Union of the European Lubricants Industry
UEIL
UEIL (the Union of the European Lubricants Industry) represents the interests of the lubricants industry in Europe, with a special focus on SMEs and independent companies that produce lubricants and metal processing fluids essential for the automotive and industrial sectors.
ID: 38096451110-61
Lobbying Activity
Meeting with Marcos Gonzalez Alvarez (Head of Unit Climate Action)
4 Dec 2025 · Presentation of UEIL position on inclusion of two-stroke engine oils in ETS2
Meeting with Calin-Ionut Ungur (Cabinet of High Representative/ Vice-President Kaja Kallas)
7 Nov 2025 · Russia sanctions implementation
Response to Circular Economy Act
6 Nov 2025
GEIR represents Europes waste oil re-refining industry, accounting for about 80% of the continents capacity. GEIR members collect and regenerate used lubricating oilsthe largest single stream of liquid hazardous waste globallyinto high-quality base oils that match virgin performance. Re-refining (regeneration) is the most sustainable treatment for waste oils, outperforming alternatives such as burning for fuel or energy recovery. According to the updated ifeu LCA (attached), re-refining saves 71% CO emissions compared to virgin production and 47% compared to the main alternative. It also removes toxic additives and delivers high-value products that can be reintroduced into the economy. Moreover, re-refining reduces the EUs dependence on imported fuels and strengthens energy security by recovering valuable crude oil. Currently, only around 61% of collected waste oil in Europe is re-refined, with the rest largely incinerated for energy. This practice releases greenhouse gases, destroys valuable materials, and contradicts the EU waste hierarchy, which prioritises regeneration over energy recovery. GEIR calls on the European Commission to seize the opportunity presented by the Circular Economy Act to make waste oil management a leading example of circularity. Our recommendations: 1. Establish a Mandatory Quota for Re-Refined Base Oils (RRBOs): GEIR believes that establishing a mandatory RRBO quota in finished lubricant is the most effective way to improve the circularity of waste oils. The quota could be set at an initial level of 10%, as an example. Specific exemptions should be defined for lubricant formulations that cannot technically include RRBOs. The quota should then apply at the company level, covering each company producing and selling lubricants. Re-refined base oils (RRBOs) are the most effective lever to reduce the sectors emissions. Europe already produces over 700,000 tonnes of RRBOs annuallymore than 20% of total base oil demand, estimated at 3 to 3.5 million tonnes per yeardemonstrating strong market readiness. Therefore, introducing a mass-balance quota would create market certainty, attract investment, and drive innovation in re-refining capacity and quality of RRBOs. The objective of this measures is to ensure full collection of used oils and maximise their regeneration into base oils, reducing emissions and conserving resources. 2. Ban the Use of Waste Oils for Energy Recover: GEIR urges the EU to prohibit the use of waste oils for energy recovery wherever regeneration is technically feasible. Burning waste oils for energy destroys valuable materials, increases emissions, and undermines circularity. Redirecting these oils toward re-refining preserves resources, prevents deliberate downgrading of waste oil quality through mixing, and supports the existing ban on waste oil mixing under Article 21 of the Waste Framework Directive. This measure would ensure high-quality feedstock for regeneration, delivering genuine environmental and economic benefits. 3. Establish high, mandatory and EU-wide collection targets for waste oils: Mandatory and ambitious collection targets at the EU level will help increase the collection and regeneration of waste lubricant oils and minimise the risk of pollution, with a feasible timeline for achieving these targets to be established. such measures would improve the overall environmental performance of waste oil management and enable the consistent and harmonised application of the waste hierarchy and the polluter pays principle. 4. Reward Circularity through Carbon Credits for Re-Refining; GEIR proposes the creation of a carbon credit system recognising the verified CO savings achieved by re-refining. Each tonne of regenerated base oil saves approximately 837 kg CO2 compared to base oil standard and 1,152 kg CO2 compared to base oil advanced. A certification-based system would reward re-refiners for cutting emissions, encourage lubricant producers to use RRBOs,
Read full response8 Jul 2025
The European Waste Oils Re-refining Industry Association (GEIR) supports the inclusion of any waste incineration installations in the EU ETS, provided this step is underpinned by a robust and comprehensive impact assessment. At present, re-refining installations are covered by the ETS, while waste incineration facilities are not, creating an uneven regulatory landscape that disadvantages re-refining operators. This imbalance runs counter to the objectives of EUs circular economy and climate goals. Re-refining is the most sustainable treatment option for waste oils, supporting resource efficiency and delivering substantial greenhouse gas emission reductions through the production of regenerated base oils (LCA report attached). Therefore, the current treatment of re-refining under the EU ETS should be reassessed to support the waste hierarchy and the EUs climate and circular economy goals. GEIR calls on the Commission to include all recycling, incineration, and WtE activities in the ETS, provided emissions from these processes are offset by the avoided emissions of re-refined products. CO savings from recycling should be verified by independent third-party certification, enabling credible climate accounting and market incentives to scale sustainable waste oil management.
Read full responseMeeting with Elena Donazzan (Member of the European Parliament)
24 Apr 2025 · Discussione relativa ai temi della Commissione ITRE
Response to Persistent organic pollutants - Polychlorinated biphenyls (PCB)
18 Mar 2025
Please see attached the feedback provided by the European Waste Oil Re-refining Industry Association (GEIR)
Read full responseMeeting with Pierfrancesco Maran (Member of the European Parliament)
5 Feb 2025 · Priorities new legislature
Meeting with Giorgio Gori (Member of the European Parliament) and Novelis Europe
24 Sept 2024 · Presentation of priorities
Response to Evaluation of the Motor Vehicle Block Exemption Regulation
24 Jun 2024
UEIL, representing the whole lubricants value chain in Europe, has noted no positive evolution in the effectiveness of the Motor Vehicle Block Exemption Regulation since its renewal in April 2023. Indeed unfortunately none of the UEILs suggestions for improvements have been taken into account in the extended MVBER. Hence, once again, UEIL calls for strengthening the MVBER to ensure the full and active participation of the independent sector in the motor vehicle aftermarket. A high degree of competition in the automotive sector is crucial for the automotive aftermarket itself, but also for consumers who can enjoy the freedom of choice and the lowest possible prices. Therefore, UEIL requires immediate improvements of the Regulation in order to really and effectively tackle anticompetitive behaviour reported many times by independent operators and national competition authorities. We call for : - full, unrestricted and free access to technical information, notably for independent operators, and for this information to be provided in a timely manner and at the latest at the time of vehicle approval. - stricter rules regulating practices which limit the supply and use of competing products in the motor vehicle aftermarket, such as the misuse of warranties, service/maintenance contracts, and bonus schemes. - stricter preventive measures to ensure that maintenance services can be carried out with a full freedom of choice, allowing the use of competing products of matching quality. The only acceptable requirement from a vehicle manufacturer regarding maintenance should be the use of products of matching quality including lubricants, brake fluids and cooling liquids. - the application of the following jurisprudence from the European Commission: any kind of pressure from a vehicle manufacturer whether through contractual obligations or by other means, which goes beyond a mere recommendation to its dealers in order to impose the use or sale of its own products or indeed those of another supplier, is likely to be illegal under EU competition rules (IP/87/500). - the scope of the MVBER to be extended to cover motor vehicles intended for off-road use and also to include two wheeled motor vehicles including motorbikes and mopeds. In addition, UEIL would like to take this opportunity to draw the attention of the European Commission to the fact that many Member States are not complying with the European provisions in force regarding access to vehicle repair and maintenance information. Therefore, UEIL urges the European Commission to consider this matter as soon as possible. For more details please see the attached position paper.
Read full responseResponse to Ecodesign for Sustainable Products - Product priorities
10 May 2023
The Union of the European Lubricants Industry (UEIL) represents the interests of the lubricants industry in Europe, with a special focus on SMEs and independent companies that produce lubricants and metal processing fluids essential for the automotive and industrial sectors. Through its 35 members, UEIL covers the whole lubricants value chain, from manufacturing and distribution to recycling, and represents over 450 companies and 100,000 employees, with an average annual consumption of lubricants in the European Union up to 5 billion litres. Because of its wide-ranging impact on sectorial applications, we would like to ensure the best possible understanding of the sector and invite the European Commission to consider not including lubricants in the scope of the priority list, given their upper value in the energy transition. More information to see on the position paper.
Read full responseMeeting with Jutta Paulus (Member of the European Parliament) and European Federation of Essential Oils and Downstream Users of Chemicals Co-ordination Group
3 May 2023 · CLP regulation
Meeting with João Albuquerque (Member of the European Parliament, Shadow rapporteur) and Bureau Européen des Unions de Consommateurs and
25 Apr 2023 · CLP - Classification, labelling and packaging
Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals
30 Mar 2023
The Union of the European Lubricants Industrys welcome the Commissions proposal to revise the Classification, Labelling and Packaging (CLP) regulation in its purpose to make labelling more consumer friendly, less burdensome for suppliers and easier to enforce. Nevertheless, due to its wide-ranging impact on sectorial applications, and to achieve the objectives of the Chemicals Strategy for Sustainability set in 2020, we support the Commissions proposal to review and improve the legislation to keep the labels as simple as possible especially for SME that do not have the adequate human resources. In that purpose, and to ensure the best possible implementation of the criteria at EU level, we invite the European Commission to consider the following recommendations for the revision in regards to: - Labelling requirements - Realistic transition period - Timeline for update of labels - Use of fold-out labels - New definition of multi-constituent substances - Difference between distance and online sales - Concept of refill sales for the end users - Application scope of the advertising requirement - Address grouping of chemicals
Read full responseResponse to Introducing new hazard classes–CLP revision
18 Oct 2022
The Union of the European Lubricants Industry (UEIL) and the Technical Association of the European Lubricants (ATIEL) have joined forces to comment on the call for evidence on the draft CLP delegated act for new hazard classes (ED, PBT/vPvB, PMT/vPvM).
The undersigned associations welcome the Commission’s proposal to revise the Classification, Labelling and Packaging Regulation (CLP). The CLP regulation is a key stone to the chemical legislation and directly concerns the downstream users of chemicals. Nevertheless, due to its wide-ranging impact on sectorial applications, we strongly believe in the necessity to evaluate the impacts of the addition of new hazard classes compounded. Besides, to ensure the best possible implementation of the criteria at EU level, UEIL and ATIEL invite the European Commission to consider the following recommendations:
1. Agree changes at the global level first - Align with UN GHS
2. Replace the word “components” by “substances”
3. Guidance development and transitional period
4. Elaborate coherent and consistent endocrine disruptors definition and categories
5. Align the definition of toxicity criteria with the REACH regulation
6. Define data to classify substances as “mobile”
Our position paper in attachment elaborates these 6 points in more details.
Read full responseResponse to Review of the EU rules on Motor Vehicle Block Exemption
30 Sept 2022
UEIL, representing the whole lubricants’ value chain in Europe, strongly supports the renewal of the Motor
Vehicle Block Exemption Regulation and therefore welcomes the proposed prolongation of the MVBER, but
requires immediate improvements in the Regulation. Postponing the necessary changes for 5 years more is not
an option. UEIL notably invites the European Commission to take inspiration from provisions included in previous
MVBERs to amend its proposal in order to really and effectively tackle anticompetitive behaviours reported many
times by independent operators and national competition authorities.
Read full responseResponse to Count your transport emissions: CountEmissions EU
17 Dec 2021
1. We are of the opinion that the topic is very relevant to the work of UEIL's Sustainability Committee and the Carbon Footprint groups. Depending on the type of the business of a particular UEIL member, emissions arising out of transportation can be very relevant and the determining factor.
2. We feel that there are already a lot of existing frameworks for calculating and reporting transport-related GHG emissions. Therefore, we would appreciate that as part of the initiative, existing frameworks are reviewed and assessed. Hence, the objective should not be to create a completely new framework, but to base on already existing frameworks and addressing gaps other frameworks have.
3. Transport and logistics do have an international outreach far beyond the EU. Therefore, to reach a high acceptance of all international actors
involved in it, the objective should be to create a framework which is globally recognized and not to aim for a regionally accepted standard.
Read full response4 Feb 2021
The Union of the European Lubricants Industry (UEIL) would like to provide feedback to the draft Delegated Regulation on amending Annex X to the Regulation (EU) 2018/858 in the attached position paper.
Read full responseResponse to A new Circular Economy Action Plan
20 Jan 2020
GEIR, the European Waste Oil Re-refining Industry section of UEIL (Union of European Lubricants Industry) has been a long-standing contributor to circular economy discussions at EU level as the re-refining industry is entirely integrating the philosophy of circular economy in its daily business. Our activities aim at saving valuable raw material (crude oil) by re-refining (also called “regeneration”) used oil and turning it into a valuable raw material (base oil) for the lubricants market, the quality of which can be compared to that of virgin base oils. Waste oils re-refining is one of the best-case examples of a functioning circular economy!
We followed closely the adoption of the 2015 Circular Economy Package, but also submitted inputs to consultations, notably on the interface between chemical, product and waste legislation. Our feedback to the present roadmap will focus on the waste related elements mentioned: waste generation reduction, modernisation of certain waste laws, increase of the amount of waste treated domestically.
Our members welcomed the release of the Green Deal, the new EU growth strategy marking the convergence of traditionally antagonistic interests: economic growth and environmental and climate protection. We do hope that this radical and promising change of mindset will infuse very concretely the content of the upcoming Circular Economy Action Plan and all the stemming initiatives.
We encourage the European Commission to start applying the Green Deal rationale to already initiated enterprises, without waiting for the publication of the new CEAP. Concretely, planned feasibility assessments of recycling targets for specific waste streams, required under the revised Waste Framework Directive (WFD), provide the perfect opportunity to tackle the above waste-related challenges without further delay.
This year for example, the Commission will start such assessment for used lubricating oils (waste oils). If the WFD recognizes the regeneration process (also referred to as ‘re-refining’) as the appropriate and best recycling method for waste oils, no recycling target is currently in place at EU level. GEIR considers that this is a missed opportunity: re-refining of waste oils is a perfect example of what a circular loop is as waste oils can be recycled countless times to base oils without losing their properties. They are therefore essential resources for lubricants production (produced from base oil), which use has not been maximized at EU level yet.
In addition to answering the objective of reducing waste generation, waste oils re-refining also reduces CO2 emissions compared to base oil production associated with extracting and processing crude oil. With modern re-refining technologies, CO2 emissions (kg of CO2 per ton of base oil) can be reduced by more than 50% as compared to the conventional production of base oil. Re-refined base oils are also non-hazardous and meet the same REACH criteria as for virgin oils – thus contributing to further environmental protection as called for by the Green Deal.
A 2018 critical review of a 2005 study on ‘Ecological and energetic assessment of re-refining waste oils to base oils – Substitution of primarily produced base oils including semi-synthetic and synthetic compounds’ (available at www.geir-rerefining.org) emphasized the environmental performance of regeneration compared to the virgin production and versus the treatment of waste oils to fuel.
Ultimately, setting a recycling target for waste oils will also increase the amount of EU waste treated domestically. It will ensure constant and reliable feedstock for existing re-refining facilities in the EU, thus reducing the need for crude oil imports from third countries. Guaranteed and local supply of waste oils will help maximise the EU’s existing re-refineries’ capacities, while allowing for further investments in new facilities. Transboundary shipment of waste oils within the EU should thus be facilitated.
Read full responseResponse to Evaluation of the Motor Vehicle Block Exemption Regulation
19 Mar 2019
The Union of the European Lubricant Industry (UEIL) is the umbrella association of the European Lubricants Industry, representing their members and, in particular, the interests of SMEs and independent lubricant companies. To date, the UEIL represents more than 450 lubricant companies, who manufacture and distribute lubricant products under their own various trademarks throughout the European Union. With members in more than 22 European Countries and a unique collective experience of lubricants and the lubricants market, UEIL is the sole representative body for independent manufacturers of lubricants in Europe. It is UEIL’s policy to favour free and fair competition within the scope of prevailing EU and national laws.
UEIL welcomes the opportunity the European Commission has given to all stakeholders to present their views on the Evaluation Roadmap and insists on the importance to keep sector specific rules for the motor vehicle aftermarket.
We note that the purpose of this evaluation is to gather facts and evidence on the functioning of the Motor Vehicle Block Exemption Regulation (including the application of Commission Regulation (EU) No 330/2010 to the motor vehicle sector), along with the corresponding Guidelines, notably by verifying the extent to which its objectives are fulfilled.
A further public consultation of 12 weeks duration is planned for this evaluation process. UEIL’s position is that the duration of this consultation is insufficiently lengthy. Enough time has to be given to all stakeholders to make provide detailed and documented submissions to the Commission. Consequently, we suggest to launch the evaluation process in Q1/2020 for 24 weeks instead of Q2/2020 for 12 weeks. Indeed, a sufficiently long period is necessary to collect in-depth and high quality evidence on the key competition issues.
The above public consultation will be supplemented by targeted questionnaires where appropriate. We consider that the Commission should organise bilateral meetings with interested stakeholders. UEIL takes the opportunity of this submission to inform the Commission of the UEIL’s interest to take part in such meetings. UEIL also suggests to include the European Parliament into the consultation.
As mentioned in the Supplementary Guidelines, “one of the Commission’s objectives as regards competition policy for the motor vehicle sector is to protect access by spare parts manufacturers to the motor vehicle aftermarkets, thereby ensuring that competing brands of spare parts continue to be available to both independent and authorised repairers, as well as to parts wholesalers” (recital 18).
It is important that the Commission keeps this key objective in mind when implementing the evaluation roadmap. Many stakeholders expect important improvements in its fulfillment.
To conclude, we would like to confirm that UEIL is keen to contribute and share its experiences in the European Commission evaluation process of the MVBER and its Guidelines.
Read full responseMeeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)
11 Mar 2015 · Circular Economy