UEIL News
Annex VIII to CLP: Submission of information on dangerous mixtures
“New” legislation unsettles consumers as well as manufacturers of lubricants. We’re talking about Article 45 of the “CLP”, the legislation on the Classifying, Labelling and Packaging of dangerous goods in the EU. The legislation has been in force since 2012, but Article 45 is now the focus. It stipulates that “Member States shall appoint a body or bodies responsible for receiving information (…) This information shall include the chemical composition of mixtures placed on the market and classified as hazardous (…).” This is nothing new so far: in many EU countries the submission of information about dangerous mixtures is required by local poison centers, at least for consumer products such as washing powders. What is new is that you must now send information on any dangerous mixture to a central ECHA (European Chemicals Agency) database, instead of the local poison centers. However, the Member States may still have additional requirements.
Annex VIII to CLP describes when, how, and which information should be submitted. There is also an 85-page guidance document which explains Annex VIII.
Unfortunately, some false rumours have been circulating about Annex VIII. First, only information about mixtures with health hazards (and some physical hazards) need to be submitted. Lubricants labelled as dangerous for the environment are excluded. Most lubricants for consumer use (e.g. engine oils) are not labelled as “dangerous” and are therefore not subject to this legislation.
Second, the submission of information on lubricants labelled as “dangerous” for industrial use only is required from January 2024, and one year later for products where the information has been submitted previously.
Information on dangerous lubricants for consumer and professional use must be submitted earlier, in January 2021. The original date for consumer products was January 2020, but this has now been postponed to 2021.
The submission does indeed include the full formulation and other information in the language of the country where the product is placed on the
50 LUBE MAGAZINE NO.154 DECEMBER 2019
market (make sure to tell your re-sellers not to deliver dangerous lubricants in another country without notification!) However, the suppliers, i.e. (toll-) manufacturers, private-labellers and related companies are responsible for the submission. As a part of the submission, a so-called “UFI” or “Unique Formula Identifier” needs to be generated (from the manufacturer’s VAT number and a numeric formulation number) and printed on the container / SDS. This means that customers may conclude from the UFI to the lube blender. There is a website available (
https://www.decoder-ufi.com/) which calculates the VAT number from the UFI. So you could generate new UFIs for re-branding.
Indeed, many lubricants formulated for industrial use only are labelled as “dangerous”, and our industry should use the next years to prepare for 2024. Questions arising from the legislation are an ongoing topic of the UEIL HSE committee, and lube blenders are invited to participate in these discussions.
Taxation Task Force update The European Commission is currently reviewing the Energy Taxation Directive that was withdrawn in 2015 (as the file was blocked in Council). The revised Energy Taxation Directive will probably be published in Q2/Q3 2020.
Related to UEIL’s objective to prevent the inclusion of lubes under EMCS, certain Member States expressed their concern on 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 EU Member States in the coming weeks to express its concern.
Finally, UEIL is actively lobbying to increase the quota on Group II base oils, as the majority of the EU Member States and the European Commission want to end the current duty suspension on the import of Group II base oil by January 2020.
TC/CC Committees
Because of their obvious synergies, the Technical Committee (TC) and the Competition Committee (CC) of UEIL – the Union of the European Lubricants Industry – organise joint meetings and work hand in hand.
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60 |
Page 61 |
Page 62 |
Page 63 |
Page 64 |
Page 65 |
Page 66 |
Page 67 |
Page 68
