HSE Committee Working Group
Health, Safety and Environment Committee (HSE) After focusing its activities in the 1st quarter of the year mostly on the Classification, Labelling, Packaging (CLP) regulation revision, the HSE Committee is now dedicating its effort on the PFAS restrictions proposal. The HSE REACH subgroup is building UEIL’s response to the ECHA public consultation, with the aim to bring as many data as possible and find alliances amongst other stakeholders. Members aim to finalise the draft response by mid-July in order to be fully equipped to upload the response before the 25 September deadline. We would also like to ask lube blenders to encourage their customers to participate on the consultation and explain why PFAS base lubricants are essential for their business.
We would also like to remember manufacturers and resellers to notify their lubricants designed for industrial use until end of this year. The notification obligation applies only for lubricants, if they are labeled as “dangerous” for human health. The notification can be done at the EU poison center portal:
https://poisoncentres.echa.europa.eu/
In the meantime, the SSBD/ESPR subgroup has been kept active with drafting a response to the Ecodesign for Sustainable Products Regulation (ESPR) public consultation, where lubricants have been identified by the European Commission as priority groups. Our position is to get lubricants out of the scope of this EcoDesign directive since lubricants provide only functionality and are working only in conjunction with other equipment; a classification without looking at the use phase is of limited value. ECHA has also recently launched a call for comments regarding the draft opinion of the Committee for Socio-economic Analysis (SEAC) concerning the restriction proposal from ECHA on Medium-chain chlorinated paraffins (MCCP) and other substances that contain chloroalkanes with carbon chain lengths within the range from C14 to C17. As for the CLP regulation revision, for which UEIL submitted a response to the public consultation in March, both Parliament and
50 LUBE MAGAZINE NO.176 AUGUST 2023
Council are working on their own position, with a trilogue phase expected to start on Q4 2023. The Committee held a round of engagement this Spring, with fruitful conversations with members of the European Parliament and the European Commission.
The Committee will meet in person in Milan early September, hosted by Federchimica.
Technical and Competition Committees Since the last online Technical and Competition Committees meeting in April, members continue working on the various technical and competition open cases.
To advance efficiently, the Committees are keen on making their voices heard, leveraging soft power or legal procedures if needed. Besides, online meetings with targeted stakeholders are being organised when necessary. Over the past months, many non-compliance cases have been successfully closed, leading to the publication of two OEM bulletins on Mercedes-Benz MB 228.51 LT so called specification.
Regarding policy updates, at the EU level, the European Commission published its revision of the Motor Vehicle Block Exemption Regulation (MVBER), effective from 1st of June and succeeding to the previous text. As expected, the revision has only made small changes. This new version of the text is now applicable until 31st of May 2028. The Committee will gather for the third time of the year in person in September in Brussels.
Sustainability Committee UEIL/ATIEL PCF Methodology Update UEIL and ATIEL are excited to report a significant progress in the development of the “Methodology for Product Carbon Footprint (PCF) Calculations for Lubricants and other Specialties”. Over more than the last half-year, our wide-ranging, cross-industry working group has devoted itself to constructing this harmonised methodology.
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