News HSE Committee Update

The September meeting of the UEIL HSE Committee once again took place through a video conference call, but we hope to meet in Brussels for our next meeting in January. During its meeting, the Committee discussed the reorganisation of its structure in order to facilitate the efficient functioning of the committee. The ever-expanding legislation leads to complex rules under which chemicals can be approved and used in lubricants, requiring the Committee to adapt to this environment. For this reorganisation, the key development will be the establishment of working groups that focus on specific topics such as changes under REACH and CLP between the HSE meetings. In addition, “folder champions” will provide updates on selected, narrowly defined topics on the three committee meetings organised throughout the year. Regarding the dynamic regulatory framework, a foretaste can be seen in the planned or active restrictions on biocides, fluorinated hydrocarbons and chlorinated paraffins. Here, the HSE Committee is also working with other associations to gather and communicate arguments to the authorities. Together with ATIEL and ATC we participated in consultations on the use of PFAS, and established communication papers on the proposed classification on Li-salts, the key constituent of many greases. We are also in direct contact with the EU and are planning another conference call with DG Environment in October. Moreover, a meeting with SMEunited is planned to explore how we can coordinate our interests.

Technical & Competition Committees Update The Technical and Competition Committees continue to make progress on a number of legal cases. The latest meeting of members took place on Wednesday 15 September.

On the advocacy side, the Committees have continued to engage with the European institutions regarding the evaluation of the Motor Vehicle Block Exemption Regulation (MVBER) and the adoption of the draft Delegated Regulation amending Annex X of Regulation 2018/858 (on approval and market surveillance of motor vehicles and their trailers).

The evaluation report on the MVBER was published by the European Commission on the 28 May. The


next step is for the Commission to decide whether to let the current MVBER regime lapse by 31 May 2023, renew it or revise it. The Committees are drafting a new letter to the Commission urging them to maintain the MVBER but also to make some improvements in particular with regard to anti-competitive behaviours and access to technical information (as outlined in the position paper). Through concrete examples, this letter aims to make clear to the Commission that anti-competitive behaviour is a real problem which needs to be addressed in a revised MVBER.

The Committees’ chairs also met with Italian Member of European Parliament Isabella Tovaglieri in September for a fruitful exchange on the challenges and opportunities faced by the European lubricant industry in particular with regard to the MVBER.

Taxation Taskforce Update The European Commission published its Energy Taxation Directive (ETD) this summer. In the European Commission’s proposal: • lubricants are out of the scope (we asked to include lubricants in the scope with the aim to have a level playing field);

• 2710 and 3403 are added to the EMCS article when moved in bulk, while we wanted EMCS only for light lubricants when moved in bulk;

• 3811 are also added to the EMCS with no limitation to bulk.

UEIL will now lobby the EU Member States and the Members of the European Parliament to positively influence the draft ETD proposal of the European Commission.

Related to UEIL’s objective to prevent the inclusion of lubes under the Excise Movement and Control System (EMCS), certain EU Member States are concerned about increased fraud with lubes across Europe and are once again increasing the pressure to include lubes under EMCS. UEIL will continue its outreach to EU Member States in the coming weeks to express its concern and will discuss with the European Commission the option of a definition of ‘light lubes’ that might be included under EMCS in the near future.

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