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Revision of EU ecolabel Criteria for Lubricants Main modifications

Revision of EU ecolabel Criteria for Lubricants Main modifications. Hildo Krop, IVAM UvA BV, Amsterdam Rens Hartkamp, SMK, Dutch CB, The Hague. Timeframe of the revision process. March 2009 – 1st AHWG July 2009 – 1st revision proposal 16 November 2009 – 2nd AHWG 10 December 2009 – EUEB

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Revision of EU ecolabel Criteria for Lubricants Main modifications

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  1. Revision of EU ecolabel Criteria for LubricantsMain modifications Hildo Krop, IVAM UvA BV, Amsterdam Rens Hartkamp, SMK, Dutch CB, The Hague

  2. Timeframe of the revision process • March 2009 – 1st AHWG • July 2009 – 1st revision proposal • 16 November 2009 – 2nd AHWG • 10 December 2009 – EUEB • April 2010 – Voting

  3. Principles of the modifications • In line with new EU regulations • Limited influence on currently approved lubricants • Increasing compatibility with other schemes in the EU • Solving issues developed during the first EEL period • Dealing with other issues currently debated in the EU

  4. Main modifications • No change in the 4 product groups • Compatibility with other schemes • Undesired substance to 0.01% • Addition of seawater tests • Dealing with issues during the 1st period • Introduction of a LuSC-list/letter of compliance • Modification of grease criteria • Reducing possible addition infinite small amounts of unassessed substances • New types of lubricants • Dealing with issues currently debated • CO2 emission reduction and Manufactured NanoMaterials

  5. Topics for the next revision • Availability of data from REACH • Stating impurities on the application form • Reduction of fraction of sensitizers to 0.1% • GHS (CLP) compatibility • Further reduction of percentage B, C, E, F, G? • Sustainability criteria • Experience LuSc-list/compatibility with GESAMP-list

  6. Article 1 Enlargement of the product group scope • hydraulic oils, greases, chainsaw oils, two stroke oils, concrete release agents and other total loss lubricants • + (industrial?) gear oils, tractor transmission oils, stern tube lubricants (cat 1 and 2 or only 3), mooring oils (thruster lubs?) 4 Categories remain

  7. Article 2 Definitions added for • “substance” as defined in Regulation 1907/2006 • “preparation” as defined in Regulation 1907/2006 • “polymer” as defined in Regulation 1907/2006 • “nanoproduct” is a product where engineered nanoparticles have been intentionally added to the lubricant in order to improve specific properties.

  8. Article 3 • All intentionally added substances above 0.01% should be unambiguously stated giving their names and the mass concentrations in which they are used including CAS Registry and EU registry number where applicable • The criteria shall apply to the freshly manufactured product at the time of application (was: delivery)

  9. Criterion 1 - No change • No health and environmental R-phrase for the final product • Applies to the fully formulated end product

  10. Criterion 2 Exclusion of specific substances Applies to all intentionally added substances above 0.01%(was 0,1%) • CMR I and II • Organic halogen and nitrite compounds • Metal compounds except Na, K, Ca, Mg and Li and Al for thickening systems • OSPAR listed • Annex XIV of Reg 1907/2006 (REACH) • No engineered nanoparticles • List of priority substance within the FRW

  11. Criterion 3 Aquatic toxicity • Applies to substances present above 0.1% in the final formulation • Substances not assessed on aquatic toxicity and biodegradability are allowed to a cumulative maximum of 0.5% in the final formulation • Unidentified Substances of Variable composition and of Biological origin (UVCB): tested substance = marketed substance (chemical analysis)

  12. Criterion 3 Aquatic toxicity • Very toxic substances for each category < 0.1% (change from < 1% to < 0.1% for hydraulic fluids) • Standard sea water toxicity tests allowed • First check for chronic toxicity values, then acute toxicity • Both daphnia and fish on chronic tests (No change) • Both algae and daphnia tests only for acute (No change) • No test required if compliance letter from CB or substance / additive to be found on the Lubricant Substance Classification (LuSC) list

  13. Criterion 4 Biodegradability and bioaccumulative potential • Applies also to substances present above 0.1% in the final formulation • Bioaccumulation testing only in case substance does NOT biodegrade • For organic (not a surfactant and no test data: result of 3 QSARs • Greases: B+C = 25% instead of B=15%, C=10% No test if: • Compliance letter from CB or substance / additive on LUSC-list

  14. Criterion 5 Renewability • No change in the percentage • Report by applicant how to assess the influence of production, transport and use of bio-oils on biodiversity, GWP and environmental pollution of the primary production process

  15. Criterion 6 Minimal technical performance • Gear oils DIN 51517 – 3 • ISO 15380 2 elastomers tested on the PIB • Other slight changes

  16. Overview of the criteria (Table 1)

  17. LuSC-list • Formulation/application aid • Non-limitative • Two parts • Substances • Brands

  18. Layout LuSC-list substances

  19. Lay-out LuSC-list brands

  20. Thankyou foryourattention

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