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 II 2.Organic halogen and nitrite compounds 3.Metal compounds except Na, K, Ca, Mg and Li and Al for thickening systems 4.OSPAR listed 5.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 – 3 ISO elastomers tested on the PIB Other slight changes

Overview of the criteria (Table 1) Category 1Category 2Category 3Category 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 of the lubricant at the time of application (Criterion 1) Category 1Category 2Category 3Category 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% (Criterion 2) Aquatic toxicityCumulative mass percentages (% w/w) of substances present in (Criterion 3.2 only)Category 1Category 2Category 3Category 4 Not toxic (D) Acute toxicity > 100 mg/L Not limited or NOEC > 10 mg/L Harmful (E) 10 mg/L < Acute toxicity  100 mg/L  20  25  5  25 or 1 mg/L < NOEC  10 mg/L Toxic (F) 1 mg/L < Acute toxicity  10 mg/L  5  1  0.5  1 or 0.1 mg/L < NOEC  1 mg/L Very toxic (G) Acute toxicity  1 mg/L  0.1/M (*) or NOEC  0.1 mg/L

LuSC-list Formulation/application aid Non-limitative Two parts  Substances  Brands

Layout LuSC-list substances Substance CAS no EINECS no Biodegradability Aquatic toxicity Remarks Fatty acids C 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 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 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 Inherently aerobically (B) Harmful (E)Assessed by the Dutch CB Dilithium azelate, pure Not biodegradable and not bioaccumulative (C) Toxic (F)Assessed by the Dutch CB Dilithium sebacate, pure Not biodegradable and not bioaccumulative (C) Harmful (E)Assessed by the Dutch CB

Lay-out LuSC-list brands Proposed maximum treat rate % Based on 100% treat rate Brand name Cat 1Cat 2Cat 3Cat 4 EEL Biodegra- dation EEL Aquatic Toxocity Renew- ability RemarksAssessed by A/B/C/X/-D/E/F/G(M * ) Base fluids Uniflex 939LAN Not limited by biodegradation and aquatic toxicity 100%A100%D89.6%Dutch CB Synative ES G20 AZ Not limited by biodegradation and aquatic toxicity 100%A100%D81.6% Dutch CB Thickeners Additives Irgalube® 3531% 100% C100% E0%Limited by R43Dutch CB Irgacor® L 120.2% --0% A mixture of different substances with the major substance represented at a maximum of 50% w/w. Dutch CB Irganox® L 570.5% -100% E0% A mixture of different substances with the major substance represented at a maximum of 20% w/w. Dutch CB Irgalube® % 52% C52% F0%Dutch CB Additin RC %2.5%1.25%2.5%100% C 60% E 40% F 95%Dutch CB Additin RC36401% 0.5%1%100% C100% F0% Max treat rate depends on R40. Dutch CB Additin RC % --0% A mixture of different substances with the major substance represented at a maximum of 28% w/w. Dutch CB Polymer systems