HSE Committee Working Group HSE
The high EU chemicals legislation actuality has kept the HSE Committee and its subgroups intensively busy in the last months.
Main file of this first quarter of 2023 is the CLP regulation revision, for which UEIL submitted a response to the public consultation in March. The revision aims, amongst others, to set new labelling requirements, and to cover “multi-constituent substances”. Stephan Baumgärtel, chair of the HSE Committee and Cindy Vandeercastel, chair of the CLP subgroup, went on a tour to promote UEIL’s position. Together with the Secretariat, they met in the European Parliament the Rapporteur Ms. Maria Spyraki (EPP, Greece) in charge if leading the position of the European Parliament on this file. They also held an online exchange with the shadow rapporteur MEP Joao Albuquerque (S&D, Portugal) and Hans Ingels, Head of Unit Chemicals at DG GROW, European Commission. The Secretariat will also participate to a roundtable organised by the Greens this week on the dossier.
The HSE Committee is also working on a response to the ECHA consultation on the PFAS restriction proposal, with a position to be ready ideally before the beginning of June. Members are also working on a response to the Ecodesign for Sustainable Products Regulation (ESPR) public consultation open until 12 May, where lubricants have been identified by the European Commission as priority groups. Any company is welcome to participate to the public consultation. Besides the responses to the questionnaire, a position paper has already been finalised and endorsed by the Board during their recent meeting at the end of April. In parallel, members are following the Safe and sustainable by design initiative (SSbD) which aims to phase out of hazardous substances. 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 Committee met in person in Brussels on 18 April, with a guest speaker from Cyclevia, the French eco-organisation of the mineral oil sector. This was
also the opportunity for members to exchange with him and learn more about this national initiative. Members also shared intelligence on the latest national associations news and brainstormed on next steps to continue implementing the 2023 strategic plan.
Technical & Competition Committees The Technical and Competition Committees gathered online to work on the various technical and competition cases currently open and exchange on the latest development on relevant EU policies. Over the past months, many non-compliance cases have been closed successfully, while the rest are evolving in the right direction.
Among the highlights, is the publication of two OEM bulletins on Mercedes-Benz MB 228.51 LT so called specification. After several exchanges, Mercedes-Benz clarified their communication explaining MB 228.51 LT was not a specification, but the trade name of the Mercedes-Benz genuine engine oil approved in the 228.51 category.
Regarding policy updates, at the EU level, the European Commission has published its revision of the Motor Vehicle Block Exemption Regulation (MVBER). As expected, the revision has unfortunately only made small changes.
Taxation Task Force The EU Co-Legislators are currently negotiating the revised Energy Taxation Directive that the European Commission published two years ago. 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.
Continued on page 45 LUBE MAGAZINE NO.175 JUNE 2023 43
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