Goodyear Tire & Rubber Co/The

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Goodyear provides a high level of transparency around its climate-policy engagement. It names a wide array of concrete legislative files it works on, including the EU Green Deal and associated Ecodesign for Sustainable Products proposal, the EU Data Act and in-vehicle data access consultation, the EU Deforestation Regulation, the ‘Euro 7’ vehicle-emissions proposal, the U.S. EPA SmartWay programme, NHTSA’s Tire Fuel-Efficiency Consumer Information rule, Peru’s “Decreto Supremo N° 024-2021-MINAM” on end-of-life tyres and Mexico’s “Ley General de Cambio Climático.” The company also describes how it engages: it “works independently and through our various industry trade associations to engage with governments and regulators,” is “working with USTMA to provide comments to NHTSA,” and is “assisting NHTSA by participating in its tire testing programs,” while in Europe it “has been providing the legislator with expertise on viable and efficient methods for traceability in the rubber supply chain.” These statements identify both the mechanisms (direct dialogue, written comments, participation in testing programmes, and industry-association advocacy) and the specific targets (NHTSA, EU legislators and regulators). On desired outcomes, Goodyear indicates that it “supports EU legislative intentions for sustainable sourcing of raw materials,” seeks “sensible regulations that advance goals related to climate and the protection of the environment,” and wants rules that “optimize contributions of its tires and services to lower the overall carbon footprint of road transport.” Although these objectives are largely qualitative, the company consistently communicates the policy direction it backs and the reasons for its stance. Taken together, these disclosures demonstrate strong transparency on what policies Goodyear lobbies, how it lobbies, and the climate-related results it is pursuing.	3

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Goodyear discloses robust governance for its climate strategy and broad compliance processes, but we found no evidence of any governance framework specifically for its lobbying activities or for aligning lobbying with climate policy. While Goodyear affirms “Yes” when asked if it has “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” the company does not detail any mechanisms to manage or monitor direct or indirect lobbying. It states that “Goodyear, in principle, does not make donations, either directly or indirectly, to political parties or candidates” and describes that “Goodyear’s Global Policy Committee is responsible for the policy development and management process,” yet neither disclosure addresses oversight, alignment or review of lobbying efforts in relation to its climate objectives. We found no evidence of a named individual or formal body tasked with ensuring that lobbying—either internal or through trade associations—supports Goodyear’s climate goals.	1