Sukhy Ubhi Lubrizol Deborah Grigg UKLA Caroline …...2014/06/27 · Automotive unit in DG ENTR (30 January) • Meetings with FIGIEFA and CECRA (10 February) • Conference call

Minutes of the UK Delegation to UEIL Meeting held on: Friday 27th June 2014, at Macdonald Hill Valley Hotel, Whitchurch, Shropshire.

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Z:\UKLA Common\UK Delegation to UEIL\14 UK Section\27 06 14\Minutes of the UK Delegation to UEIL Meeting held on 27 06 14.docx

Chairmans Initials

Attendees:

Rod Pesch UKLA

Kevin Williams Multisol

Nick Burrows Multisol

Andrew Lamb Multisol

Stuart Gregory Petrofer

David Bell Ironsides

Peter Vickers Vickers Oils

Abigail Riding Nynas Naphthenics

Tim Bates GB Lubricants

Sukhy Ubhi Lubrizol

Andrew Findlow Vanderbilt International Sarl

Deborah Grigg UKLA Caroline Slinn Afton

Richard Crombie R S Clare

Apologies:

Peter Berrisford Petrico

Nigel Bottom Witham Oil and Paint

Andy Barwell Esterchem

Sebastian Crawshaw OATs

1. Welcome and Anti Trust Statement: RAP welcomed everyone to the meeting and read out the UKLA anti competitive statement which was agreed by all present.

2. Apologies were received as above.

3. The proposed Agenda was agreed with no additions.

4. Approval of the minutes of the last meeting held on 9th January 2014. These were unanimously approved and signed by RAP.

5. Matters Arising from the last meeting held on the 9th January 2014. There were no matters arising.

6. UK Delegation Presidents Report. i) Presidents Overview:

RAP presented the Presidents Overview. This is attached to the minutes


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ii) Lobbying Activities – see Taxation report below.

iii) Committee Reports a) HSE: Caroline Slinn reported back to the delegation as follows: CLP VSI have conducted a survey of German companies on the CLP labelling requirements which has raised concerns over how many companies comply with the new regulations and costs to companies that new labelling will incur. An information document aimed at end users will be available on the UEIL website soon. This will explain the changes in labelling are due to legislative changes and not changes in formulation.

There are two current Live Topics 1. Indoor Air Quality

UKLA is funding an HSL project to evaluate the effectiveness of all the various methods presently used to measure indoor air quality. A two year project has recently started in Finland between the Finnish research centre and the Institute of working environment, looking at indoor air quality (specifically as a result of oil mixed filters).

2. Ionic mixtures

Draft summary documents summarizing the work and results have been prepared and these will be published on open section of UEIL website. They are intended for people to use to generate SDS’s. The group’s interest is to have consistency, the more people that use it the better.

Key Topics 1. Boric Acid

Polish proposal was for reclassification of boric acid from 1B to 2: Opinion of RAC is that they do not support any change in classification 21/3/14 and it is likely that ECHA will adopt this opinion. The present limit for boric acid is 5.5%. This was not mentioned in the polish dossier, therefore RAC couldn’t comment as part of the official opinion on the


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polish dossier. They did however comment that the original limit was calculated using an old method and should now be calculated according to CLP criteria. Based on new criteria a limit of 0.3% would be applied (same as general / default limit). This isn’t officially part of RAC’s opinion but leaves the topic open to further review. There is no news yet on whether or not boric acid will be prioritized for authorization. A German paper supports keeping the classification as it is. This paper together with UKLA position paper is likely to form basis of final UEIL paper. 2. REACH / SDS, Mixtures and MWF’s

There is some confusion around exposure limits; if a material in the formulation has an exposure limit then it has to be mentioned in the SDS section 8, even if it is does not have a hazard classification and does not appear in section 3. The project in Germany looking at creating a REACH type regulation for mixtures has now been put on hold. 3. ATIEL/ATC GES (generic exposure scenarios) was presented to ECHA in Feb 2014. The strategy is to present this to as many people as possible to ensure that it is adopted as normal practise. There is still some work to be done to convert GES into CLP. 6. Biocides MWFs can be: Biocidal products, Treated articles or neither. It is recognised that

we need a common view and approach to labelling MWFs throughout Europe. George Mansveld of Cimcool has convinced Dutch authorities that MWFs are not biocidal products, but are treated articles. This is now incorporated in their manual of decisions. The recommendation of the HSE committee is that if MWF producers do not claim any biocidal activity or long life etc. and then they will not have to state that the product contains a biocide on the label. 7. Formaldehyde in Metalworking Formaldehyde is to be reclassified as carcinogenic 1B and germ cell mutation category 2 under CLP, in April 2015 and ECHA are expected to put it on the SVHC list.

For formaldehyde releasers that have <0.1% of free formaldehyde (as supplied)


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there is no change in labelling expected, therefore no change to the labelling of the MWF will be required.

All hazard label requirements at the moment assume no change to the ingredients chemically.

There is a working group in Germany looking at measuring free formaldehyde.

MBM is the first formaldehyde releaser to be looked at as part of BPR approval process Austria has put a substitution proposal forward for MBM. Criteria are based on the intrinsic hazardous properties in combination with the use. An active substance will be considered as a candidate for substitution if any of the following criteria are met:

It meets at least one of the exclusion criteria (such as classified as a CMR- this could cause the active to be refused approval and substitution mandated).

It is classified as a respiratory sensitizer

Its toxicological reference values are significantly lower than those of the majority of approved active substances for the same product type and use

It meets two of the criteria to be considered as PBT

It causes concern for human or animal health and for the environment even with very restrictive risk management measures

It contains a significant proportion of non-active isomers or impurities Austria is arguing that formaldehyde is instantly released in use. Worst case scenario is that this could be reclassified 1B Cefic (FABI) lobbying against this, support requested. If MBM is reclassified then by default all other formaldehyde releasers could follow suit.

b) Competition and Technical Committees Tim Bates gave a presentation showing the cases managed by the Technical and Competition Committees. The Technical Committee and the Competition Committee have issued 4 OEM Bulletins since the last meeting:

Mann Truck & Bus March 2014 Jaguar Land Rover Manuals & Specifications April 2014 Volvo Car Corporation Specification VCC RBSO-2AE 0W-20 April 2014 Mazda Owner Manuals & Automatic Transmission Fluids May 2014 Hydrema WL 480B Loader May 2014

And one UK Marketer Bulletin in February 2014.


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The current cases, which have been raised by the membership, are: Agricultural Equipment 0 cases as they have all been transferred to the

Competition Committee Off Road Equipment 3 cases Passenger Cars 3 cases Heavy Duty Diesel 1 case Performance Claims by Marketers 2 cases The next meeting is scheduled to be held in Brussels on Wednesday 24th September 2014.

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7. UEIL Taxation Task Force Peter Vickers reported on the UEIL Taxation Task Force.

i) EMCS In 2011 two EU Member States made a request to the Commission to include lubricant oils[1] within the Excise Movement and Control System (EMCS) to address the then current issues of fraud. This request has been extensively discussed within the European Excise Committee. During the last debate within the European Excise Committee on the 27th of June 2013, the Presidency and Commission have decided to stop the discussion to include lubricant oils under ECMS within the Committee, as there was no consensus among the EU Member States. However we understand that the discussion to include light [2] lubricant oils within EMCS is again on the European political agenda through the discussions on the review of the Energy Taxation Directive (ETD). • Given the fact that lubricants are not intended to be used for purposes of heating fuel or motor fuel, they should remain outside of the scope of the EMCS. • The level of fraud is difficult to determine and can be circumvented by the parties involved, even if lubricant oils would be included within EMCS; [1] CN code 2710 19 91: Metal-working compounds, mould-release oils, anti-corrosion oils. CN code 2710 19 99: Other lubricating oils and other oils. [2] Light lubricants are defined as products with a viscosity of < 4.5 mm2 by 40 C but would still include many metal working oils, process oils, corrosion protective oils etc.

Both UEIL and UKLA have been active lobbying with Governments to intercede at EU level to ensure that there is a vote blocking the proposal, as it requires a unanimous agreement to go through. A decision should be made on this matter within the six months.


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8. Date and Venue of the Next MeetingThe next meeting will be held on Thursday 15th January 2015 at the Heritage Motor Museum,Gaydon.

UEIL Public Affairs Update

Board meeting 14 May 2014

UEIL Public Affairs Update May 2014

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Content

UEIL Public Affairs Update May 2014 2

Activities from January 2014 to May 2014

Latest policy developments

• Automotive sector

• Chemicals

• Competition

• Trade

• Environment

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Activities January – May 2014


Intelligence gathering & monitoring

• Issue tracking: REACH, taxation, competition, automotive

• Quarterly newsletter

Outreach

• On-Going contact with Mr Sanchez Galindo, Commission official in charge of the Regulation on Vehicle ConstructionRequirement (RVCR)

• Contact with FIGIEFA on the RVCR

• On-Going contact with Mrs Mitova, Principal Administrator incharge of commercial relations with Turkey in DG TRADE

Advocacy • Taxation campaign

Support • Lube Magazine

• Addressing ad-hoc requests from members

• Meeting with Barbara Bonvissuto, Deputy head of unit of the Automotive unit in DG ENTR (30 January)

• Meetings with FIGIEFA and CECRA (10 February)

• Conference call with Ricardo (18 March)

• On-Going contact with Mrs Mitova, Principal Administrator incharge of commercial relations with Turkey in DG TRADE

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Automotive sector

CARS 2020 Expert Group

• The last meeting of the group took place on 26 March.

• Final report of the CARS 2020 discussion to be published on…

Reducing CO2 emissions from new light commercial vehicles and cars

• Compromise agreement reached and adopted by the European institutions onthe 2020 CO2 emission targets for vans and cars.

• New texts have been published in the Official Journal on 26 February for vansand 5 April for cars

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Chemicals

REACH

• Commission is organising a workshop on 16 September on the safe use of chemicalsby SMEs, which aims to address the challenges faced by companies and in particularSMEs to comply with the new rules for classification, labelling, packaging of mixturesintroduced by the CLP regulation (Classification, Labelling and Packaging ofHazardous Chemicals)

• ECHA’s Member State Committee (MSC) is reviewing the first results of an updatedapproach to prioritise candidate list substances for inclusion in REACH’s Annex XIV.

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Competition

Access to technical information

• The European Commission (Directorate General for Enterprise and Industry) launched a project aiming to undertake a review on the operation of the system of access to vehicle repair and maintenance information (cars and vans) included in the Regulation n°715/2007.

• RICARDO-AEA UK has been designated to conduct this study. UEIL participated in this study which should be finalised and sent to the Commission by end of June.

• On that basis, the Commission will decide whether further actions are needed or not to improve the current situation.

UTP

• Commission to publish legislative or non-legislative paper on UTP further to the public consultation conducted last year.

• Important that the automotive sector is included in this paper. Media campaign with CECRA?

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Trade

• Turkish Market Regulation on Supply of Non-Fuel Petroleum Products: Commission asked for sound and concrete proposal if we want to increase the weight threshold from 250 kg to 1100 kg in order to include the IBC (Intermediate Bulk Containers).

• Hungarian tax law: UEIL contacted the European Commission (DG TAXUD) to share its concerns as regards the new Hungarian tax law. However, Commission replied that Hungary is not precluded from adopting rules seeking the prevention of fraudulent activities linked to lubricants, including the introduction of excise licence for the trade in such products as the measures they introduced are not disproportionate compared with what applies in some other Member States.


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Environment

Self-assessment questionnaire to assess the sustainability performance of suppliers in the automotive sector

• Questionnaire launched by a collaboration amongst ten automotive manufacturers in the

European Automotive Working Group on Supply Chain Sustainability.

• This joint questionnaire should serve as a first self-assessment of supplier performance on CSR/

Sustainability topics in areas such as social and environmental sustainability, business conduct

and compliance, and supplier management. The tool is based on the Automotive Industry Guiding

Principles to Enhance Sustainability Performance in the Supply Chain.


http://www.csreurope.org/european-automotive-working-group-supply-chain-sustainability

http://www.csreurope.org/european-automotive-working-group-supply-chain-sustainability

http://www.csreurope.org/sites/default/files/Guiding Principles.pdf

http://www.csreurope.org/sites/default/files/Guiding Principles.pdf

Sukhy Ubhi Lubrizol Deborah Grigg UKLA Caroline …...2014/06/27 · Automotive unit in DG ENTR (30 January) • Meetings with FIGIEFA and CECRA (10 February) • Conference call

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