ATIEL &UEIL Joint Sustainability Committee


Beyond these implementation aspects, the current interpretation of Gate 2 may lead to unintended consequences. In particular, the exclusion of efficiency improvements in widely deployed legacy systems risks overlooking a potentiallymaterial and immediately available source of greenhouse gas mitigation. Given the long lifetime of existing transport and industrial assets, lubricant-enabled efficiency gains can contributemeaningfully to emissions reductions during the transition period.


Furthermore, limiting the eligibility of such improvements for avoided emissions recognitionmay reduce the visibility of performance differentiation, thereby weakeningmarket incentives for the adoption of higher-efficiency lubricant technologies.


Taken together, these considerations suggest that while the intent of Gate 2 is to ensure robustness and credibility, its current structure may not yet fully capture the specific characteristics of lubricant applications nor the system-level contribution of friction reduction and efficiency improvements in existing energy-consuming assets.


7. Lubricants as enablers of the energy transition Lubricants and greases act as important enablers of energy efficiency, emissions reduction, and equipment durability across all parts of the energy system 78 . This includes EV drivetrains, industrial energy-efficient equipment, CHP units, and wind turbines.


Innovation in advanced lubricants - including ultra-low-viscosity engine oils, high-performance EV fluids, and high-durability turbine lubricants - is largely funded by today’s mainstream markets. Excluding transitional applications from avoided emissions claims may reduce incentives for investments essential to long-term decarbonization.


Furthermore, the sector supports circularity through the use of re-refined base oils9, where technically feasible, and waste minimization solutions, contributing to a broader sustainability agenda. In addition, it offers feedstock flexibility through bio-based and readily biodegradable products, which have been successfully used in demanding applications. Together, these developments underline the sector’s crucial role in overall transition solutions.


7 Holmberg, Kenneth &Erdemir, Ali. (2017). Influence of tribology on global energy consumption,


costs and emissions. Friction. 5. 263-284. 10.1007/s40544-017-0183-5. 8Woydt, M., Bock, E., Hosenfeldt, T., Bakolas, V., Luther, R., & Wincierz, C. (2023). Tribology in Germany: Effects of tribology on CO₂ emissions in the use phase of products—Contributions of tribology


to defossilization (Version 1). Gesellschaft für Tribologie e.V. 9 Abdalla, N., Fehrenbach, H., &Theis, S. (2022). Updated LCA for regeneration ofwaste oil to base oil – Summary. ifeu – Institut für Energie- und Umweltforschung Heidelberg GmbH, on behalf of GEIR (Groupement Européen de l'Industrie de la Régénération).


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


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