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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 - PowerPoint PPT Presentation
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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