PRODUCT DUMPING Extract from open letter to EU Commissioners
Open letter from UEIL President Mattia Adani to EU Commissioners Kaja Kallas, High Representative for Foreign Affairs and Security Policy, Vice-President of the European Commission, and Mares Sefcovic, Commissioner for Trade and Economic Security, lnterinstitutional Relations and Transparency European Commission
As President of the Union of the European Lubricants Industry, UEIL, I am writing to raise serious concerns about possible violations of EU law and sanctions within the European lubricants market. UEIL represents more than 450 companies across the continent, employing over 100,000 people throughout the lubricants value chain, from production and distribution to recycling. Lubricants, and their main components, base oils, are essential to the efficient operation of European machinery and industry. The EU lubricants market is long established and competitive, with business driven by product knowledge, service quality, and fair pricing.
Recently, I have received numerous reports from several Member States, including Germany, Italy, France, the Netherlands and Lithuania, describing the arrival of unusually low priced base oils and finished lubricants. These products are being sold at levels that do not appear to cover normal production costs. Although many of the base oils seem to be routed through Egypt and Turkey, we have strong indications that they may, either directly or indirectly, originate from Russia. This raises serious concerns that such shipments may form part of a triangulation scheme designed to circumvent EU sanctions.
The EU ban on seaborne imports of Russian crude oil has been in force since December 2022, and the embargo on refined petroleum products followed in February 2023, confirmed in later sanctions packages. These measures explicitly prohibit both direct and indirect imports of Russian crude oil and petroleum products, including ship to ship transfers intended to conceal their origin. For this reason, it is essential to verify whether the base oils now entering the EU market are in breach of these rules. If this proves to be the case, such activity would constitute a clear violation of EU sanctions and would seriously harm
the competitiveness and stability of the European lubricants industry. The consequences would extend far beyond our sector, as European machinery and manufacturing industries rely heavily on lubricants for their operations.
Alongside these concerns, there is also evidence that finished lubricants are being sold within the EU at prices below the normal cost of raw materials. This strongly suggests the presence of dumping practices, made possible by the availability of artificially cheap base oils from third countries. Such actions undermine the prices of compliant EU producers, depress or suppress the market, and have already caused financial losses for many responsible companies. If these trends continue, there is a real risk that production could be halted in parts of the industry, with serious implications for economic stability.
In light of these developments, I believe it is in the EU’s direct interest to investigate these potential violations and to take appropriate action. As a long standing member of the European industrial community, our sector supports all measures adopted by EU institutions, even when they impose short term challenges. However, it is vital that companies that comply with regulations are properly protected. If they are left exposed while others circumvent the rules, frustration and disillusionment may grow, and this is something we must all work to prevent.
For these reasons, I respectfully request a meeting to discuss these matters in more detail. I remain fully at your disposal for any further information, and I thank you sincerely for your time and attention.
Yours sincerely,
Mattia Adani, UEIL President
ueil.org
LUBE MAGAZINE NO.190 DECEMBER 2025
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