The lubricants standard was adopted in 2001 and by law is supposed to be revisited every few years. The current version is due to expire this year, so a revision was undertaken, led by the Product Bureau of the European Commissions Joint Research Centre. The JRC began the process in February 2017 by hosting a working group meeting attended by some 50 stakeholders, including representatives of lubricant, additive and base stock suppliers.

A follow-up teleconference was held in October, and then the JRC issued draft revisions in January this year. Following a public comment period, a vote for approval of the revisions was scheduled for late June, after this issue went to press.

Case by Case

There are multiple ways that substances can harm the environment, so the Ecolabel standard for lubricants assesses products on several criteria. Obviously, it is important that they not poison plants or animals, so toxicity is one criterion. Some chemicals are not immediately poisonous but can cause serious harm long term if they tend to accumulate in organisms, so bioaccumulation is another.

Regardless of a substances effect, it is better that it not remain in the environment, so biodegradability is also assessed. A final criterion is renewable content, which does not directly speak to the impact of a substance entering the environment but does reflect on the environmental impact of making it.

At the February 2017 working group meeting, the JRC presented draft revisions that would have sharply ratcheted requirements for the lubricants standard, according to Paula Vettel, of Novvi,
a United States-based developer and supplier of base stocks derived from sugar. She attended that meeting and reported about the lubricants Ecolabel revisions in May at the Society of Tribologists and Lubrication Engineers annual meeting in Minneapolis.

One JRC proposal would have required all lubricants bearing the Ecolabel to contain only ingredients not requiring hazard statements under EU chemicals regulations. This would have eliminated almost all lubricant additives currently in use, Vettel said. Another would have required at least 95 percent of components by volume to be more than 60 percent biodegradable over 28-day periods. This, said Vettel, would have precluded the use of practically all grease thickeners and additives in use today.

A third proposal would have required more than 95 percent of components to biodegrade by 60 percent within 10 days of reaching the 10 percent threshold. Vettel said this would have ruled out the use of high-performance esters and hydrocarbons.

According to Vettel, industry pushed back hard on these and other proposals, complaining they would make it impractical to formulate compliant products, interfering with the goal of increasing the number of Ecolabel lubes.

As a formulator, I looked at this and was horrified, she said. To their credit, the JRC listened, and it was a full-day assault on everything that they had [proposed].

Breaking it Down

The latest draft eases back from those initial proposals but still raises requirements beyond the existing standard, Vettel and JRC representatives said. Comparisons arent simple because the current draft reorganizes into three categories: total loss lubricants such as chainsaw oils, stern tube oils and lubes used in open gears; partial loss lubricants, such as two-stroke oils, which are in use long enough that they need to protect against corrosion; and accidental loss lubricants such as hydraulic fluids and closed gear oils, which are often leaked or spilled.

Limits on the use of hazardous substances were loosened from the original proposal to allow the use of lubricant additives. The current draft would not allow products to contain more than 0.01 percent by weight of substances classified as causing severe damage or harm, or 0.5 percent by weight of substances that cause allergic reactions or that are very toxic to aquatic life.

The current draft proposes aquatic toxicity limits for finished lubricants as well as their components. Total and partial loss lubes must not cause acute aquatic toxicity at concentrations of 1,000 milligrams per liter or less and must not cause chronic aquatic toxicity at concentrations of 100 mg/l or less, as indicated by accepted methods that measure effects on algae, daphnia crustaceans or fish. For accidental loss lubes the limits are 100 mg/l for acute toxicity and 10 mg/l for chronic toxicity.

Requirements for biodegradability are strictest for total loss lubricants, which under the current draft must consist at least 95 percent of substances that are readily aerobically biodegradable and contain no more than 5 percent of substances that are inherently biodegradable, or non-biodegradable and non-accumulative. Partial loss lubes may contain up to 10 percent of substances that are inherently biodegradable and up to 5 percent of those that do not degrade or accumulate. There is a cap of 0.1 percent for all categories for substances that accumulate but do not degrade.

In terms of limiting hazardous substances, aquatic toxicity, bioaccumulation and biodegradability of products, the ambition level has been tightened, said Barbara Piotrowska, a press officer for the JRC. She noted that the EC wants to increase market penetration of Ecolabel lubes. She said officials at the center believe the proposed update achieves a balance by not setting the bar too high for suppliers to meet. The center surveyed 143 products in 11 countries to see if they would meet the proposed standard.

Forty percent of the existing licenses would be able to comply with the revised thresholds, she said.

The center noted that technological advancements are in some ways easing the challenge of formulating environmentally benign lubricants. Industry now supplies base stocks from a variety of sources that are at least relatively non-toxic, biodegradable and non-accumulative. As a result, the draft revisions focus on those criteria and do away with preferences for base stocks derived from vegetable oils.

With this proposed change, manufacturers have more alternatives to choose from – not only bio-based raw materials – while still complying with the new, more restrictive thresholds that have been proposed, Piotrowska said.

The proposed rules set no minimum requirement for renewable material content except that products promoted as bio must use renewable materials for at least 25 percent of their carbon content.

Lingering Issues

Some new concerns are addressed by the draft revision. Ecolabel applicants with products containing palm oil and palm kernel oil would need to show that at least part of that content comes from suppliers who minimize impacts on soil, biodiversity and organic carbon stocks – a requirement meant to address concerns about palm supplier practices in Southeast Asia. There are also proposals that plastic containers be made of at least 25 percent recycled plastic and that lubricants intended for sale to private consumers have dispenser closure systems designed to avoid spills.

All in all, the JRC hopes the revised standard will boost protection for the environment while still allowing industry to supply more lubricants that qualify for the Ecolabel.