EU proposal to reclassify common lubricant antioxidants could have wide ranging consequences
4 September 2024
The French Agency for Food, Environmental and Occupational Health & Safety (ANSES) has submitted Harmonised Classification and Labelling (CLH) proposals for two substituted diphenyl amine (SDPA) antioxidants under the framework of the EU Classification, Packaging and Labelling Regulation. If approved, the reclassification could impact engine lubricant formulations, supply chains and sustainability, and even stop consumers changing their own oil—warns Infineum International.
The two SDPAs, C4:C8 and C9, are used as antioxidants in approximately 90-95% of all engine oils and have been proposed by the French authority for fulfilling criteria as Reprotoxic Category 1B and qualifying as Substances of Very High Concern (SVHCs).
This would lead to consumer products being removed from the market and preventing end users from changing and ‘topping-up’ their own engine oil. In the longer term, additional regulatory measures could be implemented, such as a wider scoping Authorisation or Restriction to also include professional and industrial uses.
In addition, the proposed CLH of Aquatic Chronic Cat. 1 with an M-Factor of 10 for C9 SDPA would lead to most downstream lubricant oils being classified as Dangerous Goods. This could increase costs and controls for their storage and transport, as well as lead to a potential constraint on capacity available for the total volume of oils classified as Dangerous Goods in the market.
If the proposal is accepted and enters into force around mid-2026, users would have until the end of 2027 to amend labels and safety data sheets. End user restrictions could come into force in the same time frame, with potential restrictions on professional and industrial use coming into force early in the next decade.
The ATC (The Technical Committee of Petroleum Additive Manufacturers in Europe) has noted its opinion, based upon an analysis of the available toxicology data, that the proposed CLH for both substances is not scientifically justified.
According to Infineum, there are currently no commercially available alternative antioxidants that can deliver the required performance levels for engine lubricants. While it may be possible to develop alternative chemistries, doing so before the end of 2027 represents an unprecedented challenge.
The two SDPA antioxidants are widely used in lubricants for transport and power generation applications. They are also used in applications by a wide range of other industries, such as in greases and fluids for agricultural and engineering machinery, metalworking fluids and in the production of plastics. All of which could be impacted by their re-classification.
Source: Infineum Insight