The logic behind Europe’s march to climate neutrality is evolving. What started primarily as an environmental sustainability agenda is now being led just as much by economic sustainability — competitiveness, industrial resilience, and reduced dependency on supply from outside European Union borders. Recent years of supply chain disruption have made this unavoidable.
For companies, this shift shows up in two parallel moves. First, policy is being streamlined through omnibus-style simplification and a more pragmatic tone from policymakers — not to abandon climate ambition, but to make implementation workable and to protect Europe’s industrial base. Second, the EU is doubling down on the idea that credibility and competitiveness will increasingly depend on transparent, comparable and machine-readable product data.
For lubricant value chains, this means moving beyond high-level sustainability commitments toward verifiable, product-level accountability. The direction is clear: Both compliance and competitive strategy will depend on the ability to generate, manage and communicate high-quality environmental data across the entire value chain, from base oils and additives to blending and to use and end of life.
In practical terms, the data expectations increasingly mirror the EU’s “horizontal” product requirements: renewable content, environmental footprint and performance, substances of concern, and recyclability, with digital traceability becoming the norm rather than the exception. This is the backdrop for a policy era that looks more pragmatic on the surface, while raising the bar on evidence, traceability and data integrity underneath.
Pragmatism Without Retreat
One of the most visible policy adjustments is the EU’s softened stance on a total phase out of internal combustion engines by 2035. The commission’s 2025 Automotive Package proposed that carmakers be required to reduce tailpipe emissions by 90% rather than 100% as previously targeted. The 10% reduction being given up would be made up by increased use of low-carbon steel produced in the region or by increased use of e-fuels or biofuels. This proposal would allow some ICE-related powertrains beyond 2035.
In 2022, the EU reached a final deal to require that all new cars and vans sold from 2035 must have zero carbon dioxide emissions, effectively ending the sale of ICEs. This agreement was part of the EU’s wider “Fit for 55” climate package, aimed at cutting emissions by 55% by 2030 from 1990 levels. The policy accelerated investment in electrification while triggering significant disruption across the automotive value chain.
Last year’s shift reflects a more pragmatic transition strategy, balancing decarbonization goals with industrial competitiveness. For the lubricants industry, this creates a longer transition timeline for ICE-related products, but it also introduces stricter expectations around sustainability performance and transparency.
At the same time, regulatory pressure is intensifying in several key areas. Environmental data requirements are expanding rapidly, including the need for product carbon footprints, Digital Product Passport readiness and improved tracking of substances of concern. Marketing claims are also under scrutiny, with a growing emphasis on accuracy and substantiation. Together, these developments signal a shift toward a compliance environment where data integrity and traceability are as important as product performance.
The Ecodesign for Sustainable Products Regulation, in force since July 2024, is central to this transformation. Although lubricants are not included in the current 2025-2030 working plan, their potential inclusion will be reassessed during a mid-term review in 2028. Once a product category falls within scope, DPPs also become mandatory. The Battery Regulation introduces one of the first mandatory product passports applying from February 2027. As DPPs will require structured, machine-readable data covering the entire product lifecycle, this means that lubricant manufacturers will need to prepare for a future where product-level reporting becomes the norm.
Circularity and Strategic Resource Independence
Parallel to the ESPR, the proposed Circular Economy Act and updates to Green Public Procurement criteria are expected to reshape market dynamics. The CEA proposal, anticipated in 2026 following a consultation process completed in late 2025, aims to increase the use of recycled materials. Industry bodies have encouraged lubricant manufacturers to adopt circular material targets aligned with or exceeding future regulatory requirements.
Meanwhile, public procurement is moving toward stronger sustainability and resilience criteria. The Commission plans to review the procurement framework during 2026, and it is also proposing minimum mandatory Green Public Procurement criteria in sectoral legislation. These changes will likely make compliance a prerequisite for participation in public-sector tenders.
Environmental claims are another area undergoing significant change. While the proposed Green Claims Directive has been paused, the Empowering Consumers for the Green Transition Directive will become enforceable from Sept. 27, 2026. This marks the beginning of a stricter enforcement phase. Generic claims such as “eco-friendly” or “sustainable” will no longer be permitted without robust, lifecycle-based evidence. Similarly, claims of “climate neutrality” based solely on offsets will be prohibited. Instead, companies must anchor their claims in measurable data, such as product carbon footprints, environmental footprint metrics, biogenic content, or demonstrated in-use performance improvements.
Corporate sustainability disclosures are also evolving. Although recent simplifications to the Corporate Sustainability Reporting Directive have reduced the number of companies directly in scope, the expectations placed on suppliers remain high. Large buyers, including original equipment manufacturers, industrial firms and fleet operators, will continue to demand CSRD-grade data from their supply chains.
The updated European Sustainability Reporting Standards, known as ESRS 2, place less emphasis on volume of data and more on quality, consistency and the concept of double materiality. For lubricant companies, this reinforces the need to be data-ready, regardless of formal reporting obligations.
Chemical Regulation
Chemical regulation adds another layer of complexity. The ongoing process to restrict per- and polyfluoroalkyl substances, referred to as PFAS or “forever chemicals,” reached a major milestone in March with publication of a final opinion on risk assessment and a draft socio-economic analysis. Some countries, including France and Denmark, have already introduced national restrictions for certain applications. Even if lubricants themselves are not directly targeted, related components such as additives, surfactants and treatment chemicals may be affected.
In parallel, the planned revision of the REACH regulation on registration, evaluation, authorization and restriction includes digital safety data sheets and alignment with DPP-related data structures, stricter update requirements and new polymer notification systems. The timing of the revision has shifted, and planning signals delays. Nevertheless, these changes can be expected to increase complexity of formulation and data management.
In response to these challenges, cross-industry collaboration is emerging as a critical strategy. The EU’s Horizontal Cooperation Guidelines, updated in 2023, explicitly allow companies to work together on in some ways on sustainability initiatives without breaching competition law. This creates opportunities for lubricant stakeholders to develop shared methodologies for calculating product carbon footprints and environmental footprints, align testing standards for in-use performance and define common data structures for DPPs. Such collaboration can help reduce compliance costs and create a more consistent regulatory environment across the industry.
Looking ahead, success in this new landscape will depend on how effectively companies manage three core areas of disclosure. First, product-level environmental data must be accurate, consistent and readily accessible. Second, supply chain transparency must improve, covering everything from base oils and additives to blending processes and OEM approvals. Third, communication must be precise and evidence-based, ensuring that all claims can withstand regulatory scrutiny. These pillars will define what “good” looks like for the lubricant value chain over the next five years.
In conclusion, Europe is not reducing regulations, it is refining and digitizing them. The bar for compliance is rising, particularly in terms of data quality and transparency. For the lubricants industry, this represents both a challenge and an opportunity. Companies that treat product data as a strategic asset, prepare early for the inevitability of Digital Product Passports, eliminate risks associated with unsubstantiated claims and engage in compliant forms of collaboration will be best positioned to succeed. In a landscape defined by data, those who adapt quickly will gain a lasting competitive advantage.
Elisa Swanson-Parbaeck is chair of the Communications Working Group of the ATIEL & UEIL Joint Sustainability Committee. She is also business development director in Engineered Fluids Solutions at Perstorp AB.
The Direction of European Carbon Footprint Regs
By Inga Herrmann
The European Union is moving quickly with the Green Deal. It is no longer only a vision; it is increasingly becoming part of the conditions under which companies operate. In Europe’s transition toward net zero, data is no longer just an input, and in the lubricants industry, focus is shifting. The baasis of competition is not limited to chemistry, but extends to how environmental performance is demonstrated.
Regulatory developments are reshaping how the industry measures, demonstrates and discloses environmental performance. These policies affect raw materials, finished products, customers and their business models, and they call for greater transparency, accountability and accuracy. At the same time, while regulations require measurement, they do not define a single methodology. This is where inconsistencies can emerge, and where industry interpretation begins. The gap between obligation and methodology remains a central issue.
Calculating sustainability metrics, particularly product carbon footprints, is becoming increasingly necessary. Regulatory frameworks require transparency, and non-compliance can carry penalties. Market expectations are also evolving, with investors, original equipment manufacturers and industrial buyers incorporating sustainability data into their assessments. Supply-chain pressure is increasing as well, with Corporate Sustainability and Reporting Directive-level data already expected in parts of the market. In this context, data availability and quality are becoming more closely linked to market access and continuity.
Across the lubricants value chain, several sectors have developed product carbon footprint methodologies. Together for Sustainability applies to chemicals, Catena-X to the automotive sector, and API TR 1533 to lubricant life cycle assessment. In parallel, ATIEL and UEIL have developed a joint methodology for lubricants, greases and specialties. Each framework reflects the needs of its sector, and differences can be seen in scope, system boundaries and flexibility. Together for Sustainability is broad and detailed, API allows a range of scoping choices from cradle to gate up to cradle to grave, and the ATIEL-UEIL methodology is more prescriptive in order to limit variability and support comparability amongst lubricant manufacturers.
At first glance, this landscape may appear complex. However, it reflects the different processes, technologies and boundaries across sectors. Each sector defines the level of methodological detail appropriate to its products. At the same time, differences between frameworks can lead to inconsistencies. What remains important is that methodologies follow common ISO principles and that results are transparent and traceable. In this sense, harmonization is less about a single method and more about shared foundations with sector-specific depth.
When discussing sustainability, the focus is often on the product footprint, particularly emissions from raw materials and production. For lubricants, this represents only part of the overall picture. A significant share of impact occurs during the use phase. Lubricants influence friction, energy consumption, equipment lifetime and material losses. These effects are sometimes referred to as the “handprint,” reflecting the contribution made during use.
Within life cycle assessment, avoided emissions from energy efficiency are generally outside the defined system life cycle boundary. The use phase typically accounts for lubricant losses rather than performance benefits. As a result, there is currently no unified method to quantify these effects. If the objective is to reflect the full contribution of lubricants, a consistent approach to assessing use-phase benefits would be required.
Lifecycle thinking indicates that, for many lubricant applications, the use phase represents a significant lever. While there is guidance for product carbon footprints and end-of-life treatment, there is no common requirement or unified approach for quantifying use-phase benefits. This creates a gap in how overall impact is represented when only the footprint is considered.
It is therefore useful to distinguish between the product carbon footprint and the product carbon handprint. The footprint is a required metric, covering emissions from raw materials, processing and energy use, and it is subject to verification. The handprint is an additional metric that reflects potential benefits during use, such as reduced friction, lower energy demand or extended oil life. These metrics serve different purposes and are not interchangeable. When quantified against a baseline, such effects may be described as avoided emissions, following guidance from the World Business Council for Sustainable Development.
Recent policy developments also create scope for collaboration. The European Commission’s 2023 Horizontal Cooperation Guidelines allow companies to work together on sustainability standards within competition law. This enables the development of shared rules, aligned testing approaches and common data formats. Industry initiatives, including those led by ATIEL and UEIL, are progressing in this direction.
At the same time, the challenges involved are not limited to individual companies. Harmonization across regions and across the value chain remains a consideration. This includes shared methodologies, jointly developed product rules and environmental product declarations, as well as common interpretations of standards. Given the structure of the lubricant value chain, coordination across stakeholders is likely to remain important.
Looking ahead, several elements are likely to influence how sustainability strategies are developed. These include the availability of credible and harmonized product carbon footprint data that can be compared and verified across supply chains; the need for evidence-based performance data to support claims related to energy efficiency, wear and lifetime; and the increasing role of digital systems such as Digital Product Passports, which may affect how product information is exchanged and structured.
Within the European context, regulatory developments continue to evolve, with increasing emphasis on digitalization and data requirements. In this environment, the role of data in supporting transparency and comparability is likely to remain central to how sustainability is addressed in the lubricants industry.
Inga Herrmann is Co-chairman of the ATIEL & UEIL Joint Sustainability Committee.