REGULATION
EU Ecolabel Could proposed changes to the
The European Union (EU) Ecolabel for lubricants has been enabling lubricant manufacturers to validate the environmental credentials of their products since it was first introduced in 2005. The criteria underwent a significant revision in 2011, and last year saw another series of proposed changes discussed, with the stated aim of the Commission being an increased percentage of lubricants on the market qualifying for the EU Ecolabel. It remains to be seen whether this aim will be achieved with the proposed changes, which have the appearance of harmonising the EU Ecolabel criteria more closely with those of the German Blue Angel standard RAL-UZ 178 rather than maintaining a separate identity.
The most controversial of the proposed changes, which divided the opinion of stakeholders during the consultation period, is the elimination of a mandatory minimum amount of renewable content. Until now, a lubricant was only eligible for the EU Ecolabel if it contained a minimum amount of renewable material as well as satisfying other criteria such as low aquatic toxicity and biodegradability. From January 2019 this criterion will become optional, allowing lubricants to be formulated with alternative base stocks such as polyalphaolefins, polyglycols and synthetic esters not produced from renewable materials, providing they satisfy other environmental end points such as aquatic toxicity and biodegradability. Additionally, if applicants choose to include renewable materials, their administrative burden and costs are likely to be increased due to a requirement to certify that the renewable source is sustainable. The main justification for these changes was that available life cycle studies could not demonstrate that a minimum amount of renewable content was ‘environmentally beneficial’, and in fact some experts claimed the opposite was the case. Additionally, it was recognised that other environmental standards that are relevant to the
42 LUBE MAGAZINE NO.146 AUGUST 2018
lubricants criteria threaten its identity? Mick Wragg, Senior Global Product Steward – Industrial Additives, Lubrizol
lubricants industry, such as the US EPA Vessel General Permit, do not include a mandatory amount of renewable material. However, an increased use of raw materials from renewable sources is a key element of the Commission’s Circular Economy initiative, and some observers believe that eliminating the need for a minimum content of renewable material for lubricants to qualify for the EU Ecolabel is an(other) example of uncoordinated regulation, if only because it removes the only existing regulatory driver for lubricants to contain renewable chemistry. The move away from a minimum amount of renewable material also means that some lubricants awarded the EU Ecolabel in future may not qualify as a Biolubricant/Bio-based lubricant according to the European Standard EN 16807 published in 2017, because this requires a fluid to contain at least 25% of renewable content.
Another major proposed change concerns how lubricants are to be categorised for the EU Ecolabel. Currently, the different lubricant types are assigned to one of five product categories, each with its own criteria. From January 2019 these lubricant types will be re-categorised into Partial Loss Lubricants (PLL), Accidental Loss Lubricants (ALL) or Total Loss Lubricants (TLL). Significant discussion took place between various expert stakeholders concerning the assignment of some lubricant types into these new categories, with the assignment of stern tube fluids to the PLL category proving to be most controversial. Many stakeholders familiar with the marine industry argued that ALL was a more appropriate category, especially with recent changes in ship design. It will therefore be interesting to see whether these arguments were persuasive or not when the EU Ecolabel criteria are voted on by the EU Ecolabel Board (EUEB). As well as reassigning lubricant types that are already in scope as either PLL, ALL or TLL, lubricants providing temporary protection from corrosion
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