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Association Technique de l'Industrie Européenne des Lubrifiants

ATIEL

ATIEL represents manufacturers and marketers in the European lubricants industry.

Lobbying Activity

Response to Ecodesign for Sustainable Products - Product priorities

11 May 2023

ATIEL is the Technical Association of the European Lubricants Industry. ATIEL welcomes the opportunity to comment on the proposed EU Ecodesign for Sustainable Products Regulation (ESPR). We would like to take this opportunity to describe to the Commission the unique aspects of lubricants that need to be taken into consideration in any legislative approach. This position paper supports our responses and comments in the questionnaire. Key Policy considerations We support the Commissions ambition to make products on the EU market more sustainable, however we believe that lubricants should be considered low priority for inclusion under the proposed regulations due to their inherent capability to increase energy efficiency of equipment and machinery. Lubricants also have a relatively small volume (4.3 million tonnes in 2017) and market share (30 billion EUR in 2021) in Europe. Moreover, this is split between various segments having very different requirements from engine oils and driveline fluids to hydraulic oils and greases to chain saw oils. Further to the consideration that lubricants should be a low priority under ESPR it should also not be included in the ESPR first working plan. This is because lubricants are designed and used to improve energy performance in equipment and machinery. Although ATIEL believes that lubricants should not be prioritized, we take the opportunity to contribute to the discussion considering the important role lubricants play in society through recommending some points that could be improved in the JRC report. ATIEL would like the Commission to consider lubricants and their use and applications under the ESPR scope, where other stakeholders are involved. If we consider only the production of the lubricant itself, it may be too simplistic and have an adverse effect on the footprint of the whole life cycle. Potential savings from lubricant footprint (manufacturing) are magnitudes lower than the handprint (use phase). Therefore, optimisation of the footprint may affect the handprint in an unpredictable way with potential negative impacts on sustainability
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

30 Mar 2023

The purpose of this document is to provide support for the use of multi-lingual fold-out labels on packages improving current hazard communication and labelling provisions. The objective of the Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 (CLP) is to ensure a high level of protection of human health and the environment as well as the free movement of substances, and mixtures and articles in scope of the regulation. Suppliers must therefore label and package substances and mixtures placed on the market in accordance with CLP. Article 31 in Title III of CLP outlines the general rules for the application of labels referring to the label elements required in Article 17 including the language requirements. Article 17(2) specifies that the label shall be written in the official language(s) of the Member State(s) where the substance or mixture is placed on the market, unless the Member State(s) concerned provide(s) otherwise. Suppliers may use more languages on their labels than those required by the Member States, provided that the same details appear in all languages used. With regards to the use of multi-layer fold-out labels, Article 29 provides an exemption to Article 31 relevant for small packaging allowing the use of multi-layer fold-out or tie-on labels (referencing Annex 1, section 1.5). This Article and Annex section includes restrictions which need to be considered where this exemption is used. It is interpreted that the use of multi-layer fold-out labels or tie-on tags is only allowed if it is impossible to meet the general rules for the application of a label in the language requirements for one specific Member State where the product is placed on the market. Once this condition to use a multi-layer label is met, only then can more languages be accommodated onto the label maintaining reasonableness.
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Response to Amending Regulation (EC) No 1272/2008 relating to emergency health response

16 Aug 2019

ATIEL supports the postponement of the implementation deadline for consumer products until 1st January 2021. ATIEL further supports: • The harmonisation with the international standards. ATIEL wishes to make addtional comments in relation to the below mentioned points (numbers refer to paragraphs in the Annex to the draft regulation, Ares(2019)4744568/1): • 1 (f): ATIEL welcomes an explicit authorization to place the UFI on the packaging, however, ATIEL suggests adding the below sentence as originally proposed in October 2018: “The submitter shall print or affix the UFI on the label or – where relevant, inner - packaging of a hazardous mixture. ”If not specifically mentioned in the text, this means in practice that the UFI shall be placed on all layers of packaging. This requirement adds disproportionate administrative, legal and economic costs on the economic operators. • 1 (g): ATIEL supports the amendment enabling the UFI to be mentioned in the SDS for any mixture supplied for use at an industrial sit or any mixtures for consumer or professional use. ATIEL suggests the following text to clarify any potential interpretation in the implementation and enforcement. “5.3 By way of derogation from the first subparagraph of Section 5.2, in the case of mixtures supplied for use at industrial sites or for mixtures supplied for consumers or professional use, the UFI may alternatively be indicated in the Safety Data Sheet.” • 2 (i): The proposed change to Part B, 3.2.2 on the submission of information relating to mixtures in mixtures (MIMs) is of concern, mainly: i. A supply chain communication issue. The proposed change indicates that the operator shall disclose the names of the Member States where their suppliers have placed each MIM. This could go in detriment of the supplier confidential business interests. A solution for this issue is that the suppliers notify MIMs in all Member States even though not placed in the market in that Member State. This solution is not optimal as the integrity of statistical analysis for identification of risk management needs could be questioned as well as costs and burden on MIM suppliers. ii. The generation of distinct submissions in countries where the MIM UFI can be used and in those where it cannot. If a mixture contains more than one MIM, each with distinct market placements, this could quickly multiply into a series of distinct submissions for the same mixture. The latter will consist in fluctuating combinations of MIM information. The submission becomes complex for formulators and further denies the benefits of the central submission portal. ATIEL understands that the Commission intends to seek technical solutions to these problems in the IT tools. ATIEL still believes that the legal text should be proposed after the technical solutions are in place making the legal revision workable. ATIEL therefore suggests that the proposed amendment to 3.2.2 be deleted until technical workable solutions are in place. Note-wood: Study on workability issues concerning the implementation of Annex VIII of Regulation (EC) No 1272/2008 on harmonised information relating to emergency health response and preventative measures Base Oil Interchangeability: Furthermore, ATIEL wishes to highlight the important challenge that remains regarding the Commission’s Workability Study on Annex VIII concerning Base Oil Interchangeability. Indeed, Base Oils, where several very similar substances (same chemical family and classification) can be present interchangeably, the substances could be declared within a single submission. This would require including all interchangeable components in the notification that can possibly be present at 0% concentration accompanied by a commentary within the notification. This would allow notifying components that are not present in each and single batch of a mixture. My email is christine.marlet@atiel.eu
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