Once again, Annex VIII of the CLP is a cause for much concern. Lube manufacturers supplying lubricants labeled as “dangerous” for human health (and also labeled for some physical hazards) have to submit details of the formulation including non-hazardous substances to the “appointed bodies”, which means local poison centres, by 2024 for industrial use and 2021 for professional use.
The information has to be submitted in the local language and include a “unique formulation identifier (UFI)” which allows users to track formulations. Details of the annex VIII legislation will be discussed in our HSE working group. A position paper will be issued soon and we will express our concerns on workability to the Commission.
Just a week after our next HSE meeting in May, the last registration phase of REACH ended. Substances without full registration could no longer be used in lubricants after June 1st. The only exemption is for substances bought from suppliers before June and in stock.
We will also discuss the recent proposal for a restriction of so called microplastic particles. From the Commission’s working paper, it is not entirely clear if this may also include certain polymers used i.e. in metalworking fluids. The HSE group will follow these issues and keep UEIL members updated.