceability and compliance. To maximize the environmental benefits of waste oil regeneration the regeneration
15 Summary of Regulation (EU) 2024/1157 on shipments of waste,
https://eur-lex.europa.eu/legal- REGULATION (EU) 2024/1157, Regulation on Shipments of Waste, European Parliament, https://eur-
content/EN/TXT/?uri=legissum:4757304 16
lex.europa.eu/eli/reg/2024/1157/oj/eng Version 11.06.2025 © ATIEL and UEIL Lubricants & Greases End of Life, Sustainable Best Practices Page 11 of 42
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