Revision of the EEL Proposed changes and their chance of acceptance Hildo Krop Benelux Lubricant Seminar, September 14 2017
Overview Current framework of the EEL Short history of its development Proposed changes Possible impact on current and new licenced products
Which ((bio)lubricant) ecolabel scheme in 2002? France Austria Spain Slovakia Poland Hungary Ukraine Nordic countries Biolubricant labels in Europe Germany Sweden Japan North America Taiwan Australia New Zealand Thailand South Korea
4 Which (bio)lubricant ecolabel scheme Sept 2017? EU: Some schemes aligned (eg AU, FR) Some schemes disappeared (e.g. Swann) EU (317) Sweden (142) Germany (89) USA (0) Taiwan (1) Japan (?) Thailand(?) South Korea (?) Hongkong (?) All Ecolabels focus on loss/lost lubricants EU ecolabels: Substance based more successful Asian + N. Am: Product based little attention
Environmental impact of lubricants ~ 10% of hydraulic fluids and ~ 50% of grease direct into the environment during use (VDMA old data) 100k 200k ton of Sterntube grease worldwide in (sea)water (2010) 53 000 ton/year 2-stroke oils worldwide (GESAMP 2007) ~ 40% of engine oils not accounted for (lost and/or burnt) in USA Bioschmierstoff-Kongress 2014 + JRC EEL Tech Rep: staggering 50% of the lubricants ends up in the Environment Environmental impact: four main flows of impact. 1. Direct Loss 2. Indirect Loss (burnt) 3. Waste and burnt 4. Waste and Recycling EEL focuses on direct loss + renewability
Core of the EEL: Focus on direct loss Mineralization Bio-Lubricant CO 2 Cradle to Cradle (Circular) Closing the Carbon Cycle within a limited time span Renewability 1. Biodegradation 2. Renewability 3. Ecotoxicity CLP section 4.1.3.3.2. The long-term hazard classification (H41x) of mixtures requires additional information on degradability and in certain cases bioaccumulation. Degradability and bioaccumulation tests for mixtures are not used as they are usually difficult to interpret, and such tests may be meaningful only for single substances. EEL criteria are substance based
Market section biolubricants 35 30 1.03 M ton Bottger, MEO Carbon Solutions Bioschmierstoff-Kongress 2014 25 3% of Lub market 20 15 10 EEL relevant 30% of biolub market CEN 16807 relevant 61% of biolub market 18.150 ton 29.810 ton 5 9.100 ton 0 Lub market Germany > 50% renewable >25% renewable ultimately biodegradable For 15 years around 3% of the market is biolubricant Total lubricant market in EU is declining despite some market reports EEL is applicable to only 16% of the total lubricant market
Success of the EEL 400 300 200 100 No of EEL Licences & products (2005-2016) 0 2005 2007 2009 2011 2013 2015 Licences Products 400 300 200 100 0 No of licences and products (2017) EEL, RAL-178, SS (hydr + grease) EEL RAL SS Licences Products
Drivers of Success of the EEL Set of Clear, Unambiguous, Science-based, Standardized and Affordable criteria Compatibility with other important schemes Regional (EU) approach Company involvement from the start in 2004 Development of a positive list (LuSC-list) (Henkel CIBA Rheinchemie) Growth sector in declining EU lubricant market Inclusion in several policy instruments (svgp-usa) Free publicity in magazines LubesnGreases and Lube Magazine
Success of the LuSC-list LUSC-LIST ENTRIES 2011-2015 2011 2015 SUBSTANCES 73 74 BASE FLUIDS 8 82 ADDITIVES 50 96 06-2016 Base fluids: 102 Additives: 100 http://ec.europa.eu/environment/ecolabel/documents/lusclist.pdf
Direct &indirect policy incentives linked to the EEL Obligation to use In environmentally sensitive areas (DE, AT, FR, SW, SE) In certain vessel types (PT, svgp-usa) (US-EAL if bears Ecolabel, SS or Blue Angel logo) Biolubricants in pilot projects Ms Audri (inland marine container vessel), The Netherlands Within Environmental tax incentives NL VAMIL GE Market introduction program (ended) FR + BE (Env Oil pollution tax: exempted if complies with (parts of) EEL) Canal des Deux Mers, Toulouse, France Adapted in other Environmental Schemes EU GPP schemes Greenaward (shipping scheme) (OSPAR not succeeded yet)
Current 2 nd revision (procedure) Each criteria document revised 4/5 years. Changed to 6-7 yrs Organized by JRC-IPTS (Sevilla with technical input from LEITAT (Barcelona) In general 2 3 Ad-Hoc Working Group (AHWG). o 1 st Sevilla February 2016 o 2 nd Technical report 11 15 September 2017 o 2 nd webinars: October 2017
Critreria overview Scope of the EEL 1. Limited substances 2. Excluded substances 3. Aquatic toxicity 4. Biodegradability and bioaccumulative potential 5. Renewability 6. Minimum technical performance 7. Information appearing on the EU Ecolabel Scope of the EEL 1. Excluded or limited substances 2. Aquatic toxicity 3. Biodegradability and bioaccumulative potential 4. Raw materials 5. Origin and traceability of renewable raw materials 6. (Packaging) 7. Minimum technical performance 8. Consumer information regarding use and disposal 9. Information appearing on the EU Ecolabel
SCOPE of the EEL Cat 1: Hydraulic fluids + tractor transmission olis Cat 2: Greases Incl Stern-tube greases Cat 3: Chainsaw oils, Concrete release agents, Wire rope lubs, Stern tube oils, Other total loss Cat 4: 2-T oils Cat 5: Industrial + marine Gear oils. Accidental Loss Lubricants (ALL): hydraulic systems, metalworking fluids, closed gear oils and accidental loss greases. Partial Loss Lubricants (PLL): 2-stroke oils, temporary protection against corrosion and partial loss greases. Total Loss Lubricants (TLL): chainsaw oils, wire rope lubricants, concrete release agents, open gear oils, stern tube oils, total loss greases and other total loss lubricants. Reference to ISO 6743 lubricant families. Classification of greases seems unclear Includes MWF but excludes 4-T oils MWF are diluted. How to apply criteria?
Substances REACH/CLP substance definition Stated substances REACH/CLP substance definition Stating Ingoing substance includes by-products and impurities nano in brackets Function + form of each substance No proof of by-products and impurities requested No additional criteria for substance in the nanoform or function/form of each substance
Limited and excluded hazardous substances (I) Final lubricant not classifed for health and environment Limited till 0.010%: H340, H350, H360, (SVHC) Candidate list, OSPAR-list, FWD priority list Organic halogens + nitrite Metals+metallic except Na, K, Ca, Mg and thickeners Li,Al Final lubricant not classified as acutely toxic, STOT, sensitising, CMR, Hazardous to the Aquatic environment Nothing including impurities and by-products (SVHC) Candidate list Till 0.010%: H340, H350, H360, H341, H351, H361, H362, H300, H310, H330, H301, H311, H331, H370, H372, H400, H410, H420, EUH029, EUH031, EUH032, EUH066, EUH070 FWD Priority list Organic Halogen and nitrite compounds Metals + metallic except Na, K, Ca, Mg + for thickeners Li, Al. Half concentration that would trigger classification of the final product. H304 (5%), H371 (5%), H373 (5%), H335 (10%), H336 (10%), H317 (1,1B=0.5%; 1A = 0.05%), H334 (1,1B=0.5%; 1A = 0.05%), H314 (0.5%), H315 (5%), H318 Krop (0.5%), - Consult H319 (5%).
Limited and excluded hazardous substances (II) Proposed limits of hazardous substances automatically rule out classified products except H302 and H332 Against general feeling of stakeholders at 1st AHWG I expect a high impact on currently licenced products Most likely very challenging for MWF? Problems with differences in classifications not addressed. Probably copy from Blue Angel but half-% much stricter
Aquatic toxicity Option on product + main components Option on stated substances above 0.10% Option on product + main components Option on stated substances above 0.10% Not toxic 1 2 3 4 5 Not limited Harmful <20% <25% <5% <25% <20% Toxic <5% <1% <0.5% <1% <5% Very toxic <0.1/M <0.1/M <0.1/M <0.1/M <0.1/M Data on 2 most sensitive trophic levels (Acute = algae and daphnia) Exemption of testing MM = 800 g/mol Not toxic ALL PLL TLL Not limited Harmful <10% <20% <2% Toxic <2.5% <0.6% <0.4% Very toxic <0.1/M <0.1/M <0.1/M Data on 3(?) most sensitive trophic levels Exemption of testing MM = 700 g/mol QSARs Stricter allowed fractions but limited impact on current licences Fish is most sensitive trophic level for acute tox of surfactants.
Biodegradation Biodegradation Above 0.10% 1 2 3 4 5 Ultimately >90 >75 >90 >75 >90 Inherently <5% <5% <20% <5% <25% Non+Non-Bioacc <5% <5% <10% <5% Non+Bioacc <0.1% <0.1% <0.1% <0.1% <0.1% Ultimately: OECD 301, 306, 310 + BOD/COD > 0.5 Inherently: 302C + <60% - > 20% 301, 306, 310 Read-across Biodegradation Above 0.10% ALL PLL TLL Readily >90 >75 >95 Inherently <10% <25% <5% Non+Non-Bioacc <5% <20% <5% Non+Bioacc <0.1 <0.1 <0.1 Readily: OECD 301, 306, 310 + BOD/COD > 0.5 Inherently: 302C + <60% - > 20% 301, 306, 310 Read-across Little impact IF SUBSTANCE IS READILY OR INHERENTLY BIODEGRADABLE
BIOACCUMULATION Not bioaccumulative Log K ow < 3 and > 7 BCF < 100 L/kg Not bioaccumulative Log K ow < 3 and > 10 BCF < 100 L/kg No QSARs for non-organic, surfactants, (some) organo-metals No QSARs for non-organic, surfactants, (some) organo-metals High impact on additive packages. 50% on LuSC-list do not qualify or fraction too low to be effective?
Renewability Based on fractions of C-atoms Fractions allowed: 1 2 3 4 5 >50% >45% >70% >50% >50% Raw Materials The lubricant product shall have a minimum content that shall be: a) carbon derived from renewable raw materials; or b) synthetic esters, polyalphaolefins (PAOs) or polyalkylene glycols (PAGs); or c) a combination of a) and b) Fractions allowed ALL PLL TLL >60% >65% >70% Based on ASTM D6866 test Carbon cycle not closed anymore for lost lubricants (50%) Not a biolubricant anymore in the EU Extra test required
Origin and traceability Stating type, source and origin of renewable material Renewable material must be certified by third party based on segregation or mass balance method (No demands for PAO+PAGs) Expect that > 95% of the base fluids on the LuSC-list cannot comply. For most renewable material certification scheme is absent
Minimum technical performance Chainsaw oils Based on RAL-UZ 178 Wire rope lubricants, stern At least one relevant OEM approval tube lubricants and other total loss lubricants Concrete release agents At least one relevant OEM approval Gear lubricants Enclosed gear oils. DIN 51517 section (I, II or III) Open gears: At least one relevant OEM approval 2-stroke oils Hydraulic systems Metalworking fluids Temporary protection against corrosion Greases 2-stroke marine: NMMA TC-W3 2-stroke terrestrial: ISO 13738:2011 (EGD) ISO 15380 (Tables 2 to 5) Fire resistant hydraulic fluids: ISO 12922 or Factory Mutual Approval At least one relevant OEM approval ISO/TS 12928:1999 Greases for temporary protection against corrosion: ISO/TS 12928:1999 Greases for closed gear: DIN 51826 All other greases: Fit for purpose
Final remarks on modfications Extension of scope: MWF cannot comply Hazardous substances: High impact on Licences+LuSC Aquatic toxicity: Little impact (more data requirement?) Biodegradation: Little impact if biodegradable Bioaccumulation: High impact on Licences+LuSC Renewability: Not required. No cradle to cradle anymore Traceability: High impact on renewable base fluids Still some issues to be discussed on 9 and 10 October!
Many thanks for your invitation