What Permits Are Required to Set Up an Industrial Used Oil Recycling Plant in Southeast Asia, the Middle East, and Africa?

Setting up an industrial used oil recycling plant requires several approvals, mainly covering environmental impact assessment, hazardous waste treatment, industrial operation, and pollution control. The specific permits depend on the country, the type of used oil, processing capacity, and recycling technology.

This guide focuses on industrial waste oils, including used engine oil, used motor oil, waste lubricating oil, hydraulic oil, and gear oil. It covers facilities that collect, store, filter, dewater, distill, or re-refine used oil into recovered oil products or regenerated base oil. It does not cover used cooking oil or biodiesel production.

What Permits Are Generally Required?

Before comparing individual countries, investors should understand the main approval categories.

Permit / Approval	Main Purpose	When It Is Required
Business Registration	Legally establish the company and register its business activities.	For establishing the business.
Investment Registration	Approve foreign investment or the proposed investment project.	Where required by local investment laws.
Land-use / Zoning Approval	Confirm that the site can be used for industrial waste treatment.	Before construction or site development.
Environmental Impact Assessment (EIA)	Assess impacts on air, water, soil, and surrounding communities.	Depending on project category, capacity, and location.
Environmental Permit / Authorisation	Authorize regulated environmental activities and establish operating conditions.	According to the country’s environmental licensing system.
Waste Treatment License	Authorize the treatment, recycling, or recovery of regulated waste oil.	When the facility receives and treats waste oil covered by licensing rules.
Waste Collection / Transportation License	Authorize the collection and transportation of used oil.	If the company performs these activities.
Factory / Industrial License	Approve the construction and operation of the industrial facility.	Depending on factory classification and local thresholds.
Air Emissions / Wastewater Approval	Regulate exhaust gas, wastewater discharge, and pollution control.	When the plant’s emissions or discharges trigger separate controls.
Fire and Safety Approval	Verify fire protection, oil storage, and workplace safety arrangements.	According to local industrial and safety requirements.

Waste collection, transportation, storage, treatment, and re-refining are different activities. A collection or transportation license does not automatically authorize a company to operate a recycling or re-refining plant.

Southeast Asia: Vietnam, Indonesia, and Thailand

Vietnam

Main regulatory authorities: Ministry of Agriculture and Environment and relevant provincial authorities.

Main legal framework:

• Law on Environmental Protection No. 72/2020/QH14.
• Decree No. 08/2022/ND-CP, as amended.

Permit / Document	Purpose
Enterprise Registration Certificate (ERC)	Establish the Vietnamese company.
Investment Registration Certificate (IRC)	Register the investment project where required.
Environmental Impact Assessment (EIA)	Assess environmental impacts if the project falls within the applicable categories.
Environmental License (Giấy phép môi trường)	Authorize the project’s regulated environmental activities.
Hazardous Waste Treatment Service Eligibility	Additional conditions apply when the facility receives and treats hazardous waste generated by other companies.
Construction and Fire Safety Approvals	Cover facility construction, fire prevention, and safety requirements.

The distinction between processing a company’s own waste and accepting waste oil from external generators is important. Commercial hazardous waste treatment may trigger additional eligibility and technical requirements. An Environmental License alone should not be assumed to cover every hazardous waste treatment activity.

Indonesia

Main regulatory authorities: Ministry of Environment and relevant environmental authorities; licensing applications are handled through the OSS system.

Main legal framework: Government Regulation No. 22 of 2021 on Environmental Protection and Management.

Permit / Document	Purpose
Business Identification Number (NIB)	Register the business through the OSS system.
Environmental Approval (Persetujuan Lingkungan)	Obtain the required environmental approval.
AMDAL or UKL-UPL	Complete the environmental assessment applicable to the project category.
Technical Approval (Persetujuan Teknis)	Meet technical requirements for regulated pollution control or waste management activities.
Operational Eligibility / SLO	Complete applicable operational verification before operation.
B3 Waste Management Authorization	Obtain the authorization required for the relevant hazardous waste treatment or utilization activities.

Used lubricating oil must be assessed under Indonesia’s B3 hazardous and toxic waste classification system. The required authorization depends on whether the plant collects, stores, utilizes, or treats the waste. These activities should not be treated as one general permit.

Thailand

Main regulatory authorities: Department of Industrial Works (DIW) and relevant local authorities.

Main legal framework: Factory Act B.E. 2535 (1992) and industrial waste management regulations.

Permit / Document	Purpose
Company Registration	Establish the company and register its industrial activities.
Factory License (Ror Ngor. 4 / รง.4)	Required when the factory’s classification and applicable thresholds trigger licensing.
Industrial Waste Management Approval	Authorize the receipt and management of regulated industrial waste.
Waste Transportation / Tracking Documents	Control the movement of used oil from generators to the recycling facility.
Environmental and Pollution-control Approvals	Address emissions, wastewater, and industrial waste residues.
Construction and Fire Safety Approvals	Cover factory construction and safety requirements.

The factory category determines whether a factory license is required and which conditions apply. A facility treating industrial waste may have different requirements from a conventional manufacturing factory. Investors should confirm the classification with DIW before selecting a site.

Middle East: UAE, Saudi Arabia, and Oman

United Arab Emirates (UAE)

Main regulatory authorities: Federal environmental authorities and the competent environmental authority in the relevant emirate.

Main legal framework: Cabinet Resolution No. 33 of 2018 Regarding the Circulation of the Waste Oils.

Permit / Document	Purpose
Company and Industrial Activity Registration	Register the business and intended recycling activity.
Environmental Approval	Obtain approval from the competent environmental authority.
Waste Oil Treatment Authorization	Confirm authorization to treat and recycle waste oils under the applicable regulations.
Waste Collection / Transportation Approval	Required if the company collects or transports used oil.
Industrial and Construction Approvals	Authorize site development and industrial operation.
Fire and Safety Approval	Verify oil storage, processing equipment, and fire protection.

The UAE has a federal framework for waste oils, but local implementation and project approvals are handled by the competent authorities in each emirate. Requirements in Dubai, Abu Dhabi, Sharjah, and other emirates may differ.

Saudi Arabia

Main regulatory authorities: National Center for Waste Management (MWAN) and National Center for Environmental Compliance (NCEC), together with relevant industrial authorities.

Main legal framework: Waste Management Law.

Permit / Document	Purpose
Company / Investment Registration	Establish the company and complete applicable investment procedures.
Environmental Permit	Obtain the environmental approval required for the facility.
Hazardous Waste Treatment License	Authorize treatment of waste classified as hazardous, where applicable.
Hazardous Waste Collection License	Authorize collection activities, if performed by the company.
Hazardous Waste Transportation License	Authorize transportation activities, if performed by the company.
Industrial and Construction Approvals	Cover factory development and operation.
Pollution-control and Safety Approvals	Address emissions, wastewater, residues, and workplace safety.

MWAN distinguishes between hazardous waste treatment, collection, and transportation licensing. A recycling plant receiving used oil for treatment should apply for the authorization that covers its actual operations.

Oman

Main regulatory authority: Environment Authority.

Main legal framework: Environmental Protection and Pollution Control Law and applicable hazardous waste management regulations.

Permit / Document	Purpose
Company Registration	Establish the business and register the relevant activities.
Environmental Permit	Approve the facility’s environmental activities.
Waste Management License	Authorize applicable hazardous waste treatment, storage, collection, transportation, or reuse activities.
Waste Management Plan	Describe waste types, quantities, handling, and treatment processes.
Site Coordinates and Facility Information	Identify the proposed waste management facility.
Civil Defense Approval	Address fire protection and safety where applicable.

Oman’s Environment Authority provides a Waste Management License service for companies handling hazardous waste. The application for a treatment facility requires information about the site, environmental permit, and waste management plan.

Africa: South Africa, Kenya, Nigeria, and Tanzania

South Africa

Main regulatory authorities: Department of Forestry, Fisheries and the Environment (DFFE), provincial environmental authorities, and relevant local authorities.

Main legal framework: National Environmental Management: Waste Act 59 of 2008 (NEMWA).

Permit / Document	Purpose
Company Registration	Establish the business.
Environmental Authorisation	Approve listed activities where required.
Waste Management Licence (WML)	Authorize waste management activities listed under NEMWA.
Air Emissions Licence (AEL)	Control listed atmospheric emission activities where applicable.
Water Use Licence (WUL)	Authorize regulated water uses under the National Water Act.
Land-use and Building Approvals	Confirm the site’s industrial use and construction compliance.

A WML, AEL, and WUL are not automatically required for every used oil recycling project. Their applicability depends on the plant’s activities, thresholds, emissions, and water use.

Kenya

Main regulatory authority: National Environment Management Authority (NEMA).

Main legal framework:

• Environmental Management and Co-ordination Act (EMCA).
• Environmental Management and Co-ordination (Waste Management) Regulations, 2024.

Permit / Document	Purpose
Company Registration	Establish the company.
Environmental Impact Assessment	Assess project impacts where required.
Environmental Approval	Obtain the relevant NEMA approval before proceeding with regulated project activities.
Waste Management License	Authorize the operation of a regulated waste treatment facility.
Waste Transportation License	Authorize the transportation of used oil, if undertaken by the company.
Effluent Discharge Approval	Control wastewater discharge where applicable.
Air Quality Approvals	Address regulated industrial emissions where applicable.

Kenya’s 2024 Waste Management Regulations replaced the previous 2006 regulations. A plant treating used lubricating oil should confirm the applicable waste facility license and environmental assessment requirements with NEMA.

Nigeria

Main regulatory authorities: National Environmental Standards and Regulations Enforcement Agency (NESREA) and relevant state environmental agencies, such as LASEPA in Lagos.

Main regulatory framework: Federal environmental regulations and applicable state environmental laws.

Permit / Document	Purpose
Company Registration (CAC)	Legally establish the business.
Environmental Impact Assessment	Assess the project’s environmental impacts where required.
NESREA Environmental Permits	Cover applicable waste, toxic substances, air quality, or effluent activities.
State Environmental Approval	Meet additional state-level requirements for waste oil handling and recycling.
Industrial and Construction Approvals	Authorize factory development and operation.
Fire and Safety Approval	Address oil storage and processing risks.

Federal and state requirements may apply simultaneously. For example, LASEPA regulates environmental activities in Lagos State. Investors should distinguish between regulations already in force and proposed regulations when confirming used oil management requirements.

Tanzania

Main regulatory authority: National Environment Management Council (NEMC).

Main legal framework: Environmental Management (Hazardous Waste Control and Management) Regulations, 2021, GN No. 389 of 2021.

Permit / Document	Purpose
Company Registration	Establish the business.
Environmental Impact Assessment	Assess the project’s environmental impacts where required.
Hazardous Waste Management Authorization	Authorize applicable hazardous waste treatment and recycling activities.
Waste Collection / Transportation Permits	Authorize collection and transportation where performed by the company.
Facility and Operational Approvals	Cover the treatment site, equipment, and operation.
Environmental Monitoring and Reporting	Demonstrate compliance with applicable environmental conditions.

Tanzania’s hazardous waste regulations cover treatment, recycling, reuse, recovery, and disposal. A used oil re-refining facility should confirm its waste classification and treatment authorization requirements with NEMC.

Documents Required for a Used Oil Recycling Plant

Although each country has different application procedures, most regulators require similar company, site, environmental, and technical documents.

Document	Information Required
Company Registration Documents	Company name, legal representative, ownership, and registered business activities.
Investment Documents	Investment structure, project value, and foreign investment information where applicable.
Land Ownership / Lease Agreement	Proof of legal rights to use the project site.
Land-use / Zoning Approval	Confirmation that industrial waste treatment is permitted at the site.
Project Feasibility Report	Project capacity, investment, production plan, and expected output.
Process Flow Diagram	Used oil receiving, storage, pretreatment, distillation, refining, and product handling.
Equipment Specifications	Capacity and technical details of processing and pollution-control equipment.
Feedstock Information	Types, sources, quantities, and waste classification of the used oil.
Environmental Impact Assessment	Potential impacts and mitigation measures.
Waste Management Plan	Storage, handling, treatment, recycling, and disposal of residues.
Air Emission Control Plan	Exhaust gas treatment and emission-control equipment.
Wastewater Treatment Plan	Treatment and discharge arrangements for oily wastewater.
Fire and Occupational Safety Documents	Fire prevention, equipment safety, and workplace protection.
Emergency Response Plan	Procedures for oil spills, leaks, fires, and other incidents.

The process flow diagram and feedstock information are particularly important. Regulators need to understand exactly what types of used oil the facility will accept and how the plant will process them.

Typical Approval Process

Stage	Main Actions	Key Documents / Approvals
Company Establishment	Register the business and investment project.	Company registration, investment documents
Site Selection	Confirm industrial zoning and land-use suitability.	Land ownership or lease, zoning approval
Environmental Assessment	Evaluate air, water, soil, and community impacts.	EIA or applicable environmental assessment
Waste Treatment Authorization	Apply to receive and process regulated used oil.	Waste management plan, technical process documents
Construction and Factory Approval	Obtain permission to develop and install the facility.	Construction and factory approvals
Equipment Installation	Install recycling equipment and pollution-control systems.	Equipment specifications, installation records
Inspection and Operation	Complete required inspections and obtain operating authorization.	Environmental and industrial operating approvals

The sequence may vary between countries. Some approvals must be obtained before construction, while others are issued after equipment installation and inspection.

Common Licensing Issues to Avoid

Common Issue	Why It Matters
Applying only for a waste collection license	Collection authorization may not cover treatment or re-refining.
Not identifying the feedstock clearly	Different used oil types may have different waste classifications.
Choosing a site before checking zoning	A general industrial site may not permit hazardous waste treatment.
Underestimating pollution-control requirements	The plant may generate oily wastewater, exhaust gas, sludge, and spent filters.
Assuming one environmental permit covers everything	Separate waste, factory, air, water, and fire approvals may be necessary.
Planning to import used oil without checking restrictions	International waste shipments may require additional approvals under the Basel Convention and national laws.

Frequently Asked Questions