ATIEL &UEIL Joint Sustainability Committee


4. Summary of WBCSD avoided emissions guidance v2 Avoided Emissions Guidance v2 6 introduces a structured approach for determining the eligibility of avoided emissions claims. The WBCSD paper sets out a series of criteria in the form of ‘gates’ that solutions must pass in order to be considered eligible. Under Gate 2, only technologies considered ‘climate-aligned’ are eligible. Efficiency gains in fossil-based systems are generally excluded as transitional improvements.


Additional Gate 2 requirements - such as demonstrating the absence of scalable alternatives, detailedmonitoring and tracing of impacts, and alignment with transition plans - pose challenges for a product-based sector characterized by widespread, diverse applications.


While the intent of the guidance is sound, its current structure does not fully reflect the specific nature of lubricants and greases, nor their proven contribution to immediate emissions reduction.


5. Core issue: exclusion of efficiency gains in legacy systems A key concern for the sector is the exclusion of lubricant-enabled efficiency improvements in legacy fossil-based systems. These improvements aremeasurable, verifiable, and already deliver substantial climate benefits today. Excluding them risks overlooking a pragmatic and scalable decarbonization lever at precisely the moment when rapid emissions reduction is required.


6. Practical challengeswith gate 2 ‘additional criteria’


The application of Gate 2 criteria presents several practical andmethodological challenges for the lubricants and greases sector. Lubricants are used across a highly diverse range of applications in transport, industry, and energy systems, resulting in complex and fragmented value chains. In many cases, this makes direct tracing of end-use energy impacts at product level challenging without introducing significant assumptions that may affect methodological consistency.


In addition, certain Gate 2 requirements appear primarily designed for system-level or asset- based technologies, such as renewable energy installations, rather than for high-volume, dispersed product categories used continuously acrossmultiple sectors. As a result, requirements related to detailed attribution, impact traceability, and demonstrating the absence of scalable alternatives may not be fully proportionate to the operational reality of lubricants, despite well- established evidence in scientific and engineering literature of their efficiency benefits.


6World Business Council for Sustainable Development. (2025, July 24). Guidance on avoided emissions v2.0: Drive innovations and scale solutions toward net zero.


Version 15.09.2026©ATIEL andUEIL Avoided Emissions & Handprint in the Lubricants and Greases Sector


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