Service 07 · BIS · EPR · API · ACEA · IEC · NSF H1

Regulatory &
Compliance Support

Every formulation we develop is built from day one to meet its target regulatory specification. We prepare all technical documentation for domestic and export market certification — BIS IS 13656 engine oil & IS 7623 grease, EPR used-oil registration on the CPCB portal (2024 rules), ASTM test data packages, TDS, SDS/MSDS, API SP, ACEA, IEC 60296 and NSF H1. We have guided clients through BIS certification since 2010 and understand exactly what is required to pass on the first submission — across product lines as varied as chain lubricant formulation, bio-lubricant & bio-grease formulation and railway lubricant formulation.

9+
Standards & Specs Covered
4 mo.
Avg. Formulation to BIS Cert
1st
Submission Success Rate
India + Export
Domestic & International
Standards We Cover

Every Major Lubricant
Certification Standard

BIS IS 13656
Engine Oil — India Domestic
The primary BIS standard for automotive engine oils in India. Required for any lubricant brand selling engine oil through retail channels in India. We formulate specifically to the IS 13656 grade limits and prepare the complete test data package for BIS submission.
Most Commonly Requested
BIS IS 7623
Lubricating Grease — India Domestic
BIS specification for lubricating greases — covering penetration, dropping point, water washout, and corrosion requirements. Required for grease products supplied to government tenders and large industrial customers in India.
Grease Manufacturers
BIS IS 1012
Gear Oil — India Domestic
BIS standard for automotive gear oils. Covers GL-4 and GL-5 grade gear oils for manual gearboxes and differentials. Required for branded gear oil products in the Indian market.
Gear Oil Producers
API SN / SP / SN+
Petrol Engine Oil — International
API SP is the current highest petrol engine oil category. Required for export markets, OEM supply, and premium domestic branded products. We design additive systems to meet API SP performance limits across all ASTM engine test requirements.
Export & OEM Supply
API CF / CI-4 / CJ-4 / CK-4
Diesel Engine Oil — International
API CK-4 is the current heavy-duty diesel engine oil category. Required for modern low-emission diesel engines meeting Euro VI equivalent emissions standards. Critical for commercial vehicle OEM supply.
Commercial Vehicles
ACEA A3/B4 · E4/E6
European Standards
ACEA sequences are required for European OEM approvals (Mercedes-Benz, Volkswagen, BMW, Renault) and for export to European and Middle East markets. We design formulations to meet ACEA sequences and prepare the technical file.
Europe & Middle East
IEC 60296
Transformer Oil
International standard for unused mineral insulating oil for transformers and switchgear. Covers dielectric strength, moisture content, oxidation stability, and pour point. Required for transformer oil supplied to power utilities.
Power Utilities
NSF H1
Food Grade Lubricants
NSF H1 registration is required for lubricants used in food processing equipment where incidental food contact may occur. Requires using only NSF-approved ingredients. We formulate NSF H1 compliant greases and oils and advise on registration with NSF International.
Food & Pharma
BIS IS 335
Transformer Oil — India
BIS IS 335 is the Indian standard for mineral insulating oil for transformers, equivalent to IEC 60296. Required for transformer oil supply to Indian power utilities and government electrical projects.
Indian Power Sector
Documentation We Prepare

Every Document You
Need for Certification

DocumentPurposeStandard / BodyIncluded For
ASTM Test Data PackageAll required test results compiled against specification limits with pass/fail status for each propertyBIS / API / ACEAAll certification projects
Technical Data Sheet (TDS)Product specification sheet with all ASTM properties, typical values, and grade information — formatted for customer and end-user useCustomer-facingAll formulation projects
Safety Data Sheet (SDS / MSDS)16-section GHS-compliant SDS covering hazard classification, handling, storage, first aid, disposal, and transportation informationGHS / Indian RegulationsAll formulation projects
BIS Application Supporting DocumentTest data organised in BIS-required format with accredited lab names, sample identifiers, and test date recordsBIS / BEEBIS certification projects
Blending / Manufacturing SOPProduction procedure for your factory team — addition sequence, temperatures, hold times, QC checkpointsInternal productionAll formulation projects
QC Acceptance ProtocolWhich tests to run on every production batch, acceptance limits, corrective actions — for your in-house QC teamInternal QCAll formulation projects
API Certification DocumentationPerformance claim documentation formatted for API licensing — links ASTM test results to specific API category requirementsAPIAPI certification projects
ACEA Technical FileEuropean Automobile Manufacturers Association test file compilation for ACEA sequence claimsACEAACEA projects
The Certification Process

From Blank Sheet to
Certified Product

1
Target Specification Selection
The first decision is which specification to certify against — and sometimes this is not obvious. We help clients choose the right specification for their target market, production scale, and budget. Certifying for BIS IS 13656 (Indian domestic) versus API SP (export and premium domestic) involves different ASTM test requirements, different cost implications, and different commercial positioning.
2
Specification-Targeted Formulation
Once the target specification is chosen, we formulate specifically to pass it. Every additive component is selected and dosed to ensure every test limit in the specification is comfortably met — not just barely passed. A formulation that passes BIS with 10% headroom on every test is far more reliable in production than one that passes on the margin.
3
NABL-Accredited Lab Testing
All tests required for the target specification are submitted to NABL-accredited laboratories. For BIS IS 13656, this includes the full set of ASTM tests specified in Annexure A of the standard. We manage the lab submission, sample dispatch, and follow up on results. All test certificates are retained with lab accreditation number and test date.
4
Test Data Package Compilation
On receipt of all test results, we compile the certification test data package: every test result tabulated against the standard limit, clearly showing pass status for each property. For BIS, this is organised in the format expected by the BIS certification inspector. We review every result — a result that technically passes but is very close to the limit may trigger a reformulation discussion before submission.
5
Documentation Delivery & Submission Support
The complete document package is delivered: test data compilation, TDS, SDS/MSDS, blending SOP, and QC protocol. For BIS certification, we advise on which accredited test labs to select, the sample submission procedure, and the inspection process. We remain available to answer any technical questions raised by the BIS inspector during the review.
Case Study

Five Engine Oil Grades
BIS Certified in 4 Months

Completed Project · BIS IS 13656 Certification
Complete Engine Oil Range Certification — Rajasthan Manufacturer Entering Branded Market
A Rajasthan-based lubricant company entering the branded engine oil retail market needed BIS IS 13656 certification for a full product range: 5W-30, 10W-30, 15W-40, 20W-40, and 20W-50. They had no existing formulations and had never gone through a BIS certification process. The engagement began with zero — no formula, no test data, no documentation — a typical position for anyone looking to start a lubricant business in India.
We developed a unified additive system that allowed all five grades to share the same additive package with grade-specific VII and base oil adjustments. All five grades were blended and submitted for the full ASTM test suite required by IS 13656, Annexure A. We prepared the complete BIS documentation package for all five grades simultaneously. We also prepared TDS and GHS-compliant SDS/MSDS for all five grades and a master blending SOP.
Grades Certified
All 5 on first submission
Total Timeline
4 months from project start to certification
Documents Delivered
5 TDS, 5 SDS, BIS test package, blending SOP
Prior Experience
Client had zero prior BIS certification experience
India 2024–27 Compliance · CPCB

EPR for Used Oil —
2025–26 Targets, Deadlines & Penalties

Extended Producer Responsibility for used oil took effect in India on 1 April 2024 under amendments to the Hazardous and Other Wastes (Management and Transboundary Movement) Rules. Every base-oil producer, lubricant manufacturer, and lubricant importer is now responsible for the collection and environmentally sound disposal/recycling of a fixed percentage of the oil they place on the market. The percentage rises every year.

Financial YearEPR Target (% of base-oil quantity placed on market)What This Means in PracticeDeadline to File Half-Yearly Return
FY 2024–255%For every 100 kL of new base oil sold/imported, 5 kL equivalent of used oil must be collected & channelised to a CPCB-authorised recycler.30 Oct 2024 & 30 Apr 2025
FY 2025–2610%Target doubles. Producers with no in-house collection must purchase EPR certificates from registered recyclers.30 Oct 2025 & 30 Apr 2026
FY 2026–2720%Target doubles again. Shortfall triggers Environmental Compensation (EC) per the Rules.30 Oct 2026 & 30 Apr 2027
FY 2027–28 onwards50%+ (notified annually)CPCB notifies an updated target each year, aligned with the Hazardous Waste Rules baseline.Half-yearly per Rule notification

Who Must Register on the CPCB EPR Portal

PRODUCER
Lubricant & Grease Manufacturer
Any entity that manufactures and sells lubricant or grease in the Indian domestic market must register as a Producer on the CPCB EPR portal. Registration covers all SKUs and base-oil grades supplied.
Mandatory
IMPORTER
Base Oil & Finished-Lubricant Importer
Importers of base oil, finished engine oil, hydraulic oil, or grease must register on the EPR portal and meet the same targets as domestic producers. Customs clearance is increasingly linked to EPR registration status.
Mandatory
RECYCLER
CPCB-Authorised Used-Oil Recycler
Registered re-refiners and recyclers issue EPR certificates against the volume of used oil they channelise. Producers buy these certificates to demonstrate compliance with their annual target.
Sells EPR Certificates

5-Step CPCB EPR Registration Process

1
Document Preparation
Gather company KYC (PAN, GST, CIN), factory licence, BIS / ISI certificate(s), MoEFCC consent (CTO), product list with annual base-oil quantity, and the authorised signatory authorisation letter. Importers add IEC certificate and customs data.
2
Online Portal Registration
Register on the CPCB EPR portal (eprusedoil.cpcb.gov.in). Submit Form 1 with company details, product categories, and projected base-oil quantity for the financial year. A unique EPR Registration Number is issued on approval, typically within 30–60 days.
3
Annual Target Acknowledgement
Once registered, the producer’s annual EPR obligation for the year is calculated as: (annual base-oil quantity placed on market) × (year-specific %). Acknowledge the target on the portal at the start of each FY.
4
Channelisation & EPR Certificate Procurement
Either set up own collection through authorised aggregators, or purchase EPR certificates from CPCB-registered recyclers. Each certificate represents a kg of used oil channelised. Maintain a verifiable audit trail and manifest copies.
5
Half-Yearly Returns & Annual Audit
File Form 3 half-yearly returns on the portal (30 October & 30 April every year). At year-end, the EPR fulfilment is audited and any shortfall attracts Environmental Compensation. Records must be retained for 5 years.
Penalty Schedule · What Non-Compliance Costs
Environmental Compensation Levels Under the Used Oil EPR Framework
Producers failing to meet the annual EPR target pay Environmental Compensation (EC) at rates fixed by CPCB. EC is calculated per kg of shortfall. Repeated non-compliance can result in suspension of the EPR Registration Number — which in turn affects the company’s ability to sell lubricants through organised retail and to clear imports through customs.
Year 1 Shortfall
EC at notified rate per kg
Year 2 Shortfall
EC + portal access restricted
Repeated Failure
EPR registration may be suspended
Non-Registered Producer
Cannot legally place product on market

Why a Lubricant-Domain Consultant Wins Here

Generic environmental-compliance firms can fill the CPCB forms. They can’t advise on which base oil chemistry attracts higher used-oil recovery value, how a re-refining process actually works, or whether your formulation will survive the re-refining cycle. Lubechem combines EPR registration support with our underlying lubricant chemistry knowledge — often as part of an ongoing annual R&D partnership — so the same engagement that gets you registered also tells you how to design your products and choose recycler partners that minimise the per-kg compliance cost. Compliance work dovetails with our lubricant process optimisation, lubricant & grease plant setup and lubricant & grease troubleshooting practices. We have advised manufacturers on used-oil re-refining process design since the original Hazardous Waste Rules of 2008. See our Product Development R&D service for waste-oil re-refining process advisory.

Questions & Answers

Frequently Asked About
Compliance & Certification

Is BIS IS 13656 certification mandatory to sell engine oil in India?

BIS certification under IS 13656 is mandatory for engine oils sold under the ISI mark — and practically speaking, most organised retail channels and distributors in India require it. Without BIS IS 13656 certification, you cannot use the ISI mark and your product will face significant market access barriers.

Selling to industrial customers (bulk, non-retail) may be possible without BIS certification, but we always recommend certifying — the process is straightforward for a correctly formulated product and significantly expands your market access.

How long does BIS IS 13656 certification typically take?

For a single grade with a correctly formulated product, the process from formulation start to certification typically takes 3 to 5 months. The largest variable is ASTM test lab turnaround — the full IS 13656 Annexure A test suite can take 6 to 10 weeks to complete through an NABL lab.

For a full range of 4–6 grades sharing a common additive system, we can often run all grades through testing simultaneously, so the total timeline is similar to a single grade. We have completed 5-grade certifications in 4 months.

Do you handle the BIS application submission on our behalf?
We prepare the complete technical documentation package and advise you on every step of the BIS submission process. The formal application is submitted by the licence applicant (your company) — BIS requires the manufacturer to be the applicant. We guide you through the online BIS portal submission, help you prepare the factory inspection documentation, and remain available to respond to any technical questions from BIS inspectors.
Can you help us get API or ACEA claims for export markets?

Yes. API certification (licensing to display the API donut mark) and ACEA sequence claims can be pursued for export markets and premium domestic products. We design formulations to meet the ASTM engine test limits for the relevant API or ACEA category and prepare the technical data file.

API licensing involves submitting performance claims to the API Institute and paying the applicable licence fee. ACEA claims are self-certification against the ACEA published sequences. We advise on the appropriate route and prepare all technical documentation.

Our BIS certification was rejected. Can you diagnose the failure and get us certified?
Yes — share the BIS rejection notice or the specific test result that failed. In our experience, BIS failures fall into three main categories: formulation issues (an ASTM property genuinely out of specification), test lab issues (a lab error or calibration problem), or documentation issues (a test result submitted for the wrong sample). We diagnose which it is, take the appropriate corrective action, and guide the resubmission.
Do you handle ISO 22241 (DEF/AdBlue quality) certification?
ISO 22241 quality assurance for Diesel Exhaust Fluid (DEF/AdBlue) is within our advisory scope. The standard covers urea concentration, purity, and contamination requirements for SCR emission control systems. We can advise on quality requirements and connect you with accredited testing facilities, though DEF production is a specialised manufacturing area distinct from lubricant blending.
Does EPR for used oil apply to importers as well as manufacturers?

Yes. Under the 2024 amendments to the Hazardous Waste Rules, importers of base oil and finished lubricant are treated as Producers and must register on the CPCB EPR portal. The annual target percentage is calculated on the quantity placed on the Indian market — whether manufactured domestically or imported. Customs clearance increasingly requires a valid EPR Registration Number.

Can I buy EPR certificates to meet my target instead of setting up collection?

Yes. CPCB-registered re-refiners and recyclers issue EPR certificates against the quantity of used oil they channelise and process. Producers buy these certificates to demonstrate target fulfilment. This is the practical compliance route for most small and mid-sized lubricant manufacturers — setting up an in-house collection network is expensive and not justified below a certain production scale.

We help clients identify and onboard reliable CPCB-registered recyclers, negotiate certificate rates, and maintain the manifest audit trail required for the half-yearly Form 3 return.

What is the penalty for missing my EPR used-oil target?
Producers failing to meet the annual target pay Environmental Compensation (EC) per kg of shortfall at the rate notified by CPCB. Repeated non-compliance can lead to suspension of the EPR Registration Number — which restricts the producer’s ability to place product on the market through organised channels. Non-registered producers face stop-sale notices.
Related Services

Certification Starts
With Formulation

Need BIS, API, or ACEA
Certification Support?

Tell us which specification you need and where you are in the process. We respond within one business day with an honest assessment of what is required.