We caught up with Jami Rice recently to chat about her role, where she sees the top 3 challenges and opportunities driving North American Lubricants and what Jami’s one piece of advice to companies just starting EDR readiness is. Read on to learn more.
1) Tell us about yourself—key priorities and responsibilities
I’m the Commercial Regulatory Manager for Pennzoil Quaker State Company and Shell Lubricants across the Americas region. The regulatory environment has become increasingly complex for lubricants. My current focus is leading EPR strategy, execution, and cross functional readiness in the U.S. and Canada, responding to the lubricants industry’s increasing inclusion in Cap & Invest programs, and emerging ESG regulations. My remit spans advocacy strategy, compliance operations, and commercial enablement. I also hold board positions in organizations deeply connected to these emerging issues.
2) Top 3 challenges and opportunities driving North American Lubricants regulatory compliance today
1) Fragmented, fast‑moving regulation
State-by-state, province-by-province patchwork requirements create inconsistent timelines, scope, and reporting asks, which increase complexity and costs. The lack of streamlining EPR across the U.S. or even North America is a great example of how we are missing an opportunity to create efficiencies, economies of scale, and design a system that will work for harder-to-recycle industries.
2) Complex supply chains
Lubricants have tens of thousands of SKUs, moving through multiple routes to market: retailers, distributors, direct to customers, direct to businesses. Regulations often assume brand owners and distributors have information that is not actually available. There is an opportunity to simplify the way rules are written to accept the best available data that allows companies to do what is best for their businesses and customers while efficiently and effectively complying with regulations.
3) General lack of knowledge about lubricants, their purpose and life cycle, and how supply chains work by those passing enacting laws and writing regulations.
The primary purpose of lubricants is to reduce friction, leading to increased efficiency, reduced particulate pollution, and reduced emissions. Lubricants and their packaging are also highly recyclable, as evidence by a profitable re-refined lubricant industry that emerged naturally, without the pressure of regulation. Lubricants are essential to electrification, agriculture, manufacturing and more—the things that drive our economy. We need more peer reviewed data about lubricants to help legislators and regulators write laws and rules that make sense and are attuned to the realities of the lubricant business.
3) How EPR shifts responsibility—and what it looks like in practice
EPR intends to shift the end-of-life burden of packaging, and in some cases product, to the businesses placing the products in the market. Ideally, EPR would task industries to do this without picking winners and losers, dictating costs and fines and procedures, and recognize industry expertise in dealing with its products. Unfortunately, that is not how it is playing out in every state, and there is a real opportunity for legislators, regulators, experts, and industry to come together, share knowledge, pull best practices that are already proven in other jurisdictions, and create an EPR system that will work efficiently and be cost effective to protect both environmental goals and affordability.
4) One piece of advice to companies just starting EPR readinessDo not wait to take action. EPR is here, and given the growth of EPR in the world, will most likely expand in the next few years. Businesses must stand up in-house expertise quickly and determine their path forward, recognizing how EPR impacts their particular products and packages. They can choose to operate processes internally or hire external help or use a combination of the two that works best for them. It is important to join coalitions, like the NLCRC for lubricants, that understand their industry’s place in EPR requirements, especially unique risks. And be careful of generalized consultants who may not understand the particular EPR requirements of a particular product in a particular jurisdiction.
5) Why events like Lubricant Expo North America matter
Events like Lubricant Expo put EPR on the main stage, but in a way that is focused on the specific risks and requirements of the lubricant industry, which does not have the same concerns as bottles of water or bags of bread. The pre-event coordination ensures aligned messages, better Q&A, and take-home actions for attendees—speeding adoption of workable solutions. EPR is moving from policy to operations, and lubricants containers don’t fit curbside or “blue bin” recycling models. All lubricant producers need to understand how this impacts their business.
Hear Jami speak at lubricant Expo North America in the session Extended Producer Responsibility (EPR) in Lubricant Packaging, Track 1, 10:30am – 11:30am
View the full agenda here
