Anyone who has an interest in lubricant additives in Europe during the past decade will have been drawn into a discussion about the Registration, Evaluation, Authorization and Restriction of Chemicals. REACH has been the European Unions flagship chemical health and safety legislation over the past 20 years, a period covering the drafting and then phased introduction of registration deadlines based on volumes.

The likelihood of that conversation getting heated has increased in the past few years, as the legislation has advanced and suppliers have had to think about registering their smaller-volume chemicals, with all the associated, often crippling, costs.

Some were highly concerned that substances would be unavailable in Europe but may be still available elsewhere. This could mean that manufacturers using these materials would move location or switch suppliers, either leaving European plants at a disadvantage compared with manufacturers outside of the continent or exporting jobs from existing European sites. (Also see Out of REACH in Mays edition of LubesnGreases EMEA.)

The counterargument is that REACH was intended to remove harmful substances from the marketplace and therefore the environment, and it appears to be achieving at least that part of its remit. Legislators are happy while many in the industry are not. But is it REACHs fault?

Substantial Loss

There is no doubt that some substances have been lost to all industries, not just lubricants. In an email to LubesnGreases, ATIEL – the trade body representing the technical side of the European lubricants business – said, Although ATIEL members report little disruption so far of supply from upstream due to REACH, the number of substances in Europe has decreased and the number of new registrations since May 2018 has dropped.

ATIEL then expressed concerns for the future. The costs to register and evaluate all chemicals have very clearly diverted resources away from investigating new chemistries, it said. Consequently, these new chemistries might not be brought to market or be available in Europe.

However, ascribing all substance withdrawals to REACH is probably incorrect, according to Stephan Baumgrtel, who chairs the health and safety committee of the Union of the European Lubricants Industry, another trade body that represents the interests of Europes lubricants manufacturers.

It is difficult to distinguish between withdrawals because of REACH, because of marketing strategy [or because of] changing markets, said Baumgrtel. There is also other legislation that may affect the market. We saw a reduction of biocides available for metalworking fluids … because of the BPR, he added.

The BPR, or Biocidal Products Regulation, brings with it the consequence that many metalworking fluids based on well-established biocides, such as formaldehyde, would have to be labelled as carcinogens if the biocide is present at a useful concentration.

Kevin Duncan, chair of the stewardship group of the United Kingdom Lubricants Association, agrees with Baumgrtel and echoes the reported comments of Ursula von Stettin of BASF (also previously reported in these pages) that the costs of REACH are part of an overall business case for the introduction or retention of products.

Opportunity for Some

While some lube blenders are bemoaning the loss of sulfurized esters and sulfurized olefins, which are often malodorous and have lethal hydrogen sulfide gas as either a byproduct of manufacture or a degradation product, two new and innovative anti-wear/extreme pressure additives have become available on the market.

Germany-based Gelitas gelatin-derived extreme pressure/anti-wear additives are exempt from REACH registration, as they are considered to be food products. This is exactly the type of repurposing of safe chemicals that the EU intended when REACH was first devised.

Matthias Reihmann, head of global product management photo and technical for Gelita, explained how the companys Novotech products comply with REACH. The main component [of each product], gelatin hydrolysate, is a natural polymer and exempt from REACH. The solvent is water and not an organic solvent, he said.

Gelita uses two stabilizers – citric acid and potassium sorbate – which are both REACH-registered food additives.

New Jersey-based Nanotech Industrial Solutions inorganic fullerene-like tungsten disulfide dispersions are also fully registered. CEO George Diloyan echoed the view of many in the business: REACH registration is vital in order to do business in Europe.

Nanotech Industrial Solutions registration means that lubricant manufacturers and blenders can get full benefits of these innovative solids in various high-performance formulations of greases, oils and metalworking fluids.

Similarly, while some established esters may not be registered, other relatively new and innovative base fluids, such as Biosynthetic Technologies estolides, are available and fully registered under REACH. These products are biobased from renewable raw materials, biodegradable and nontoxic. Dow Chemicals oil-soluble polyalkylene glycols, introduced in the last decade, are polymers and are REACH exempt.

In the Annex

While the larger additive companies approached by LubesnGreases declined to comment on the record, the general market opinion is that they have all been doing admirable swan impressions by appearing serene above the water while working hard below the surface to make progress and ensure continuity of supply. This will undoubtedly have resulted in some innovation in formulating.

John Neale of United Kingdom-based engineering lubricant company John Neale Ltd. sees REACH and BPR as opportunities and not threats to doing business.

We have made packages of amines selected from non-metalworking areas of application, neutralizing them with either boric acid or carboxylic acids, he said. The resulting salts are exempt from REACH, as they are ionic mixtures. The components are registered by the supplier, and the salt is in water and is therefore exempt under Annex V, which lists 13 substances categories for which registration is unnecessary.

Annex V exemption has allowed us to continue developing novel packages for water-mix metalworking fluids, Neale explained.

Neale and his team have had other successes with REACH-registered chemicals not commonly used in lubricants.

We have introduced a new aluminum stain inhibitor [inhibitor AL-SE] where we assessed a range of additives used in the coating industry. The additive gives outstanding results in water-mix metalworking fluids, said Neale.

Taking a wider perspective, he added, The reduction in available additives makes you look more broadly at what is available in other markets.

Neale has also developed formulations based on polymeric ingredients, which, like the salts above, are exempt from REACH. Examples include a polymeric ester and an emulsifying phosphate ester. Both are new ingredients in metalworking fluids and both have performance advantages over current technologies.

Feeling the Impact

The past 10 to 15 years have seen hazardous chemical substances withdrawn from the market in Europe. To some in the lubes industry, this is seen as a near disaster, reducing the ability of European companies to compete outside the bloc. Legislators and environmental groups see this as a triumph for consumer health and safety.

Contrary to what is repeatedly claimed by industry lobbies, the [REACH Refit] report clearly concludes that REACH did not create [an] unnecessary burden. This sends a strong message to the market: It is time to invest in substituting dangerous chemicals with safer solutions, said Alice Bernard, a lawyer for the international environmental law charity ClientEarth. REACH Refit was a European Union review of REACHs fitness for purpose.

The impact of lost substances has probably been felt more in the smaller volume industries, such as metalworking fluids and greases, where most formulation is performed by the lube marketer. Larger volume players have been less affected. The larger additive package suppliers either based their packages on large volume chemicals, where the registration costs could be recovered easily, or were able to formulate away from potentially vulnerable substances as market specifications have changed.

To counter the withdrawals, there has been an ongoing process of new introductions, some repurposing of existing chemicals and reformulation of existing products, sometimes even with improved performance.

With similar REACH-like systems due or soon to be implemented in Turkey, South Korea, China and the United States, there are several players who now see the tribulations of the past decade turning into longer-term advantages for companies who have trodden the REACH path. Time will tell whether this optimism is well-founded or whether the regulatory burden will restrict the ability of European lubes manufacturers to meet the challenges of rapidly changing markets.

Trevor Gauntlett has more than 25 years experience in blue chip chemicals and oil companies, including 18 years as the technical expert on Shells Lubricants Additives procurement team. He can be contacted at trevor@gauntlettconsulting.co.uk