Continued from page 20

The European Commission has provided indicative timings around innovating for safe and sustainable EU chemicals and SSbD criteria are set to be developed and implemented by 2022 but in the absence of criteria from the European Commission, how should we interpret “safe” and “sustainable”?

If we take the European Ecolabel for Lubricants as a reference point, then ‘safe’ might be defined as substances which are not substances of very high concern, not classified as carcinogenic, mutagenic, reprotoxic (CMR) substances, not endocrine disruptors, and are not persistent, bioaccumulative and toxic. ‘Safe’ may also allow for the use of substances which carry certain hazard statement (H) phrases but have actual and cumulative values below specific, well-defined threshold values. ‘Sustainable’ may suggest the use of raw materials which are derived from renewable crops or animal fats, which may or may not need to be validated by third-party chain of custody certificates, such as, RSPO (Round Table for Sustainable Palm Oil). What then is the long-term future of petrochemical derived base fluids and additives, many of which are safe? And what of substances which are readily biodegradable, inherently biodegradable or non-biodegradable, will these criteria be judged under safe or sustainable?

We can justifiably ask if we are beginning to see a future scenario where all lubricants developed and placed into the European market will be environmentally acceptable lubricants, formulated and certified in accordance with the current or future revisions of the European Ecolabel for Lubricants. Of course, there are many examples where all three

elements of performance, safe and sustainable are designed into base oils and additives, some with a high degree of renewable, sustainable raw material content but one only needs to look to the current Lubricant Substance Classification (LuSC) List to see how few additives are available for the formulation of EU Ecolabel compliant lubricants. If this is what the future looks like, safe and sustainable by design poses both a very real threat and opportunity for base oil, additive and lubricant innovation across many different applications and one that we must be willing to embrace.

Making safe and sustainable chemicals is only one consideration as part of a wider circular economy, design must also take into consideration the creation of products that can be suitably re-used or recycled at the end of their useful life. Forward-thinking companies should be acting now and integrating the fundamental basic principles of SSbD into their corporate and research and development strategies.

References 1. The European Green Deal, Document 52019DC0640, 11th December 2019. (Link: EUR-Lex - 52019DC0640 - EN - EUR-Lex (

2. Chemicals Strategy for Sustainability Towards a Toxic-Free Environment, Annex to the European Green Deal, COM(2020) 667 Final, 14th October 2020.


Figure 2: Current and future aspirational approaches for creation of products that are safe and sustainable by design



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