“The survey is intended to help us understand the potential impact of tariffs on engine oils and hydraulic fluids for businesses and consumers,” the authority explained in a recent email to Lube Report. The regulator added that such surveys allow them to “gather evidence from supply chain businesses and consumers that may be affected by a potential tariff measure.”

The case of dumping of engine oils and hydraulic fluids has stirred significant concern among leading U.K. lubricant marketers.

Earlier this year, their trade body, the United Kingdom Lubricants Association, formally requested that the TRA investigate these allegations. The scope of the investigation, which began on June 17, covers trading activities by Lithuanian company SCT-Lubricants, its affiliates in the U.A.E., and U.K. importer Lubriage Ltd., based in Northampton, between April 1, 2023 and March 23, 2024.

In response to the probe, the TRA gathered information from various parties, including the accused companies, some UKLA members including Aztec Oil – the company that initiated the complaint – as well as trade representatives from the European Union, Lithuania and the U.A.E.

According to UKLA, the U.K. lubricant market amounts to about 600,000 tons of automotive and industrial lubricants annually, making it the second-largest market in Europe after Germany, not counting Russia.

Aztec, based in Chesterfield, accused Lubriage of dumping at least 10% of this volume in 2023 and a similar portion between January and September 16, 2024, “effectively doubling imports in a low-growth market.” Aztec claimed these imported oils and fluids were sold at prices significantly below both manufacturing and import costs.

The imposition of tariffs is a common practice for governments around the world. Former U.S. President Donald Trump, for example, promised to impose tariffs on various Chinese products if re-elected, a measure that some economists warn could lead to spiraling consumer prices and inflation.

However, David Whitby, a consultant in the European lubricants industry, suggested that the TRA’s potential tariffs on engine oils and hydraulic fluids could benefit U.K. lubricant producers and consumers.

“If tariffs are set at the right level, they could help to protect local suppliers,” said Whitby, who runs the U.K.-based consultancy Pathmaster Marketing Ltd. Addressing the possibility that Lubriage might circumvent tariffs by importing only base oils for domestic blending, he noted that importing base oils and additives entails additional freight and storage costs, as well as higher blending costs in the U.K.

At the time of publication, the TRA had not responded to Lube Report’s request for the survey results. Whitby speculated that they might need more time to complete the investigation.

“These [unfair trade] investigations are always thoroughly researched in the U.K.,” he said. “I’m confident that UKLA’s submission has been well considered and substantiated.

Meanwhile, SCT-Lubricants’ interests are represented by trade officials from the EU’s European Commission, Lithuania, and the U.A.E., who have urged the TRA to adhere to the World Trade Organization’s Anti-Dumping Agreement. According to Article 5.4 of the agreement, “an investigation can only be initiated if it is supported by domestic producers representing more than 50 percent of the total production of the product in question, produced by that portion of the domestic industry expressing either support for or opposition to the application.” This means the TRA must uphold principles of the free market by ensuring equal and fair conditions for all participants.

Among the key questions the TRA survey might reveal is whether the companies represented by UKLA in this case constitute over half of the U.K.’s lubricant suppliers.