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The next revision of the EU Ecolabel seeks to expand lubricant coverage


The second revision of the European Ecolabel (1st revision of 2005/360/EC was 2011/381/EC) is underway, with the 1st Ad Hoc Working Group Meeting for the revision of the EU (European Union) Ecolabel for the products group lubricants scheduled for 9 February in Seville, Spain.

Based on the licenses registered in the Ecolabel, it is difficult to estimate the real market impact of the scheme; there is no information on the real tonnage of the EU Ecolabel lubricant products and their share of the general market in the EU. However, the estimates in the EU are around 300,000 metric tonnes (MT) per annum.

Currently, only 16% of the lubricants market is included under the scope of the EU Ecolabel, and there is a recommendation to expand this to 56%.

The EU Ecolabel is part of a broader EU Action Plan on Sustainable Consumption and Production and Sustainable Industrial Policy adopted by the European Commission on 16 July 2008. The EU Ecolabel criteria apply to more than 30 non-food and non-medical product groups that are reviewed every three to five years.

The EU Ecolabel promotes products with a reduced environmental impact along the life cycle and is awarded only to the best (environmental) performing products in the market.

According to a report by the Joint Research Centre entitled “Revision of European Ecolabel Criteria for Lubricants: Preliminary Report,” published in December 2016, the current definition of lubricant, which is “a preparation consisting of base fluids and additives,” is too broad.

The report does not imply a policy position of the European Commission, however, as it merely aims to provide evidence-based scientific support to the European policymaking process.

In the 2011/381/EC, the product group “lubricants” is comprised of the following categories:
1: hydraulic fluids and tractor transmission oils
2: greases and stern tube greases
3: chainsaw oils, concrete release agents, wire rope lubricants, stern tube oils and other total loss lubricants
4: two-stroke oils
5: industrial and marine gear oils.

Preliminary analysis of the existing EU Ecolabel for lubricants indicates the need to explore further during the current revision process the following aspects: 1) A revised definition of “lubricant,” which comprises all product types covered in the scope, 2) A harmonisation of the lubricant classes covered with the ISO 6743 classification, aiming to clearly establish what are the types of lubricants considered under each category, 3) A potential to enlarge the scope to cover higher market share and to allow companies to improve the environmental performance for the different types of lubricant formulations.

In addition, most of the current categories encompass professional and industrial products. However, the report said that the EU Ecolabel is a label that mainly targets consumers. Thus, it recommends the inclusion of certain categories of lubricants that are usually sold to private end consumers as well (e.g. automotive lubricants).

“The existing five categories will certainly be extended to a sixth, automotive lubricants, likely, engine oils,” said Mathias Woydt, head of Division 6.3, Tribology & Wear Protection at BAM, Germany’s Federal Institute for Materials Research and Testing. “If so, an ecolabelled engine oil falls in the ACEA oil sequences C1-C5, more specifically C5, with reduced sulfated ashes of <0.5/0.8 wt.-%.”

An important part of revising the Ecolabel criteria is the involvement of stakeholders, through consultation on draft technical reports and criteria proposals, as well as stakeholder involvement in working group meetings, such as those about to take place in Seville. Stakeholders involved in this report included competent bodies, manufacturers and retailers. The document provides the background information required for the working group meeting.

There are three sections to the report. Task 1 is an analysis of the scope, definitions and description of the legal framework, task 2 is a market analysis, and task 3 is an overview of existing technical lifecycle assessment studies.

Task 1

Task 1 provides an overview of existing technical categories, relevant legislation and standards, and stakeholders’ feedback received in the first questionnaire. It proposes the scope and definition of the product for the revised criteria. The practicability of the proposed changes is assessed in the light of other relevant information (market data, technical analysis, feedback from stakeholders, etc.) and further modifications may later be proposed.

The questionnaire (Appendix 1 of the report) was provided to all stakeholders who had expressed interest in the revision. Forty-four stakeholders answered the questionnaire, most of these (32) being manufacturers of lubricants. Others were: competent bodies (3), suppliers of raw materials (7), and two that did not belong to any particular group.

An overview of several environmental regulations (mainly EU-wide) and labelling schemes related to lubricants, as well as national regulations promoting bio-based lubricants is presented, followed by an overview of environmental schemes for lubricants.

The questionnaire included a proposal to amend the current definition of lubricant from “a preparation consisting of base fluids and additives” to “a substance or mixture capable of reducing friction and wear when introduced between two surfaces which are in relative movement.”

There is a wide range of products available on the lubricants market, but only a few of them are covered by the different voluntary labelling schemes. Moreover, environmental impacts of a lubricant product can be caused at any stage of its life cycle. For this reason, it was initially suggested in the questionnaire to extend the scope as much as possible, including accidental loss of lubricants. It has also been proposed to include lubricant types not currently covered, and to use the words in ISO 6743, “Lubricants, industrial oils and related products,” to define each single family seeking to be aligned with this commonly used standard.

The definition proposed in the questionnaire was accepted by 21 stakeholders, with seven wanting improvements or a different definition.

When analysing the answers related to the scope, those provided by organisations that have been involved with the EU Ecolabel previously were given particular consideration. Twenty-one of these 26 stakeholders did not have difficulty understanding the existing scope. It was noted that some products could fit into two categories.

Stakeholders considered that alignment with ISO 6743 would be an improvement but that there were potential difficulties, due to the different categories included. Some said that a first classification according to environmental impact would be clearer, adding the ISO 6743 families as sub-classifications.

The following proposals have been made:

• Keep the product group name “lubricants.”
• Amend the current definition, to be based on functionality, so that it is comprehensive enough to cover all products in the scope.
• Use the following definition: “A lubricant means a substance or mixture capable of reducing friction, adhesion, heat, wear and corrosion when introduced between two solid surfaces in relative movement and capable to transmit power. The most common constituent substances are base fluids and additives.”
• Make no changes to the complementary definitions.

However, the revised scope, the revised criteria, further research and discussions with stakeholders might result in a proposal for amendments at a later stage of the revision process.

Task 2

The next revision of the EU Ecolabel seeks to expand lubricant coverageConsidering that the EU Ecolabelled lubricants are also marketed outside the EU, and that applicants from third countries (e.g. the U.S.) have applied for the EU Ecolabel, the market data gathered under this section encompasses: Europe, North America, Asia Pacific, Central and South America, the Middle East and North Africa. The data have been provided by a market research firm in the U.S. ( and cover all lubricant types.

Key market figures presented enabled a quantitative assessment of the economic relevance of the different lubricant products at micro and macro level until 2022.

The lubricant market is divided into three main groups: industrial, commercial automotive and consumer automotive. The classification of lubricants according to the market where they are going to be used was also reviewed, from both a global and a regional perspective. A specific overview was dedicated to the small, but growing biolubricants market.

Recent data from the EU Ecolabel Helpdesk Team revealed that 97 licenses have been awarded with a flower. In total, 363 products have become available on the market (EU and third countries).

The global demand for lubricants was 36.4 MT in 2014 and is expected to reach 43.9 MT by 2022, growing at a Compounded Annual Growth Rate (CAGR) of 2.4%. The market had a value of USD35.7 billion in 2014 and it is expected to reach USD68.5 billion in 2022, growing at a CAGR of 7.3%.

A key factor in the development of the global lubricants market is expected to be the rapid industrialisation of Brazil, Russia, India, China and South Africa. The positive outlook of the global automotive industry, in particular in China, India and Brazil, will continue to be important. In 2014, Asia Pacific was the largest regional market, accounting for more than 40% of global demand, and it is expected to remain the fastest growing regional market.

Increasing demand for engine oils, transmissions fluids and gear oils in commercial and consumer automotives is expected to drive the global lubricants market growth.

Increasing importance for industrial machinery maintenance in the manufacturing sector has led to a shift towards condition-based maintenance instead of breakdown maintenance. Additionally, increasing industrial output, particularly in metal forming, foundry, plastics, machining and mining industries of China and India has led to capability expansions by many companies. Demand for lubricants in these industries is expected to significantly grow over the forecast period.

Falling crude oil prices, along with large inventory stocks with net importers, have led to a steep fall of average base oil prices. Such prices fell from an all-time high of USD1,275 per tonne in 2011 to USD976 per tonne in 2014. Average base stock prices are therefore expected to rise significantly over the next six years, on account of the expected recovery of global demand-supply, along with increasing dependence on synthetic lubricants. These prices are expected to follow a similar trend to that of global average crude oil spot prices.

Major producers of base oils can be grouped into two categories: those linked to an oil company and those not linked to an oil company, often tagged as independent manufacturers. In the global base oil market, four companies account for almost 45% of the share: Shell, ExxonMobil, BP/Castrol and Chevron.

Task 3

The technical analysis provided information about the potential impact of lubricants on the environment and human health. The entire life cycle of a lubricant was assessed in order to recognise the life cycle stages with the highest environmental impact and those with the highest improvement potential. The Life Cycle Assessment (LCA) covered manufacturing, use and disposal, and encompassed petroleum, petrochemical, oleochemical and engineering industry activities.

The LCA showed that besides raw materials (which can have relevant impact), the life stages of use and end-of-use can have high environmental impact. These impacts are very important, since approximately 50% of all traditional lubricants are released into the environment during use, spills or disposal stages. The most affected impact categories, due to vegetable base fluid lubricant, are the eutrophication potential, aquatic ecotoxicity and acidification potential. The most affected category with regard to mineral-based lubricants is global warming potential, abiotic depletion, ozone layer depletion and photooxidant creation potential.

The case of engine oils is different from hydraulic oils, however. First, engines are sealed, do not leak, and a collection and waste management system is already in place in Europe. Second, a significant and additional fuel economy above the 3% quoted in ACEA C5, such as >4.5% or >5.0%, may merit an ecolabel. This had been proposed by the German Environmental Agency ( in 2006. In other words, significant fuel economy generated by engine oils may overrule the current toxicity approach in terms of environmental impact.

A prioritisation methodology was proposed, to serve as the basis for the revised scope. It was proposed to maintain those lubricants currently included in the EU Ecolabel scope, and explore the possibility of including new types of lubricants, based on the following priorities:

• total loss lubricants
• accidental loss lubricants with potential release to environmentally sensitive areas
• lubricants linked with human health issues
• lubricants that have disposal issues
• lubricants that have a high market share and/or target end-consumers.

In addition to the environmental assessment, the following issues are relevant:

• harmonisation with the criteria of other labelling schemes for lubricants, like Vessel General Permit 2013 and EN 16807: 2016-12 “Biolubricants”
• current penetration of EU Ecolabel for lubricants
• alignment with EU regulations on chemicals.

This revision proposes to extend the current EU Ecolabel scope to: metalworking fluids (MWFs), 4-stroke engine oils, and temporary protection against corrosion lubricants, bearing in mind that the lubricant market is too broad to cover all of the market in only one revision.

The following relevant impacts on environment and human health have been identified and key areas of potential improvement have been suggested:

• raw materials extraction and processing
• emission to soil/water and hazardous substances
• spillage during use phase and waste generation and disposal
• emissions into the air.

According to Woydt, “As part of [the] refinements, there seems to be a motion to include re-refined base oils. This will engage strong discussions, as it is a paradigm shift.

“It is clear that re-refined oils represent a re-use with CO2 benefits and reduced waste, but is not renewable and renewables can´t be mixed with re-refined. If one acknowledges an environmental contribution by re-refined oils, then it should not interfere with the renewable content. One can imagine a ratio of two parts renewable origin for one part of re-refined oil,” Woydt said.


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