REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Circularity of mineral and synthetic lubrication and industrial waste oil management in the EU
Date: 2023-10-26
Institutions: Directorate-General for Environment, European Commission
Subjects: circular economy, extended producer responsibility, industrial waste, lubricants, mineral oil, pollution control measures, used oil, waste disposal, waste recycling

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 26.10.2023  COM(2023) 670 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Circularity of mineral and synthetic lubrication and industrial waste oil management in the EU  
 
 
1.  Introduction 

This  report  presents  the  results  of  the  data  analysis  and  the  assessment  done  on  the 
management  of  mineral  and  synthetic  lubrication  and  industrial  waste  oils  in  the  EU 
with  a view to  considering the feasibility  of  adopting  measures  to  further improve the 
treatment  of  waste  oils,  including  quantitative  targets  on  the  collection  and  the 
regeneration of waste oils, which the Commission carried out in accordance with Article 
21(4)  of  the  Waste  Framework  Directive1  (WFD).  This  report  draws  from  three 
extensive studies2 3 4 by the Commission carried out between the years 2019 and 2023.  

2.  Background 

Waste oils are defined in the WFD as “any mineral or synthetic lubrication or industrial 
oils which have become unfit for the use for which they were originally intended, such 
as used combustion engine oils and gearbox oils, lubricating oils, oils for turbines and 
hydraulic oils”5.  

Lubricating and industrial oils typically consist of base oils and additives. Engine oils, 
used  in  the  automotive,  marine  and  industrial  sectors,  represent  up  to  half  of  all 
lubricant oils placed on the market. Hydraulic oils rank second representing 15% - 20% 
of the volume. When these oils become waste they are classified as hazardous waste and 
represent  the  most  important  liquid  hazardous  waste  stream  in  the  EU,  with 
approximately 1.6 million tonnes of waste oils collected in 20176. Waste vegetable oils 
generated by kitchens and similar activities are not in the scope of the current report, nor 
covered by the definition of waste oil.  

Waste oils have been regulated in the EU for over 40 years. Directive 75/439/EC7 on the 
disposal  of  waste  oils  required  that  waste  oils  were  collected  and  disposed  of  without 
causing  avoidable  damage  to  man  and  the  environment.  In  the  year  19878  major 
amendments  were  introduced  resulting  in  priority  being  given  to  the  regeneration  of 
waste  oil  over  its  incineration  for  energy  recovery.  The  WFD  requires  that  Member 
States  must  take  stringent  measures  to  ensure  that  waste  oils  are  separately  collected, 
avoiding  mixing  with  other  wastes  and,  if  feasible,  with  other  types  of  oil  and  are 

1 Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste and repealing 
certain Directives, OJ L 312, 22.11.2008, p. 3–30    
2 Study to support the Commission in gathering structured information and defining of reporting obligations on waste 
oils and other hazardous waste” (2020). https://op.europa.eu/en/publication-detail/-/publication/73a728bc-72f5-11ea-
a07e-01aa75ed71a1/language-en/format-PDF/source-123020647  
3 Environmental and economic sustainability of waste lubricant oil management in the EU. European Commission 
(2023). https://publications.jrc.ec.europa.eu/repository/handle/JRC133752    
4 Study to analyse lubricant and industrial oil EPR systems and waste oil collection schemes in EU Member States to 
support measures to increase collection rates. European Commission (2023). 
https://data.europa.eu/doi/10.2779/948514  
5 Article 3(3) of Directive 2008/98/EC    
6  Generation  and  collection  figures  for  EU28  (see  footnote  2).  Eurostat  reports  higher  figures  of  4.0  -  4.5  Mt  in  a 
highly aggregated statistic which is not very meaningful or comparable. 
7 Council Directive 75/439/EEC of 16 June 1975 on the disposal of waste oils, OJ L 194, p. 23-25, p. 31-33 
8 Council Directive 87/101/EEC of 22 December 1986 amending Directive 75/439/EEC on the disposal of waste oils, 
OJ L 42, 12.2.1987, p. 43–47 

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managed  without  harming  human  health  or  the  environment  and  respecting  the  waste 
hierarchy.   

As indicated in the European Green Deal Communication9, the European Union strives 
for a climate neutral  and circular economy,  in  the context of a  toxic-free environment 
for  which  more  action  to  prevent  pollution  is  required.  In  meeting  these  objectives, 
which  are  further  developed  in  the  Circular  Economy  Action  Plan10  and  in  the  Zero 
Pollution Action Plan11, the sound  environmental management of waste oils, in  a way 
that  emissions  and  discharges  are  minimised  and  where  base  oils  are  largely 
regenerated, has a relevant contribution to make.    

3.  Overview of waste oil management in the EU 

In 2017, about 4.3 million tonnes of lubricant and industrial oils were placed on the EU 
market. The 1.64 million tonnes of waste oils collected in the EU28 in 2017 represent 
38%  of  this  amount  and  is  82%  of  the  theoretically  collectable  waste  oil  (~2  million 
tonnes)12.  Unavoidable  losses  of  oil,  estimated  to  be  2.3  million  tonnes,  occur  during 
use,  mostly  due  to  burning  in  engines  or  by  being  disposed  with  other  waste.  It  is 
estimated that about 18% of collectable waste oils are lost due to burning in small waste 
oil  burners,  due  to  illegal  conversion  into  fuels  and,  to  a  limited  extent,  via  direct 
releases  into  the  environment.  Such  activities  have  a  direct  and  deleterious  impact  on 
water, soil and air quality, are illegal, contrary to the waste hierarchy and may result in 
unfair  competition  with  legal  waste  operators,  thereby  requiring  intensified  efforts  in 
terms of collection and enforcement to avoid them.  

The particular case of waste oils from ships is addressed by Directive 2000/59/EC13 on 
port reception facilities which aims to substantially reduce discharges of ship-generated 
waste and cargo residues into the sea. The European Maritime Safety Agency provides a 
pollution  prevention  service  including  earth  observation  services  using  satellite 
imagery14.  

The  approach  taken  to  manage  waste  oils  differs  largely  among  the  Member  States. 
Extended  Producer  Responsibility  (EPR)  schemes  for  waste  lubricant  oils  are 
implemented in 11 Member States15.  

9  Communication  from  the  Commission  to  the  European  Parliament,  the  European  Council,  the  Council,  the 
European  Economic  and  Social  Committee  and  the  Committee  of  the  Regions  The  European  Green  Deal, 
COM(2019) 640 final  
10  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social Committee and the Committee of the Regions A new Circular Economy Action Plan For a cleaner and more 
competitive Europe, COM(2020) 98 final 
11  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social Committee and the Committee of the Regions Pathway to a Healthy Planet for All EU Action Plan: ‘Towards 
Zero Pollution for Air, Water and Soil’, COM(2021) 400 final 
12 All figures in this paragraph are reported in the study referred to in footnote 2. 
13 http://data.europa.eu/eli/dir/2000/59/2019-06-27  
14 https://www.emsa.europa.eu/csn-menu.html 
15 BE, BG, HR, DK, EL, ES, FR, IT, LT, PL, PT. 

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It is reported16 that approximately 61% of the waste oils collected are regenerated into 
base  oils,  whereas  24%  are  treated  to  produce  fuels  and  11%  used  for  direct  energy 
recovery in cement, lime, steel and power plants, with the remainder being incinerated 
as hazardous waste. In 2019 there were 27 waste-oil regeneration plants in the EU2817, 
distributed  throughout  11  Member  States,  with  an  approximate  capacity  to  treat  1.5 
million tonnes of waste oils. In total about 0.95 million tonnes of waste oils were treated 
in  regeneration  plants  in  the  EU  resulting  in  approximately  0.68  million  tonnes  of 
regenerated  base  oil.  These  figures  show  that  regenerated  base  oils  represent 
approximately 8%18 of the yearly amount of base oil produced in the EU and indicates 
that even if all waste oils available to be collected were collected and regenerated back 
into base oil, only a fraction of the demand can be covered by regeneration.   

Figure 1: Waste oil management in EU27 Member States19. 

Despite uncertainties in the estimation of the amounts of oils placed on the market that 
can  be  collected,  evidence  shows  there  is  still  room  for  improvement,  not  only  in  the 
amount and quality of waste oils collected, but also in the amount of collected oils that 
are regenerated. The sections below outline approaches to bring about an improvement 
in  both  aspects,  recognising  that the starting point  and the context associated to  waste 
oil management differs largely from one Member State to another.  

16 See footnote 2. 
17 EU28, specifically in BG, DK, FI, FR, DE, EL, IT, PL, PT, ES, UK (the latter not shown in map) 
18 About 8 Mt/yr of virgin base oils produced in  EU28 between 2013-2018.  
19 See footnote 4.   

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4.  Collection of waste oils 

Collection rates of waste oils vary greatly between Member States. In 2018 they ranged 
between  38  and  100%  of  the  collectable  oils20.  The  limited  information  on  illegal 
practices  that  impact  collection  rates  suggests  that  the  main  practice  that  negatively 
affects  the  collection  of  waste  oils  is  their  illegal  burning.  Direct  discharge  to  the 
environment appears to be rare and not sufficiently significant to explain differences in 
collection rates. 

EPR and collection schemes 

Member  States  with  high  collection  rates  do  not  necessarily  apply  a  common 
approach21. Some have an EPR system in place (e.g. Portugal, Italy) while others do not 
(e.g.  Germany,  Austria).  Similarly,  for  Member  States  with  a  low  collection  rate,  a 
common pattern could not be found. Some have an EPR (e.g. Bulgaria) and some do not 
(e.g.  Romania).  All  other  things  being  equal,  collection  performance  appears  to  be 
higher  in  countries  that  have  a  high  population  density,  significant  industrial  activity 
and close-by regeneration or energy recovery capacity.  

Figure 2: Waste oil collection rates in 2018 (collected/collectable)22 
According to a recent study23, there is no clear conclusion as to whether an EPR or other 
formalised  collection  schemes  (e.g.  deposit-refund  schemes)  are  necessary  to  ensure 

20 GEIR (2019). https://www.geir-rerefining.org.   
21 See footnote 4. 
22 Ibid   
23 See footnote 4.  

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high  collection  rates.  It  seems  clear  however  that  two  main  factors  drive  waste  oil 
collection performance:  

•  cost/benefit  for  waste  holders:  if  the  waste  holder  is  paid  for  the  waste  oil  the 

collection rates increase;  

•  willingness  of  waste  holders  to  manage  their  waste  legally:  this  is  highly 
dependent on the awareness of holders and on enforcement by Member States. 

Therefore, collection rates are high where collection is profitable, that is, where waste 
holders receive money for their waste, collection is for free or they are otherwise willing 
to  pay  the  market  price  for  managing  their  waste.  Geographical  areas  where  the  cost 
exceeds  the  willingness  to  pay  may  not  be  serviced  and  this  can  result  in  illegal 
management.  Ultimately,  the  characteristics  of  the  incentive  scheme  appear  to  have 
more influence on collection rates than whether an EPR is in place or not. 

Electric vehicles and impact on waste oil volumes 

The study24 also provided projections for the generation of waste oils in EU-27 up to the 
year 2050 based on two modelling approaches, one based on lubricant demand forecasts 
by  McKinsey  &  Company25  and  a  second  based  on  the  same  demand  growth  and 
considering the EU regulatory targets to decrease GHG emissions from  vehicles26 and 
information  on  lubricant  use  in  electric  vehicles27.  These  assume  that  the  demand  for 
lubricant in the EU electric and fuel cell fleet will be 10% of that from a conventional 
fleet, predicting a decrease in use of engine oils in the EU. It is assumed that the waste 
oil  generation  from  the  automotive  sector,  which  currently  represents  approximately 
40% of the lubricating oils market, will decrease gradually from its 2035 level to 32.5 % 
of it in 2050. According to the referred study, the EU-27 total waste oil generation will 
be  between  1.7  and  2  million  tonnes  in  2050,  a  value  similar  to  the  amount  of 
collectable  waste  oils  reported  for  2017.  These  projections  indicate  that  the  overall 
amount of the waste oil available for treatment is unlikely to change very much in the 
next decades and can be explained by the estimation that the referred reductions in road 
transport oil generation will be largely offset by growth from other transport modes and 
from industrial / non-transport uses.  

Measures to increase waste oil collection and quality 

24 Ibid. 
25  https://www.mckinsey.com/industries/oil-and-gas/our-insights/lubes-growth-opportunities-remain-despite-switch-
to-electric-vehicles 
26 The second model uses fleet composition and evolution estimates developed  in the  ‘EURO7 standards’ proposal 
(COM(2022) 586 final).  
27  Shah,  Raj,  et  al.  "Recent  trends  in  batteries  and  lubricants  for  electric  vehicles."  Advances  in  Mechanical 
Engineering 13.5 (2021). 

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Currently,  the  average  EU  collection  rate  for  waste  oils  is  about  82%28  but  with  wide 
variation  between  Member  States  due  to  national  and  context-specific  aspects.  Seven 
Member States have legally binding waste oil collection targets in their legislation29. As 
illustrated  by  the  analysis30  made  of  reporting  made  by  Member  States  for  the  year 
2020, the available statistical information on waste oil collection and management is not 
sufficiently  robust  to  set  mandatory  EU  collection  targets.  An  approach  relying  on 
national targets could however be considered by Member States.  

Such approach could pivot on two target values for the year 2030, set at 80% and 95%31 
with  respect  to  the  collectable  waste  oil32  quantities.  Member  States  performing  best 
could consider immediately applying the higher target33 or, if already met, ensuring it is 
at least maintained. Lower performers should focus their efforts on achieving the 80% 
collection target by 2030 and the 95% target by 2035. This approach has the advantage 
of directly addressing the objective of collecting more waste oils while providing some 
flexibility to Member States.  

Based on the analysis of existing waste oil management systems and collection schemes 
in the EU (and beyond) and of the best practices applied, and on the limited information 
on  waste  oil  collection  and  regeneration  in  the  EU  Member  States,  a  number  of 
measures  to  increase  the  quantity  and  the  quality  of  waste  oils  collected  could  be 
considered:  

a.  The possibility for Member States to set mandatory collection targets.  

i.  80% of generated waste oils (dry weight) to be collected by 2030 . 

ii.  95% of generated waste oils (dry weight) to be collected by 2030  for 

Member States that already collect more than 80%.  

b.  Other possible measures to increase waste oils collection34  

i.  Introduce  a  subsidy  for  small  waste  holders.  Approved  small  waste 
holders could receive a flat-rate annual subsidy upon request to cover 
collection costs. 

28 See footnote 4. 
29 BE, FR, EL, LT, PL, PT and ES. 
30 See footnote 4. 
31 As described in the study referred to in footnote 4 which analyses the economic, social and environmental impacts 
of such a measure. 
32 Collection rate defined as the ratio between collected waste oil and generated (collectable) waste oil. 
33  A  100%  collection  target  is  not  proposed  given  that:  a)  in  a  context  of  disperse  and  low  volume  waste  oil 
generation scenario this may result in disproportionate costs and environmental impacts from collecting all produced 
waste oils separately and b) the uncertainties in waste oil emission factors used to estimate the collectable amount of 
waste oil advise caution. 
34 Any measure must be implemented in compliance with EU State aid rules as well as with the polluter pays 
principle. 

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ii.  Prohibit  charging  waste  holders  for  collection  (free  collection  or 
collector is paid), potentially subject to conditions such as minimum 
collection volume or quality requirements. 

iii.  Make  it  mandatory  for  waste  oil  collectors  to  provide  a  spatially 
inclusive and comprehensive collection service, thereby guaranteeing 
collection  in  less  profitable  cases  (remote  areas,  small  waste  oil 
producers, etc). 

iv.  Give  small  waste  holders  access  to  municipal  collection  facilities 
(e.g.  civic  amenity  sites).  This  would  provide  a  convenient  service 
for small waste oil producers, reducing risk of illegal disposal. 

v.  Define  specific  criteria  to  license  waste  oil  collectors,  defining 
minimum  requirements  e.g.,  in  relation  to  geographical  coverage  of 
service, storage and quality control capacity, etc.  

c.  Possible measures to increase collected waste oil quality35 

i.  Define  mandatory  quality  control  by  waste  collectors  (including 

control points, frequency, parameters, etc).  

ii.  Ensure  separate  collection  of  waste  streams  with  potential  to 
contaminate waste oils (e.g. vegetable and cooking oil, brake fluids). 

iii.  Require  waste  holders  that  contaminate  the  waste  oils  (e.g.  by 
improper  segregation  and  subsequent  contamination  of  batches  in  a 
lorry or storage tank) to pay for its treatment. 

iv.  Establish  detailed  guidelines  and  provide  training  to  clarify  which 
waste oils should be kept segregated by the waste holder (e.g. avoid 
mixing with polychlorinated biphenyl oils, brake fluids, etc). 

It should be noted that not all listed measures can be combined (e.g., subsidies for small 
waste holders + free/paid collection) and that the best way to implement measures can 
be  very  specific  to  the  national  context  including,  for  instance,  whether  measures  are 
adopted as part of an EPR scheme or otherwise via specific legal provisions, guidance, 
or other means36. These measures should be further complemented with enforcement by 
Member  States  and  with  information  and  awareness-raising  activities  addressed  to 
waste oil producers and to the general public.  

5.  Regeneration of waste oils 

The Circular Economy Action Plan aims to foster and encourage a sustainable, resource 
efficient and competitive economy, in which the value of materials and products is kept 
in  circulation  for  as  long  as  possible.  Given  that  waste  oils  can  be  recycled  via 

35  A  greater  collected  waste  oil  quality  can  also  have  a  positive  impact  on  the  amount  of  collected  oil  that  is 
regenerated.  
36 The study referenced in footnote 4 provides an extensive analysis of how EPR schemes and other collection 
schemes are applied in different Member States. 

7 

 
 
 
technically well-established processes they have the potential to significantly contribute 
to the circular economy objectives.  

The  Waste  Framework  Directive  defines  the  regeneration  of  waste  oils  as  “any 
recycling  operation  whereby  base  oils  can  be  produced  by  refining  waste  oils,  in 
particular  by  removing  the  contaminants,  the  oxidation  products  and  the  additives 
contained in such oils”37. It also establishes a waste hierarchy that sets a preference for 
preparing  for  reuse  and  recycling  over  energy  recovery.  For  waste  oils,  Article  21 
indicates a priority for regeneration over other treatment options.  

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Regeneration

Incineration

Conversion to fuel

Other

Figure 3: Waste oil use per treatment38 

Seven  Member  States39  report  regeneration  rates  of  90%  or  more40  whereas  10  have 
rates below 10%. Use in cement kilns and power plants is overall not very significant, 
but  in  three  Member  States41  it  accounts  for  more  than  50%  of  oils  collected.  It  is 

37 Article 3(18) of Directive 2008/98/EC 
38 As published in the report referred to in footnote 3.   
39 DK, EL, LU, IT, NL, BE, FI and BG. 
40 100% regeneration rates are reported by some countries. However, evidence suggests that such high regeneration 
rates may be accounting artefacts, as some countries report initial sediment and water separately from dry waste oils 
and others report only the regeneration of waste oil of sufficient quality.  
41 HR, EE and SI. 

8 

 
 
 
 
 
 
estimated  that  5  -  15%  of  collected  waste  oils  are  of  low-quality  and  unsuitable  for 
regeneration  and  is  thereby  generally  used  in  cement  kilns,  industrial  boilers  and 
hazardous waste incinerators.  This implies a conservative upper limit of 85% collected 
waste  oils  that  can  be  regenerated  (based  on  current  collection  outcomes  and 
technologies). 

As reported in several studies42, waste oils can be regenerated by different processes: in 
the  EU  approximately  32%  of  collected  waste  oils  are  regenerated  through  hydro-
treatment,  46%  by  solvent  extraction  and  22%  by  distillation.  Available  regeneration 
capacity  in  the  EU  does  not  appear  to  be  a  limiting  factor  since  it  exceeds  what  is 
currently  treated  by  regeneration  and  new  re-refineries  projects  have  been  identified 
(e.g.  in  Portugal).  However,  more  capacities  would  be  needed  if  all  waste  oils  being 
collected were sent to regeneration (and if collection rates increased).  

The main reasons that seem to explain why a significant fraction of waste oils collected 
does  not  enter  the  regeneration  pathway  include:  1)  uneven  spread  of  regeneration 
capacities among Member States; 2) lack of incentives for regeneration due to absence 
in  some  Member  States  of  specific  instruments  to  support  regeneration  (financial 
support,  targets)  3)  increased  demand  of  low-sulphur  fuels,  especially  for  the  marine 
fuels market and 4) variability of virgin oil prices, making regeneration less competitive 
than energy recovery when virgin oil prices are on the lower end. 

Comparison of waste oil regeneration vs energy recovery 

The  Commission  has  recently  concluded  a  new  state-of-art  life  cycle-based  study43  to 
compare the overall performance of the three main waste oil regeneration technologies44 
with different options to recover energy from waste oils45. The analysis was carried out 
using  a  specific  life  cycle  assessment  (LCA)  modelling  tool46  which  was  applied  to 
simulate  the  different  waste  management  activities  and  processes  included  in  each 
technology,  and  to  calculate  the  respective  potential  environmental  impacts47  and  life 
cycle  costs  (LCC).  This  analysis  was  subsequently  used  to  obtain  insights  about 
possible policies that could be put in place to increase waste oil flows towards the most 
beneficial pathways.  

The study distinguishes two types of LCC. Conventional LCC describes financial cost 
as  the  sum  of  budgets  costs  and  transfers,  i.e.,  internal  costs  of  managing  waste  oils. 
Societal  LCC  sums  internal  and  external  costs,  both  expressed  as  shadow  prices,  to 
quantify  the  total  cost  incurred  by  society,  thus  reflecting  a  social  costs-and-benefits 

42 See footnotes 2 and 4 
43 See reference to JRC study in footnote 3. 
44 Hydro-treatment, solvent-extraction and distillation. 
45 Waste oil derived fuel replacing primary marine fuel (WODFa); Waste oil derived fuel replacing primary light fuel 
oil (WODFb); combustion in cement kiln; combustion in hazardous waste incinerator and combustion in an industrial 
boiler.    
46 Life-cycle assessment software: EASETECH v3.4.0  
47 14 impact categories were analysed 

9 

 
 
 
 
assessment  and  including  the  specific  shadow  price  of  CO2,  other  emissions  and 
resource depletion.48 The study also includes an analysis to check the sensitivity of the 
results  to  several  factors  and  an  assessment  of  the  uncertainty  in  the  final  results  by 
performing a discernibility analysis49.  

Outcome of the assessment of regeneration vs energy recovery 

For most individual impact categories, as well as in terms of societal life cycle costing, 
the  three  regeneration  pathways50  perform  best  among  all  waste  oil treatment  options. 
Notably,  regeneration  stands  out  as  the  preferred  management  pathway  when 
considering  only  the  impacts  on  global  warming.  The  results  are  more  nuanced  when 
looking at the total societal life cycle costs (i.e. the monetised environmental emissions 
of all types and resource depletion), which shows that the least performing regeneration 
pathway  (solvent-based)  only  generates  a  small  benefit  over  the  treatment  to  fuel  (via 
distillation)  and,  under  some  conditions,  can  even  fall  behind  this  treatment.  The 
discernibility  analysis  also  shows  that  in  terms  of  societal  life  cycle  costing,  solvent-
based and distillation-based regeneration are not robustly  superior to  treatment  to  fuel 
(although  the  opposite  is  also  true).  Direct  incineration  pathways  (e.g.  combustion  in 
cement kilns) are clearly inferior options.  

In  conclusion,  regeneration  -  depending  on  the  specific  technology  and  context  -  is 
superior or comparable to treatment to fuel and superior to direct energy recovery, from 
a  societal  cost  perspective.  This  analysis  shows  that  Member  States  should  promote 
options that deliver the best overall environmental outcome. For waste oil management, 
this  means  encouraging  the  development  of  installations  making  use  of  the  best 
performing and most advanced regeneration technologies, which not only have the best 
overall environmental performance, but also yield the highest value51 base oils. 

Possible measures to increase regeneration of waste oils 

There  are  different  approaches  that  could  be  implemented  to  increase  the  amount  of 
regenerated waste oils. The most promising fall into the category of regeneration targets 
or  price-based  instruments.  Regeneration  targets  can  take  the  form  of  setting  country-
level  mandatory  minimum  percentages  of  1)  collected  waste  oils  that  must  be 
regenerated;  2)  lubricant  or  base  oils  put  on  markets  that  must  be  derived  from 
regenerated  waste  oils  or  3)  regenerated  content  in  every  lubricant  product.  The  first 
approach regulates the supply of regenerated waste oils and is suitable for target setting 
at Member State level, whereas the other two affect the demand and represent product 
requirements.  As  regards  price-based  instruments,  the  options  studied  included 

48 A default value of 100 euro/tonne CO2 suggested by CE Delft and DG MOVE for 2030 was used.  
49  Applying  Monte  Carlo  simulations  on  two  scenarios  simultaneously,  e.g.,  hydro-treatment  versus  solvent 
extraction. 
50 Hydro-treatment, solvent extraction and distillation 
51 Generally, oils belonging to API Groups II and III. 

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implementing  a  subsidy  on  regeneration  financed  through  the  general  budget  or 
financed via a levy on virgin-based base oils.  

An  assessment  of  the  socio-economic  impacts  of  policies  that  would  establish  two 
benchmark waste oil regeneration rates, to  be achieved by Member States by the year 
2030, was made:  

1)  a  regeneration  rate  of  70%  of  all  collected  waste  oils,  which  represents  an 

increase from the current EU average rate of 61%. 

2)  a  regeneration  rate  of  85%  of  all  collected  waste  oils,  which  corresponds  to  a 

conservative estimate of what can realistically be regenerated.    

The environmental effects52 are by definition the same for all policies that achieve the 
same target. Whereas setting a mandatory minimum regeneration rate target, defined as 
a percentage of collected waste oils, results in a financial burden that is undefined and 
largely depends on the specific implementation in each Member State, the main burden 
of the other two options, based on setting  minimum  targets  for the use of  regenerated 
waste oil in lubricant products, initially falls on lubricant producers, and ultimately on 
lubricant consumers.  

Subsidies  for  regeneration  financed  either  out  of  the  general  budget  or  via  a  levy  on 
virgin base oil lead to relatively high costs, which largely exceed expected societal life 
cycle  cost  savings.  This  is  because  the  subsidies  would  have  to  be  paid  for  all 
regenerated base oil, including for the large  fraction (61%) already being  regenerated. 
Assessing  the  outcome  of  the  three  target-based  policies  is  not  straightforward  given 
that  the expected benefits  in  terms  of  avoided societal  costs   are of the same order of 
magnitude as the estimated administrative costs53, leading to the conclusion that the net 
benefits after accounting for the costs are expected to be rather small (and in some cases 
negative)  and  may  not  be  sufficient  to  justify  a  policy  intervention  at  EU  level, 
particularly in view of the uncertainties involved. 

6.  Conclusions 

Regeneration  is  generally  the  treatment  option  providing  the  best  overall  performance 
from  the  environmental  and  socio-economic  point  of  view.  While  Member  States 
should make further efforts to implement the rules on waste oils laid down in the WFD, 
the rationale for proposing additional requirements at EU level is currently limited. For 
instance, experience in Member States shows that high waste oil collection rates can be 
achieved  without  mandatory  EPR  schemes,  therefore  not  allowing  to  make  a  general 
case for setting a mandatory EPR system for waste oils. In addition, more robust data on 

52 Leading to the avoidance of 0.6 Mt of CO2-eq. emissions until 2045 for the 70% target and 1.7 Mt for the 85% 
target (cumulative over the time-period considered). 

53 Resulting in a calculated cumulative benefit of 124 M€ between 2024 and 2045 in terms of avoided societal costs 
for the 70% target and 330 M€ for the 85% target. Cumulative administrative costs of 11-213 M€ are estimated, for 
the same time-period 2024-2045.  

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the  performance  of  different  Member  States  with  respect  to  waste  oil  generation, 
collection and treatment is necessary with a view to taking legislative action.  

The Commission encourages Member States to take note of the findings outlined in this 
report and to consider them in order to improve the implementation of the EU rules on 
waste  oils  at  national  level,  incentivise  the  collection  of  higher  quality  waste  oils  and 
further  promote 
the  best  performing  regeneration 
technologies.  

treatment,  employing 

their 

The Commission will follow closely data on waste oils submitted by Member States and 
will strive to support its improvement. Based on such data and other information on the 
implementation of the WFD as regards waste oils, the Commission may consider further 
EU  action  in  the  future,  for  instance  as  regards  setting  mandatory  EU-wide  waste  oil 
collection  or  regeneration  targets,  in  particular  if  measures  taken  by  Member  States 
would create barriers for the Single Market.     

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