ESPR: What it means for the lubricant industry
The European Union (EU) continues to lead in environmental governance, with its latest initiative, the Ecodesign for Sustainable Products Regulation (ESPR), enacted on 18 July 2024. ESPR expands the scope of the 2009 Ecodesign Directive, applying stringent sustainability criteria across nearly all physical products, including lubricants.
A key part of the European Green Deal, ESPR promotes durability, repairability, recyclability, and energy efficiency while phasing out hazardous substances where possible. The regulation also introduces digital product passports to improve transparency and traceability.
Dr. Stephan Baumgärtel, managing director of the German Lubricant Manufacturers Association (VSI), notes that while lubricants are a priority product group, there is still uncertainty regarding the specific requirements. The European Commission’s Joint Research Centre (JRC) published an initial report on 13 November 2024, but industry leaders await further working group discussions to clarify expectations.
Conflicting requirements for recycled and bio-based lubricants
ESPR calls for greater use of recycled base oils and bio-based lubricants, but industry experts warn of contradictions. Bio-based lubricants are difficult to recycle, conflicting with ESPR’s focus on product longevity. Additionally, existing standards such as the EU Ecolabel require lubricants to be biodegradable and non-toxic, creating further regulatory challenges.
OEM approvals remain a key hurdle. While some engine oils made with recycled base oils meet ACEA and API industry standards, many lack official OEM endorsement, raising concerns about performance and market acceptance. In countries like Türkiye, where a minimum percentage of recycled base oils is required, the availability and quality of these products remain inconsistent.
A global Regulatory Ripple Effect
ESPR will extend beyond Europe, affecting global manufacturers exporting to the EU market. Companies that fail to develop eco-friendly formulations risk restricted access and higher compliance costs. This legislation is also expected to influence sustainability policies in other regions, fostering a harmonised global approach.
Despite uncertainties, ESPR could create a level playing field by standardising carbon footprints, recycling criteria, and lifecycle assessments for lubricants. Baumgärtel will provide an ESPR update at the ALIA Annual Meeting in Bali, Indonesia, on 11-12 March 2025.
