and metalworking fluids have been added to the scope of the EU Ecolabel in the PLL or ALL category respectively. Additionally, lubricating greases will be assigned to either PLL, ALL or TLL depending on their end use, which will define the criteria that must be met to qualify for the EU Ecolabel. An initial proposal to include four-stroke lubricants in the scope of the EU Ecolabel, essentially with the aim of increasing the percentage of total lubricants sold in EU that would qualify for this award, was not carried forward.
Several other proposed changes appear to be less controversial: lubricants qualifying for the EU Ecolabel will have to contain an even lower amount of hazardous substances, although an analysis by the regulators of existing EU Ecolabel approvals for lubricants suggests that this change will not lead to the loss of many current licences. Minimising/ eliminating hazardous chemistry is a basic principle of the EU Ecolabel; in the past, this was achieved by only allowing lubricants not classified as hazardous to qualify even though they might have contained a low amount of hazardous ingredients whereas going forward the amount of such ingredients will be further restricted, especially for some hazard end points. There was one piece of good news for formulators however, as a last-minute change of position by the regulators meant that so-called Substances of Very High Concern (SVHCs) could be present in qualifying lubricants providing they are below 1000 ppm. Initially, it was proposed that there would be no de minimis limit to these substances, leaving industry facing the impractical situation of having to certify that their products contained no SVHCs down to parts per billion or parts per trillion amounts to qualify for the EU Ecolabel.
A subtle change in the definition of biodegradability from rapidly to readily may be more challenging for base stocks to achieve, as they will now be expected to meet the ’10-day’ window to qualify as ‘readily’ biodegradable. In response to concerns that very few commercially available base stocks would meet this stringent criterion, the regulators have conceded that multi-constituent substances or substances with Unknown or Variable composition, Complex reaction products or Biological in nature (UVCBs) would not need to satisfy this requirement providing the applicant can justify the biodegradation result. Similarly, concern was expressed that a proposed increase in the upper limit of the octanol water
partition coefficient (expressed as LogKow) from > 7 to > 8 for the bioconcentration criterion, may require some applicants to develop new data to qualify for the updated criteria. This could have increased the cost of requalifying lubricants for the EU Ecolabel, although the author understands that this proposal may not have been carried forward to the definitive version of the criteria to be voted on by the EUEB. Several observers commented that the combination of these proposed changes, as well as the changes to the amount of hazardous ingredients permitted in the lubricant, may threaten the status of many of the substances and products currently found on the Lubricant Substance Classification List (the so-called LuSc List). If this was the case and one or more of the ingredients is no longer on the LuSC list, then there could be an increased administrative burden on current licence holders when they re-apply to have their product certified.
Finally, packaging requirements for plastic containers have been revised and will apply equally to products sold to businesses or direct to the consumer. This means that from 1st January 2019 plastic packaging will be required to contain at least 25% post-consumer recycled material. Early in the discussion the Commission also proposed the inclusion of a take-back scheme for empty containers but eventually decided not to include this requirement in the current update.
The final criteria document was presented to the EUEB in February and, by the time this article is published, they are expected to have voted on it at the June meeting. Usually the Decision will be published six months later and current licence holders will then have a further period (typically another six months) to confirm that their product(s) still meet the (new) EU Ecolabel criteria, and apply to have their licence(s) renewed. Industry had proposed a longer transition period in case new data needed to be generated, and it is unclear at present whether this will be granted. It also remains to be seen whether the revision to the EU Ecolabel criteria achieves the Commission’s aim of increasing the uptake of this environmental accreditation by the EU lubricants industry, or whether the changes prove to be a revision too far for lubricant manufacturers in the absence of a significant demand from the EU market for this type of label.
LINK
www.lubrizol.com
LUBE MAGAZINE NO.146 AUGUST 2018
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