Cie Generale des Etablissements Michelin SCA

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Michelin provides an extensive, detailed picture of its climate-related lobbying. It names numerous individual measures it seeks to influence, including European Regulation 1235/2011 amending 1222/2009 on tyre labelling, the UN Global Technical Regulation 15 on the Worldwide Harmonised Light-Vehicle Test Procedure (WLTP), the revision of EU vehicle-safety legislation to introduce a wet-grip threshold, technical content for European Regulation 2017/2400 on heavy-duty-vehicle CO₂ emissions, consultations on the EU Emissions Trading Scheme’s indirect-cost compensation, and the Global Macro Roadmap for transport decarbonisation. The company also sets out how it lobbies and whom it targets: it supplies “technical recommendations to the European Commission”, sits on expert groups such as EGLA and UNECE working parties, exchanges directly “with country-level and EU regulators and associations”, and works indirectly through coalitions it helped create, including the Transport Decarbonisation Alliance and the Paris Process on Mobility and Climate. Finally, Michelin is explicit about the concrete outcomes it pursues, such as securing “threshold and labelling regulation for tire rolling resistance”, updating ISO 28580, harmonising “tailpipe testing procedures, including CO2, for light vehicles”, testing wet-grip performance “at legal tread depth limit…to avoid premature renewal of tires and save CO₂”, achieving accurate in-service conformity and fuel-consumption monitoring for trucks, and accelerating the transition to net-zero mobility before 2050 through zero-emission urban freight zones and other TDA workstreams. This breadth of specific policies, clear description of lobbying channels and audiences, and explicit articulation of desired regulatory changes demonstrates a comprehensive level of transparency on its climate-policy lobbying. 4
Lobbying Governance
Overall Assessment Comment Score
Limited Cie Generale des Etablissements Michelin SCA indicates that it has "constant engagements with best in class environmental associations" to ensure its engagement activities are consistent with its overall climate strategy, and it confirms a "public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement" by answering "Yes". However, the company does not disclose who oversees these engagements, lacks a described process for monitoring or managing alignment of its direct or indirect lobbying, and provides no information on any sign-off procedures or regular reviews to ensure its policy advocacy remains aligned with its climate commitments. 1