UEIL Newsletter – April 2023

28/04/2023

President’s Report

In December 2019, a few months after its election, the European Parliament adopted the EU’s Green Deal, a framework aimed at making the EU climate neutral by 2050.

Among the many policy initiatives that have been launched within the framework, the most relevant for our industry are:

The Fit for 55 Package, which includes, among others, a provision requiring that from 2035 all new cars and vans registered in the EU would need to have zero emissions.
The Ecodesign for Sustainable Products Regulation (ESPR), which not only will require manufacturers to assess the environmental impact of their products and design them to be more sustainable throughout their entire life but could also mandate specific and pervasive information and formulation requirements.

The fate of such initiatives will define the shape of our industry in the future.

Political pressure to finalize the regulations is increasing. The next European Parliament elections are scheduled to take place in 2024, and most likely, the EU Commission will want to get there with some results in its pockets.

This past February, the proposal on zero-emissions vehicles was approved by the European Parliament but then failed to obtain ratification from the EU Council, because of a blocking minority said to be composed of Bulgaria, Germany, Italy and Poland. Negotiations are ongoing and seem to be pointing at the possibility to keep allowing the use of internal combustion engines if green fuels are used.

As for ESPR, the EU Commission has proposed to include lubricants in the priority sectors to be regulated. A public consultation is open and will close on 12 May. The finalization of the regulation is planned for the end of the year.

UEIL, as part of the large industrial families of the chemicals, oil and manufacturing industries, needs to be an active part of the debate. For that, we need all the possible support and insight from the best minds in our great industry. You are all invited to engage with us. We need you all!

Mattia Adani

UEIL President

Technical & Competition Committees Update

The Technical and Competition Committees gathered online to work on the various technical and competition cases currently open and exchange on the latest development on relevant EU policies. Over the past months, many non-compliance cases have been closed successfully, while the rest are evolving in the right direction.

Among the highlights, is the publication of two OEM bulletins on Mercedes-Benz MB 228.51 LT so called specification. After several exchanges, Mercedes-Benz clarified their communication explaining MB 228.51 LT was not a specification, but the trade name of the Mercedes-Benz genuine engine oil approved in the 228.51 category.

Regarding policy updates, at the EU level, the European Commission has published its revision of the Motor Vehicle Block Exemption Regulation (MVBER). As expected, the revision has unfortunately only made small changes.

Sustainability Committee Update

UEIL/ATIEL PCF Methodology Update

UEIL is pleased to announce significant progress in its collaboration with ATIEL to develop a harmonized methodology for calculating and reporting Product Carbon Footprints (PCFs) for lubricants. Since January 2023, a dedicated working group, supported by external consultants, has been diligently working to establish a cradle-to-gate (blenders/marketers exit gate) PCF methodology for the entire lubricants industry, ensuring consistency and transparency throughout the supply chain.

The PCF Working Group has held three full-day in-person meetings and weekly virtual catch-ups to advance the methodology drafting. As of April 2023, the group has successfully addressed key aspects of the methodology, including allocation methodologies, product system and system boundaries, cut-off definitions relevant for the Lifecycle Inventory, sensitivity analysis, interpretation guidelines, and the reporting framework. The working group is now finalizing the first draft before reviewing it internally for the first time.

After the internal review period, the first draft will be submitted for external reviews by associated organizations.

The publication of the PCF methodology for the lubricants industry is expected in the second half of 2023.

ICIS 27^th World Base Oils and Lubricants Conference 2023

John Eastwood (Sustainability Committee Co-Chair) will be in Windsor on 4^th May to present a paper entitled ‘Product Carbon Footprints’. The presentation will take place in the Technical Session at 2.00pm and will outline the leadership role of UEIL in developing Corporate Carbon Footprint toolbox and the joint work with ATIEL to develop a Product Carbon Footprint calculation methodology for the Lubricants industry.

Health, Safety and Environment Committee

The high EU chemicals legislation actuality has kept the HSE Committee and its subgroups intensively busy in the last months.

Main file of this first quarter of 2023 is the CLP regulation revision, for which UEIL submitted a response to the public consultation in March. The revision aims, amongst others, to set new labelling requirements, and to cover “multi-constituent substances”. Stephan Baumgärtel, chair of the HSE Committee and Cindy Vandeercastel, chair of the CLP subgroup, went on a tour to promote UEIL’s position. Together with the Secretariat, they met in the European Parliament the Rapporteur Ms. Maria Spyraki (EPP, Greece) in charge if leading the position of the European Parliament on this file. They also held an online exchange with the shadow rapporteur MEP Joao Albuquerque (S&D, Portugal) and Hans Ingels, Head of Unit Chemicals at DG GROW, European Commission. The Secretariat will also participate to a roundtable organised by the Greens this week on the dossier.

The HSE Committee is also working on a response to the ECHA consultation on the PFAS restriction proposal, with a position to be ready ideally before the beginning of June. Members are also working on a response to the Ecodesign for Sustainable Products Regulation (ESPR) public consultation open until 12 May, where lubricants have been identified by the European Commission as priority groups. Any company is welcome to participate to the public consultation. Besides the responses to the questionnaire, a position paper has already been finalised and endorsed by the Board during their recent meeting at the end of April. In parallel, members are following the Safe and sustainable by design initiative (SSbD) which aims to phase out of hazardous substances. While the lithium classification and the REACH revision proposal are facing some delays, members are getting ready for their publication by Q4 2023, if not before.

The Committee met in person in Brussels on 18 April, with a guest speaker from Cyclevia, the French eco-organization of the mineral oil sector. This was also the opportunity for members to exchange with him and learn more about this national initiative. Members also shared intelligence on the latest national associations news and brainstormed on next steps to continue implementing the 2023 strategic plan.

Taxation Taskforce Update

The EU Co-Legislators are currently negotiating the revised Energy Taxation Directive that the European Commission published two years ago. This revised Directive is important for the lubricant sector to promote a level playing field in Europe.

Furthermore, related to UEIL’s objective to prevent the inclusion of lubes under the Excise Movement and Control System (EMCS), certain EU Member States are concerned about increased fraud with lubes across Europe and are once again increasing the pressure to include lubes under EMCS. UEIL will continue its outreach to the EU Member States in the coming weeks to express its concern and will discuss with the European Commission the option of a definition of ‘light lubes’ that might be included under EMCS at the end of 2023.

The European Commission has also decided to abolish the quota on Gp II in the second half of 2022. Belgium has asked the European Commission to reinstall the quota on Gp II as on basis of input of the lubricant sector the demand is still higher than the supply on Gp II in the EU. If the European Commission approves this request, Member States will discuss the need for a quota on Gp II at technical working group level in Q2 2023. UEIL is in favour to reinstall a quota on Gp II as the demand is still higher than the supply in the EU.