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Ingevity Corporation

Ingevity

Ingevity provides specialty chemicals, high-performance carbon materials and engineered polymers that purify, protect, and enhance the world around us.

Lobbying Activity

Response to Revision of the CO2 emission standards for cars and vans

9 Oct 2025

Modifications to CO2 emission standards for technology neutrality should be complemented with stricter Euro 7 standards: The CO2 standards for light-duty vehicles are the EUs main policy instrument to decarbonise road transport, whereas the Euro 7 standards are the EUs main policy instrument to reduce all other exhaust and non-exhaust criteria pollutant emissions, including particulate matter, nitrogen oxides, and volatile organic compounds. These two sets of standards are not mutually exclusive. During the development of the Euro 7 standards, the stringency of CO2 standards were an influential determinant on the final stringency of the Euro 7 standards, with a common argument being that a stringent Euro 7 would slow down decarbonization efforts. A political agreement was ultimately reached, where the Euro 7 standards as originally proposed by the European Commission were significantly weakened, especially for light duty vehicles. This weakening of the Euro 7 proposal was justified by the firm commitments within the CO2 regulation for full electrification of all light-duty cars and vans by 2035. It was claimed at the time that further emission reductions from Euro 7 passenger cars and vans was no longer necessary due to the commitments by the industry towards full electrification of their fleets. Given the now significant and increasing political pressure to revise the CO2 standards for 2035 to accommodate technology neutrality, Ingevity believes that the European Commission should include a review of the Euro 7 exhaust and evaporative emission standards within the impact assessment and proposal. The CO2 standards and Euro 7 standards are directly interlinked, as changes to the CO2 standards will change the pace of transition to fully electric vehicles and allow for Euro 7 internal combustion engines to continue to operate past 2035 and well beyond 2050 considering their full useful life. The European Commission should therefore ensure that all vehicles allowed to be sold into the European market under the CO2 standards implement the most advanced emission control technologies available to ensure air quality objectives are maintained. Euro 7 as it stands today does not ensure this, as evidenced by the Commissions own impact assessments supporting the original Euro 7 proposal. International data reviews show there are still large segments of the Euro 7 Type IV evaporative and Stage II refueling emissions test and emission limits that continue to significantly lag other major markets, including the U.S., Canada, China, and Brazil. Furthermore, the automotive manufacturers have already cost-effectively implemented advanced evaporative and refueling emission control technologies in their vehicle fleets exported to other global markets with control efficiencies exceeding 98%, including the US, Canada, China and Brazil, whose emissions standards currently exceed those in force in the EU. We call on the European Commission to reconsider the Euro 7 exhaust and evaporative emissions emission limits as originally proposed for light-duty vehicles along with any revision of the CO2 standards to ensure all new vehicles introduced into the EU market contribute to improving air quality without delay.
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Meeting with Miguel Jose Garcia Jones (Cabinet of Commissioner Wopke Hoekstra)

30 Jun 2025 · Discussion on the bottlenecks green hydrogen development faces

Meeting with Catherine Chabaud (Member of the European Parliament)

5 May 2023 · Discussion sur les emballages et déchets d'emballages

Meeting with Jens Gieseke (Member of the European Parliament, Shadow rapporteur)

8 Mar 2023 · Austausch zur EU-Verkehrspolitik

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius), Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius)

30 Nov 2022 · EU forest and biomass policies, including in the revision of the Renewable Energy Directive (RED)

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

Clean transport will be key in ensuring the European Union reduces its emissions and achieves its carbon-neutral ambitions by 2050. However, it is paramount that greening transport does not cause unintended and offsetting increases of emissions and ILUC in other sectors. In particular, the latest revision of the Renewable Energy Directive (RED) increases targets for advanced biofuels and maintains feedstocks which can durably affect the sector of bio-based chemicals, a key sector for safe, sustainable and low carbon impact day-to-day products. Annex IX-A of the RED provides a list of specific feedstocks which can be used to produce advanced biofuels and thus achieve the target set by the Directive. The implementation of the Directive has significantly affected the supply chain of crude tall oil (CTO) because it is easily converted to a drop-in fuel relative to the other listed feedstocks. CTO is intentionally produced for the chemical industry by converting black liquor soap solids and thus tall oil should be considered a product/co-product. The RED Annex IX-A mandates will impact other sectors in environmental transition, such as the green chemical sector using CTO. To this, the European framework for the promotion of renewable energy should be looked at in terms of consequence and adapted to ensure complementarity and relevance with other key sectors in transition. Crucially, the RED does not make the distinction between the various components which can be derived from CTO. This lack of distinction has given all CTO the preferential status of waste, whereas one and a half million tons – about 75% - of the CTO produced annually is a high-quality, chemical-grade used in numerous applications throughout the European and global economy. Asphalt road paving, agriculture, adhesives, consumer packaging, mining of critical minerals, print media, paints, durable coatings, synthetic rubber, automotive part manufacturing, and lubricants are a few examples of everyday applications that will be impacted. These products are derived from specific components of CTO, such as tall oil fatty acid (TOFA) and tall oil rosin (TOR), that are separated from less-valuable ‘neutrals’ components in dedicated refineries. Indeed, the pine chemical industry already follows a cascading principle to make sure that products of higher value are produced from green chemical-grade CTO. Thus, providing incentives for use of CTO and derivatives for advanced biofuels is leading to a shift in sustainably responsible commercial use of these products and dramatically overstates the overall carbon mitigation impact for biofuel. The European Commission has only proposed to increase the advanced biofuel targets, from 1.75% to 2.2% in 2030. The consequence of this action is that all global CTO, regardless of its quality or grade, will be increasingly used for biofuel production. Current projections are that all of the global chemical-grade CTO supply could be diverted to biofuels by 2025. CTO will be increasingly less available to produce sustainable chemicals for essential use, and subsequently unavailable for recovery and reuse, a key aspect of the green circular economy. The demand for green chemical applications, currently utilizing chemical-grade CTO, will remain. With all CTO diverted to meet the RED advanced biofuel target, and with no equivalent incentive for CTO use in green chemicals, the chemical industry would likely be forced to replace CTO with less environmental and socially less-desirable materials such as petroleum, palm oil, Chinese and Brazilian gum rosin, and soybean oil. In order to avoid collateral impacts for the green transition of other key sectors, the RED should be adapted to prevent the use of problematic feedstocks, such as crude tall oil.
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Response to Development of Euro 7 emission standards for cars, vans, lorries and buses

2 Jun 2020

Ingevity welcomes the European Commission’s proposed roadmap for post-Euro 6/VI standards. The European Green Deal promises consistent targets for the reduction of polluting emissions. While Euro 6/VI have brought considerable improvement, there are still margins of improvement needed to meet these targets. Although alternative and low carbon fuels represent an innovative solution in the achievement of climate objectives, there will still be a large need for conventional vehicles and fossil fuels. These internal combustion engine vehicles can and should be brought closer to zero emissions. One key factor to bring combustion engine vehicles closer to zero emissions lies in the control of evaporative emissions. The recently updated Euro6d evaporative requirements - including canister pre-aging, increasing the number of diurnals to two (48-hr diurnal), and reducing the effective SHED limit - are all positive measures that improve the control technology response, reduce emissions, and enhance air quality. However, international data reviews show there are still large segments of the European evaporative program that continue to lag other major markets, including the U.S., Canada, China, and Brazil. Furthermore, ensuring strong evaporative emissions control would help European consumers both through improved fuel savings and increased confidence that the vehicles they are buying are more environmentally sound. To meet the ambitions of the European Green Deal, the near-zero control of evaporative emissions is needed to improve air quality on the days during which citizens are most impacted. This would include zero-evaporative technology, control for extended parking, best achievable control technology for refueling (ORVR), and consideration for hot driving conditions. Considering EU ambitions towards the environment and the options laid out in the roadmap, option 3 appears as the most favourable path forward. Option 3 would ensure the respect of the European Green Deal commitment as well as provide competitive assets for the European industry. Further comments provided in the attachment.
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