Technical Committee The last UEIL Technical Committee meeting was held on 22 May 2019 in Brussels.

The Technical Committee is currently investigating: • Industrial

• Off Road • PCMO • HDDO

• Two Stroke

4 cases 1 case 6 cases 3 cases 1 case

The Technical and Competition Committees recently issued in 2018-2019 the following OEM Bulletins:

Fiscal issues The European Commission is currently reviewing the Energy Taxation Directive that it withdrew in 2015 (as the file was blocked in Council) and will probably publish a revised Energy Taxation Directive after the EU elections and election of the new European Commission in November 2019. UEIL hopes that through a revised Energy Taxation Directive under the new European Commission, a real level playing field can be achieved for the lubricants market in Europe.

Related to UEIL’s objective to prevent the inclusion of lubes under EMCS, certain Member States expressed their concern about increased fraud with lubes in Europe and are once again increasing the pressure to include lubes under EMCS. UEIL will continue its outreach to the fiscal attachés of the Permanent Representations of the EU Member States in the coming weeks to express its concern. However, it is clear that under this European Commission (mandate ends in October 2019) no EU actions are foreseen.

UEIL HSE Committee The HSE Committee met on 22 May 2019.

The changes in industrial lube product requirements, as well as in legislation, keeps the UEIL HSE group busy. During our last meeting we discussed a large number of topics.


First of all, companies manufacturing lubricants labeled as “dangerous” are concerned about the new bureaucratic burden resulting from “Annex VIII to CLP”, according to which companies have to provide the full formulation to the ECHA, in addition to a formulation number (UFI) associated with a particular formulation printed on the container.

Biocides are a recurring topic on our agenda. Metalworking fluids (MWF) have a very short lifetime without biocides, and bacteria could be harmful to workers.

Formaldehyde releasers have been used for decades to protect MWF but are now suspected of causing cancer, and alternative biocides are rare.

Additionally, there are doubts about the future of the common biocide BIT. Following an accident in a factory in China, the supply of a BIT predecessor has ceased and we don’t know when production will restart. MWF suppliers are developing more biocide- free formulations on the basis of different chemistry that excludes the use of boric acid, which is again the focus of the ECHA.

In a recent consultation, ECHA proposes lowering the “specific concentration limit” of boric acid from 5.5%to 0.3%. That means that any MWF concentrate with a boric acid concentration of greater than 0.3% needs to be labeled as “toxic for reproduction” which is not acceptable for end users.

Our colleague from the US, John Howell, explained that the issue of how to label products composed of low viscosity hydrocarbons under GHS has been on the table in the US for about two years.

The classification of hydrocarbons with a kinematic viscosity of < 20.5 mm2/sec with the GHS symbol “exploding chest” creates great confusion, since the same pictogram is used for carcinogens. Furthermore, the scientific reasons for this classification is unclear.

The US lube manufacturer association ILMA will further discuss this and warn the GHS Committee

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