Lubrizol supports the EUs continued commitment to technological neutrality and policy coherence as outlined in the call. However, we believe that the current regulatory framework, centred exclusively on tailpipe emissions, risks creating unintended imbalances. A regulation that mandates 100% tailpipe CO reduction by 2035 does not account for the full climate impact of different technologies across their lifecycle.
Lubrizol
Company · Belgium · EU Transparency Register 673144424081-21
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 925 companies & groups on this site, they rank #452 by legislative files engaged — a count of participation, not a measure of influence.
Declares membership of
- Cefic (www.cefic.org)
- CIA (www.cia.org.uk)
- Amcham Eu (www.amchameu.eu)
- AISE (www.aise.eu)
- ATC (www.atc-europe.org)
- UEIL (www.ueil.org)
- EfFCI (www.effci.com)
- EBS (https://ebsummits.eu/)
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026).
- Register category
- Companies & groups
- Head office
- Wickliffe, Ohio, United states
- EU office
- Auderghem, Brussels
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Lubrizol filed 2 positions between 27 May 2024 and 29 Aug 2025, across 2 of the 326 legislative files tracked here, attaching a full position paper 2 times.
What they argued
While Lubrizol commends the European Commission for its efforts to establish a single, standardised methodology for assessing the environmental footprint of batteries through the Product Environmental Footprint (PEF) methodology, we would like to highlight three areas of concern: 1. The Circular Footprint Formula relies on complex end-of-life predictions; 2.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
- EDF - Electricité de France · 2 files in common
- Transport & Environment · 2 files in common
- Deutsche Umwelthilfe e.V. · 2 files in common
- European Advanced Carbon and Graphite Materials Association · 2 files in common
- BMW Group · 2 files in common
Showing 5 of 9.
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.