HSE Committee Working Group
HSE
2023 has kicked-off with an intensive activity for the HSE Committee and its subgroups, who met in person in Brussels mid-January to set their strategic plan for the year.
Regarding the purely chemical legislations, members are working on publishing a response to the public consultation on the CLP regulation revision proposal, published at the end of 2022. The revision aims, amongst others, to set new labelling requirements, including some flexibility on the use of multi fold out labels. The HSE Committee is also working on a response to the ECHA consultations on the proposed restriction of medium chain chlorinated paraffins (MCCP) and on the very broad PFAS restriction proposal. While the lithium classification and the REACH revision proposal are facing some delays, members are getting ready for their publication by Q4 2023, if not before. The “International Lithium Association” (IliA) will start a lithium Risk Management Option Analysis (RMOA) to identify risks associated with the use of Lithiumsalts. ELGI and other associations are looking for detection methods for unreacted Lithium compounds. The HSE Committee will follow these activities proactive. Eventually, the biocide subgroup has finalised its position paper on the importance of biocides for metalworking fluids, which has been published on UEIL website and social media.
In addition to chemicals files, members are following intensively another dossier in regards to Ecodesign. The European Commission has indeed identified lubricants in its call for evidence on priority groups when implementing the Ecodesign for Sustainable Products Regulation (ESPR), whose proposal is currently under negotiation in the European Parliament and Council. Members of the subgroup have organised themselves to draft a response to the on-going public consultation, while the Secretariat is regularly in contact with other industry associations on that matter. In parallel, the subgroup is following the Safe and sustainable by design initiative (SSbD) which
52 LUBE MAGAZINE NO.174 APRIL 2023
aims to phase out of hazardous substances, which could also impact the performance of lubricants.
Therefore, strengthening the HSE Committee’s advocacy activities is the key priority for 2023.
Technical & Competition Committees Update The Technical and Competition Committees continue to make progress on a large number of cases. On the advocacy side, the Committees carry on their contacts with National Competition Authorities in order to express UEIL’s views regarding the MVBER and to make them aware of the uncompetitive behaviours faced on the market.
Regarding Regulation (EU) 2018/858 and more specifically provisions on Access to Technical Information (ATI), the Committees maintain regular exchanges with the European Commission regarding the failure from some Member States to implement or properly implement the Regulation. The issue has been raised once more by DG GROW during a meeting with National Type Approval Authorities on 16 February 2023.
Taxation Task Force The EU co-legislators are currently negotiating the revised Energy Taxation Directive that the European Commission published last year. This revised Directive is important for the lubricant sector to promote a level playing field in Europe.
Furthermore, 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 the 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 at the end of 2023.
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
