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

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

April 2010 – Voting

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

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

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

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

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.

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)

Criterion 1 - No change

No health and environmental R-phrase for the final product

Applies to the fully formulated end product

Criterion 2 Exclusion of specific substances

Applies to all intentionally added substances above 0.01% (was 0,1%)1. CMR I and II2. Organic halogen and nitrite compounds3. Metal compounds except Na, K, Ca, Mg and Li and Al for

thickening systems4. OSPAR listed5. Annex XIV of Reg 1907/2006 (REACH)6. No engineered nanoparticles 7. List of priority substance within the FRW

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)

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

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

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

Criterion 6

Minimal technical performance

Gear oils DIN 51517 – 3

ISO 15380 2 elastomers tested on the PIB

Other slight changes

Overview of the criteria (Table 1)  Category 1 Category 2 Category 3 Category 4

Hydraulic fluids, industrial gear oils,

tractor transmission oils

and stern tube oils

Greases, stern tube greases

Chain saw oils, concrete release

agents, mooring oils and other total loss

lubricants

Terrestrial and marine two-stroke oils

Health or Environmental R-phrase

None None None Noneof the lubricant at the time of application

(Criterion 1)  Category 1 Category 2 Category 3 Category 4

OSPAR-listed; the Community list of priority substances in the field of water policy; organic halogens; nitrites; metals and

metallic compounds except Na, K, Mg, Ca and for thickeners Li, Al; CMR cat 1,2 (R45, R46, R60 or R61); Annex XIV of

Reg 1907/2006; Manufactured nanoparticles.

< 0.01% < 0.01% < 0.01% < 0.01%

(Criterion 2)

Aquatic toxicity Cumulative mass percentages (% w/w) of substances present in

(Criterion 3.2 only) Category 1 Category 2 Category 3 Category 4

Not toxic (D)Acute toxicity > 100 mg/L

Not limited orNOEC > 10 mg/L

Harmful (E)

10 mg/L < Acute toxicity 100 mg/L

20 25 5 25or

1 mg/L < NOEC 10 mg/L

Toxic (F)

1 mg/L < Acute toxicity 10 mg/L

5 1 0.5 1or

0.1 mg/L < NOEC 1 mg/L

Very toxic (G)Acute toxicity 1 mg/L

0.1/M(*) 0.1/M(*) 0.1/M(*) 0.1/M(*)orNOEC 0.1 mg/L

LuSC-list

Formulation/application aidNon-limitativeTwo parts

Substances Brands

Layout LuSC-list substances

Substance CAS noEINECS

noBiodegradability

Aquatic toxicity

Remarks

Fatty acids C12-1490990-10-6

292-771-7 Ultimately (A) Not toxic (D)Organic substance removed from Annex IV to Annex V of Regulation 1907/2006

(REACH) by Regulation 987/2008

Fatty acids C12-18 and C18-unsatd.

90990-15-1

292-776-4 Ultimately (A) Not toxic (D)Organic substance removed from Annex IV to Annex V of Regulation 1907/2006

(REACH) by Regulation 987/2008

Fatty acids rape-oil erucic acid-low

93165-31-2

296-916-5 Ultimately (A) Not toxic (D)Organic substance removed from Annex IV to Annex V of Regulation 1907/2006

(REACH) by Regulation 987/2008

Lithium 12-hydroxystearate, pure,

C19H38O3Li

7620-77-9

231-536-5Inherently

aerobically (B)Harmful (E) Assessed by the Dutch CB

Dilithium azelate, pure38900-29-7

254-184-4

Not biodegradable and not

bioaccumulative (C)

Toxic (F) Assessed by the Dutch CB

Dilithium sebacate, pure19370-86-6

242-999-8

Not biodegradable and not

bioaccumulative (C)

Harmful (E) Assessed by the Dutch CB

Lay-out LuSC-list brandsProposed maximum

treat rate %Based on 100% treat rate

Brand nameCat 1 Cat 2 Cat 3 Cat 4

EEL Biodegra-

dation

EEL AquaticToxocity Renew-

abilityRemarks Assessed by

A/B/C/X/- D/E/F/G(M*)

Base fluids

Uniflex 939LAN Not limited by biodegradationand aquatic toxicity

100%A 100%D 89.6% Dutch CB

Synative ES G20 AZ

Not limited by biodegradationand aquatic toxicity

100%A 100%D 81.6% Dutch CB

Thickeners

Additives

Irgalube® 353 1% 1% 1% 1% 100% C 100% E 0% Limited by R43 Dutch CB

Irgacor® L 12 0.2% 0.2% 0.2% 0.2% - - 0%A mixture of different substances with the major substance represented at a maximum of 50% w/w.

Dutch CB

Irganox® L 57 0.5% 0.5% 0.5% 0.5% - 100% E 0%A mixture of different substances with the

major substance represented at a maximum of 20% w/w.

Dutch CB

Irgalube® 5010 0.58% 0.58% 0.58% 0.58% 52% C 52% F 0% Dutch CB

Additin RC2415 12.5% 2.5% 1.25% 2.5% 100% C60% E 40% F

95% Dutch CB

Additin RC3640 1% 1% 0.5% 1% 100% C 100% F 0% Max treat rate depends on R40. Dutch CB

Additin RC9321 0.36% 0.36% 0.36% 0.36% - - 0%A mixture of different substances with the major substance represented at a maximum of 28% w/w.

Dutch CB

Polymer systems