7735/11 MS/fp 1 

DG I 1A EN

COUNCIL OF

THE EUROPEAN UNION

Brussels, 16 March 2011 

 

7735/11 

ENV 201 

COVER NOTE 

from: European Commission 

date of receipt: 4 March 2011 

to: General Secretariat of the Council 

Subject: Draft Commission Decision of [...] on establishing the ecological criteria for 

the award of the EU Ecolabel to lubricants 

Delegations will find attached Commission document D012687/02. 

________________________ 

Encl.: D012687/02 
EN EN 

EUROPEAN COMMISSION 

Brussels 

D012687/02 

 

Draft 

COMMISSION DECISION 

of [...] 

on establishing the ecological criteria for the award of the EU Ecolabel to lubricants 

(Text with EEA relevance) 
EN 2 EN 

Draft 

COMMISSION DECISION 

of 

establishing the ecological criteria for the award of the EU Ecolabel to lubricants 

THE EUROPEAN COMMISSION, 

Having regard to the Treaty on the Functioning of the European Union, 

Having regard to Regulation (EC) No 66/2010 of the European Parliament and of the Council 

of 25 November 2009 on the EU Ecolabel1

, and in particular Article 8(2) thereof, 

After consulting the European Union Ecolabelling Board, 

Whereas: 

(1) Under Regulation (EC) No 66/2010, the EU Ecolabel may be awarded to those 

products with a reduced environmental impact during their entire life cycle. 

(2) Regulation (EC) No 66/2010 provides that specific EU Ecolabel criteria are to be 

established according to product groups. 

(3) Commission Decision 2005/360/EC2

 has established the ecological criteria and the 

related assessment and verification requirements for lubricants which are valid until 30 

June 2011. 

(4) Those criteria have been further reviewed in light of technological developments. The 

new criteria, as well as the related assessment and verification requirements, should be 

valid for four years from the date of adoption of this Decision 

(5) Decision 2005/360/EC should be replaced for reasons of clarity. 

(6) A transitional period should be allowed for producers whose products have been 

awarded the EU Ecolabel for lubricants on the basis of the criteria set out in Decision 

2005/360/EC, so that they have sufficient time to adapt their products to comply with 

the revised criteria and requirements. Producers should also be allowed to submit 

applications based on the criteria set out in Decision 2005/360/EC or on the criteria set 

out in this Decision until the lapse of validity of that Decision. 

(7) The measures provided for in this Decision are in accordance with the opinion of the 

Committee established by Article 16 of Regulation (EC) No 66/2010, 

 

1

 OJ L 27, 30.1.2010, p. 1. 

2

 OJ L 118, 05.05.2005 
EN 3 EN 

HAS ADOPTED THIS DECISION: 

Article 1 

The product group "lubricants" shall comprise the following categories: 

Category 1: hydraulic fluids and tractor transmission oils 

Category 2: greases and stern tube greases 

Category 3: chainsaw oils, concrete release agents, wire rope lubricants, stern tube oils and 

other total loss lubricants 

Category 4: two-stroke oils 

Category 5: industrial and marine gear oils. 

Article 2 

For the purpose of this Decision, the following definitions shall apply: 

(1) lubricant means a preparation consisting of base fluids and additives. 

(2) basefluid means a lubricating fluid whose flow, ageing, lubricity and anti-wear 

properties, as well as its properties, regarding contaminant suspension, have not been 

improved by the inclusion of additive(s). 

(3) substance means a chemical element and its compounds in the natural state or obtained by 

any production process, including any additive necessary to preserve the stability of the 

products and any impurity deriving from the process used, but excluding any solvent 

which may be separated without affecting the stability of the substance or changing its 

composition. 

(4) thickener means one or more substances in the base fluid used to thicken or modify the 

rheology of a lubricating fluid or grease. 

(5) main component means any substance accounting for more than 5 % by weight of the 

lubricant. 

(6) additive means a substance or mixture whose primary functions are the improvement 

of the flow, ageing, lubricity, anti-wear properties or of contaminant suspension. 

(7) grease means a solid to semi-solid mixture which consists of a thickener and may 

include other ingredients imparting special properties in a liquid lubricant. 

Article 3 

In order to be awarded the EU Ecolabel under Regulation (EC) No 66/2010 a product shall 

fall within the product group "lubricants" as defined in Article 1 of this Decision and shall 
EN 4 EN 

comply with the criteria as well as the related assessment and verification requirements set out 

in the Annex to this Decision. 

Article 4 

The ecological criteria for the product group "lubricants", as well as the related assessment 

and verification requirements shall be valid for four years from the date of the adoption of this 

Decision. 

Article 5 

For administrative purposes, the code number assigned to the product group "lubricants" shall 

be "027". 

Article 6 

Decision 2005/360/EC is repealed. 

Article 7 

1. By derogation from Article 6, applications for the EU Ecolabel for products falling 

within the product group "lubricants" submitted before the date of adoption of this 

Decision shall be evaluated in accordance with the conditions laid down in Decision 

2005/360/EC. 

2. Where the EU Ecolabel is awarded on the basis of an application evaluated according 

to the criteria set out in Decision 2005/360/EC, that EU Ecolabel may be used for 12 

months from the date of adoption of this Decision. 

Article 8 

This Decision is addressed to the Member States. 

Done at Brussels, 

For the Commission 

Janez POTOČNIK 

Member of the Commission
EN 5 EN 

ANNEX

FRAMEWORK 

The aims of the criteria 

These criteria aim in particular at promoting products that have a reduced impact on the water 

and soil during its use and contain a large fraction of biobased material. 

CRITERIA 

1. Excluded or limited substances and mixtures 

2. Exclusion of specific substances 

3. Additional aquatic toxicity requirements 

4. Biodegradability and bioaccumulative potential 

5. Renewable raw materials 

6. Minimum technical performance 

7. Information appearing on the EU Ecolabel 

Assessment and verification requirements 

(a) Requirements 

The specific assessment and verification requirements are indicated within each criterion. 

Where the applicant is required to provide declarations, documentation, analyses, test reports, 

or other evidence to show compliance with the criteria to the competent body, it is understood 

that these may originate from the applicant and/or his supplier(s) and/or their supplier(s), etc., 

as appropriate. 

The supplier of the additive, thickener or base fluid may provide the relevant information 

directly to the competent body. 

Where possible, the testing should be performed by laboratories that meet the general 

requirements of EN ISO 17025 or equivalent. 

Where appropriate, test methods other than those indicated for each criterion may be used if 

the competent body assessing the application accepts their equivalence. 

Where appropriate, competent bodies may require supporting documentation and may carry 

out independent verifications. 
EN 6 EN 

The general scheme for the assessment of any constituent substance in a lubricant product is 

given in Table 1. 

(b) Measurement thresholds 

All constituent substances that are present above 0.010% (w/w) and which are intentionally 

added and/or are formed intentionally after any chemical reaction in the applied lubricant 

shall be unambiguously stated giving their names and the mass concentrations in which they 

are present and where applicable, their CAS Registry and EC registry number. 

The criteria shall apply as follows: 

• to the applied lubricant for criteria 1a, 6 and 7 

• to each stated substance intentionally added or formed above 0.010% (w/w) for criterion 

1b and 2, 

• to each stated substance intentionally added or formed above 0.10% (w/w) for criteria 3, 4 

and 5. 

In addition the total fraction of the stated substances where the formulated criteria 3 and 4 do 

not apply shall remain below 0.5% (w/w). 

EU ECOLABEL CRITERIA

Criterion 1 – Excluded or limited substances and mixtures 

a) Hazardous substances and mixtures 

According to the Article 6(6) of Regulation (EC) No 66/2010 on the EU Ecolabel, the product 

or any part of it shall not contain substances (in any forms, including nanoforms) meeting the 

criteria for classification with the hazard statements or risk phrases specified below in 

accordance with Regulation (EC) No 1272/2008 or Directive 67/548/EC nor shall it contain 

substances referred to in Article 57 of Regulation (EC) No 1907/2006. The risk phrases below 

generally refer to substances. Nanoforms intentionally added to the product shall prove 

compliance with this criterion for any concentration.

List of hazard statements and risk phrases: 

Hazard Statement1 Risk Phrase2

H300 Fatal if swallowed R28 

H301 Toxic if swallowed R25 

H304 May be fatal if swallowed and enters airways R65 

H310 Fatal in contact with skin R27 

H311 Toxic in contact with skin R24 
EN 7 EN 

H330 Fatal if inhaled R26 

H331 Toxic if inhaled R23 

H340 May cause genetic defects R46 

H341 Suspected of causing genetic defects R68 

H350 May cause cancer R45 

H350i May cause cancer by inhalation R49 

H351 Suspected of causing cancer R40 

H360F May damage fertility R60 

H360D May damage the unborn child R61 

H360FD May damage fertility. May damage the unborn 

child 

R60; R61; R60-61 

H360Fd May damage fertility. Suspected of damaging the 

unborn child 

R60-R63 

H360Df May damage the unborn child. Suspected of 

damaging fertility 

R61-R62 

H361f Suspected of damaging fertility R62 

H361d Suspected of damaging the unborn child R63 

H361fd Suspected of damaging fertility. Suspected of 

damaging the unborn child 

R62-63 

H362 May cause harm to breast fed children R64 

H370 Causes damage to organs R39/23; R39/24; R39/25; 

R39/26; R39/27; R39/28 

H371 May cause damage to organs R68/20; R68/21; R68/22 

H372 Causes damage to organs through prolonged or 

repeated exposure 

R48/25; R48/24; R48/23 

H373 May cause damage to organs through prolonged or 

repeated exposure 

R48/20; R48/21; R48/22 

H400 Very toxic to aquatic life R50 

H410 Very toxic to aquatic life with long-lasting effects R50-53 

H411 Toxic to aquatic life with long-lasting effects R51-53 
EN 8 EN 

H412 Harmful to aquatic life with long-lasting effects R52-53 

H413 May cause long-lasting harmful effects to aquatic life R53 

EUH059 Hazardous to the ozone layer R59 

EUH029 Contact with water liberates toxic gas R29 

EUH031 Contact with acids liberates toxic gas R31 

EUH032 Contact with acids liberates very toxic gas R32 

EUH070 Toxic by eye contact R39-41 

1 As provided for in Regulation (EC) No 1272/2008 of the European Parliament and of the Council 

2 As provided for in Council Directive 67/548/EC 

This criterion shall also apply to the following hazard statements and risk phrases: 

Hazard Statement1 Risk Phrase2

H334: May cause allergy or asthma symptoms or breathing 

difficulties if inhaled 

R42 

H317: May cause allergic skin reaction R43 

H314 Causes severe skin burns and eye damage R34; R35 

H319 Causes serious eye irritation R36 

H315 Causes skin irritation R38 

EUH066 Repeated exposure may cause skin dryness or 

cracking 

R66 

H336 May cause drowsiness and dizziness R67 

1 As provided for in Regulation (EC) No 1272/2008 of the European Parliament and of the Council 

2 As provided for in Council Directive 67/548/EC 

Substances or mixtures which change their properties upon processing (e.g., become no 

longer bioavailable, undergo chemical modification) so that the identified hazard no longer 

applies are exempted from the above requirement. 

Concentration limits for substances meeting criteria of Article 57 (a), (b) or (c) of Regulation 

(EC) No 1907/2006 shall not exceed 0.010% (w/w). If specific concentration limits are 

referred to for substances meeting criteria of Article 57 (a), (b) or (c) they should remain 

below one tenth (1/10) of the lowest specific concentration value indicated unless this value 

falls below 0.010% (w/w). 

Derogations from Criterion 1a are listed in Table 1. 

Assessment and verification of criterion: the applicant shall provide the exact formulation of 

the product to the competent body. The applicant shall demonstrate compliance with this 
EN 9 EN 

criterion for substances in the product on the basis of information consisting as a minimum of 

that specified in Annex VII of the Regulation (EC) No 1907/2006. Such information shall be 

specific to the particular form of the substance, including nanoforms, used in the product. For 

that purpose, the applicant shall provide a declaration of compliance with this criterion, 

together with a list of ingredients and related Safety Data Sheets in accordance with Annex II 

to Regulation (EC) No 1907/2006 for the product as well as for all substances listed in the 

formulation(s). Concentration limits shall be specified in the Safety Data Sheets in 

accordance with Article 31 of Regulation (EC) No 1907/2006. 

Sufficient data shall be available to allow for the evaluation of the environmental hazards 

(indicated by the hazard statements H400 – H413 or R-phrases: R 50, R 50/53, R 51/53, R 52, 

R 52/53, R 53), of the product in accordance with Regulation (EC) No 1272/2008 or Council 

Directives 67/548/EC and 1999/45/EC of the European Parliament and of the Council3

. 

The evaluation of a product for hazards to the environment shall be performed by the 

conventional method as indicated in Annex III to Directive 1999/45/EC or by the summation 

method in section 4.1.3.5.2 of Regulation (EC) No 1272/2008. However, as defined by part C 

of Annex III to Directive 1999/45/EC or by section 4.1.3.3 of Regulation (EC) No 1272/2008, 

the results of testing the preparation (either the product preparation or the additive package) 

as such can be used to modify the classification concerning the aquatic toxicity that would 

have been obtained using the conventional or summation method. 

b) Substances listed in accordance with Article 59(1) of Regulation 1907/2006 

No derogation from the exclusion in Article 6(6) of Regulation (EC) No 66/2010 may be 

given concerning substances identified as substances of very high concern and included in the 

list foreseen in Article 59 of Regulation (EC) No 1907/2006, when present in mixtures, in 

concentrations higher than 0.010% (w/w). 

Assessment and verification: the list of substances identified as substances of very high 

concern and included in the candidate list in accordance with Article 59 of Regulation (EC) 

No 1907/2006 can be found here: 

http://echa.europa.eu/chem_data/authorisation_process/candidate_list_table_en.asp

Reference to the list shall be made on the date of application. 

Concentration limits shall be specified in the safety data sheets according to Annex II, 

paragraph 3.2.1(c) of Regulation (EC) No 453/2010. 

Criterion 2 – Exclusion of specific substances 

The following stated substances are not allowed in quantities exceeding 0.010% (w/w) of the 

final product: 

– Substances appearing in the Union List of priority substances in the field of water 

policy in Annex X to Directive 2000/60/EC as amended by laid in Decision 

2455/2001/EC4

 and the OSPAR List of Chemicals for Priority Action 

 

3

 OJ L 200, 30.7.1999, p.1. 

4

 OJ L 331 15.12.2001 
EN 10 EN 

(http://www.ospar.org/content/content.asp?menu=00950304450000_000000_000

000) 

– Organic halogen compounds and nitrite compounds

– Metals or metallic compounds with the exception of sodium, potassium, 

magnesium and calcium. In the case of thickeners, also lithium and/or aluminium 

compounds may be used up to concentrations limited by the other criteria 

included in the Annex to this Decision. 

Assessment and verification: conformance with these requirements shall be stated in writing 

and signed by the applicant. 

Criterion 3 - Additional aquatic toxicity requirements 

The applicant shall demonstrate compliance by meeting the requirements of either criterion 

3.1 or criterion 3.2. 

Criterion 3.1 - Requirements for the lubricant and its main components

Acute aquatic toxicity data of the main components and the mixture shall be provided. 

Acute aquatic toxicity data for each main component shall be stated on each of the following 

two trophic levels: algae and daphnia5

. The critical concentration for the acute aquatic toxicity 

for each main component shall be at least 100 mg/L. 

Acute aquatic toxicity data for the applied lubricant shall be stated on each of the following 

three trophic levels: algae, daphnia and fish. The critical concentration for the acute aquatic 

toxicity for a lubricant in Category 1 and 5 shall be at least 100 mg/l and for a lubricant in 

Category 2, 3 and 4 at least 1000 mg/l. 

Table 2 summarises the requirements for the different lubricant categories according to 

Criterion 3.1.

Assessment and verification: either marine or freshwater toxicity data are accepted. The tests 

are carried out according to and using relevant test species mentioned in the following 

guidelines: ISO/DIS 10253 or OECD 201 or Part C.3. of the Annex to Commission 

Regulation (EC) No 440/20086

for algae, ISO TC 147/SC5/WG2 or OECD 202 or Part C.2. of 

the Annex to Regulation (EC) No 440/2008 for daphnia and OECD 203 or Part C.1. of the 

Annex to Regulation (EC) No 440/2008 for fish. Equivalent test methods as agreed with a 

competent body are also permitted. Only (72hr) ErC50 for algae, (48hr)EC50 for daphnia 

and (96hr)LC50 for fish are accepted. 

Criterion 3.2 - Requirements for each stated substance present above 0.10% (w/w) 

Chronic toxicity test results in the form of No Observed Effect Concentration (NOEC) data 

shall be stated on each of the following two aquatic trophic levels: daphnia and fish. 

In case chronic toxicity test results are missing, acute aquatic toxicity tests results shall be 

provided for each of the following two trophic levels; algae and daphnia. One or more 

 

5

 Crustacean can substitute for daphnia throughout this Decision where marine data is submitted. 
EN 11 EN 

substances exhibiting a certain degree of aquatic toxicity are allowed in each of the five 

lubricant categories for a cumulative mass concentration as indicated in Table 1. 

Assessment and verification: No Observed Effect Concentration (NOEC) data on the two 

trophic levels, daphnia and fish, are established by the following test methods: Part C.20. and 

Part C.14 of the Annex to Regulation (EC) No 440/2008 for daphnia and fish respectively, or 

equivalent test methods as agreed with a competent body. 

Either marine or freshwater acute toxicity data are accepted on algae and daphnia. The tests 

in marine water are carried out according to and using relevant test species mentioned in the 

following guidelines: ISO/DIS 10253 or OECD 201 or Part C.3. of the Annex to Commission 

Regulation (EC) No 440/20086

 for algae, ISO TC 147/SC5/WG2 or OECD 202 or Part C.2. of 

the Annex to Regulation (EC) No 440/2008 for daphnia and OECD 203 or Part C.1. of the 

Annex to Regulation (EC) No 440/2008 for fish. Equivalent test methods as agreed with a 

competent body are also permitted. Only (72hr)ErC50 for algae and (48hr)EC50 for daphnia 

are accepted. 

Assessment and verification for Criteria 3.1 and 3.2: high quality test reports or literature 

data (testing according to acceptable protocols and GLP) including the references shall be 

submitted to the competent body demonstrating compliance with the requirements set out for 

the aquatic toxicity in Table 1. 

In the case of slightly soluble substances or preparations (< 10 mg/l) the method of the wateraccommodated fraction (WAF) can be used in the aquatic toxicity determination. The 

established loading level, sometimes referred to as LL50 and related to the lethal loading, 

may be used directly in the classification criteria. The preparation of a water accommodated 

fraction shall follow the recommendations set out according to one of the following 

guidelines; ECETOC Technical Report No 20 (1986), Annex III to OECD 1992 301 or the 

ISO Guidance document ISO 10634, or ASTM D6081-98 (Standard practice for Aquatic 

Toxicity Testing for Lubricants: Sample Preparation and Results Interpretation or equivalent 

methods). In addition, demonstration of the absence of toxicity for a substance at its limit of 

water solubility shall be deemed to have met the requirements of this criterion. 

An aquatic toxicity study does not need to be conducted when: 

– the classification of the substance, base fluid or additive is already stated on the Lubricant 

Substance Classification list or 

– a valid letter of compliance from a competent body can be submitted or 

– the substance is unlikely to cross biological membranes MM > 800 g/mol or molecular 

diameter > 1,5 nm (> 15 Å) or, 

– the substance is a polymer and its molecular weight fraction below 1000 g/mol is less than 

1% or 

– the substance is highly insoluble in water (water solubility < 10 μg/l), 

 

6

 OJ L 142, 31.5.2008, p.1. 
EN 12 EN 

as such substances are not regarded as toxic for algae and daphnia in the aquatic system. 

The water solubility of substances shall be determined where appropriate according to OECD 

105 or equivalent test methods. 

The molecular weight fraction below 1000 g/mol of a polymer shall be determined according 

to Part A.19. of the Annex to Regulation (EC) No 440/2008 or equivalent test methods. 

Criterion 4 - Biodegradability and bioaccumulative potential 

Requirements for the biodegradability and bioaccumulative potential shall be fulfilled for 

each stated substance present above 0.10% (w/w). 

The lubricant shall not contain substances that are both: non-biodegradable and (potentially) 

bioaccumulative. 

However, the lubricant may contain one or more substances with a certain degree of 

degradability and potential or actual bioaccumulation up to a cumulative mass concentration 

as indicated in Table 1. 

Assessment and verification: conformity shall be demonstrated by providing the following 

information: 

High quality test reports or literature data (testing according to acceptable protocols and 

GLP) including the references on the biodegradability and when required on the (potential) 

bioaccumulation of each constituent substance. 

4.1 Biodegradation 

A substance is considered ultimately biodegradable (aerobic) if: 

1. In a 28-day biodegradation study according Part C.4. of the Annex to Regulation (EC) No 

440/2008, OECD 306, OECD 310 the following levels of biodegradation are achieved: 

— in the ultimately biodegradable tests based upon dissolved organic carbon ≥ 70 %, 

— in the ultimately biodegradable tests based upon oxygen depletion or carbon dioxide 

generation ≥ 60 % of the theoretical maxima. 

In these ultimately biodegradable tests the 10-day window principle will not necessarily 

apply. If the substance reaches the biodegradation pass level within 28 days but not within the 

10-day time-window, a slower degradation rate is assumed. 

2. The BOD5/ThOD or BOD5/COD ratio ≥0.5. The BOD5/(ThOD or COD) ratio can only be 

used if no data based on Part C.4. of the Annex to Regulation (EC) No 440/2008, OECD 306 

or OECD 310 or any other equivalent test methods are available. The BOD5 shall be 

assessed according to Part C.5. of the Annex to Regulation 440/2008 or equivalent methods 

while the COD shall be assessed according to Part C.6. of the Annex to Regulation 440/2008 

or equivalent methods. 
EN 13 EN 

A substance is considered inherently biodegradable if it shows: 

— a biodegradation > 70 % in the Part C.9. of the Annex to Regulation (EC) No 440/2008 or 

OECD 302 C test for inherent biodegradation or equivalent methods, or 

— a biodegradation > 20 % but < 60 % after 28 days in Part C.4. of the Annex to Regulation 

(EC) No 440/2008, OECD 306, OECD 310 tests based on oxygen depletion or carbon dioxide 

generation or equivalent methods. 

The biodegradation test does not need to be conducted when: 

the classification of the substance, base fluid or additive is already stated on the Lubricant 

Substance Classification list or a valid letter of compliance from a competent body can be 

submitted 

A substance is non-biodegradable if it fails the criteria for ultimate and inherent 

biodegradability. 

The applicant may also use read-across data to estimate the biodegradability of a substance. 

‘Read-across’ for the assessment of the biodegradability of a substance shall be acceptable if 

the reference substance differs by only one functional group or fragment from the substance 

applied in the product. If the reference substance is readily or inherently biodegradable and 

the functional group has a positive effect on the aerobic biodegradation then the applied 

substance may also be regarded as readily or inherently biodegradable. Functional groups or 

fragments with a positive effect on the biodegradation are: aliphatic and aromatic alcohol [-

OH], aliphatic and aromatic acid [-C(=O)-OH], aldehyde [-CHO], Ester [-C(=O)-O-C], 

amide [-C(=O)–N or -C(=S)–N]. Adequate and reliable documentation of the study on the 

reference substance should be provided. In case of a comparison with a fragment, not 

included here above, adequate and reliable documentation of the studies should be provided 

on the positive effect of the functional group on the biodegradation of structurally similar 

substances. 

4.2 Bioaccumulation 

The (potential) bioaccumulation does not need to be established when the substance: 

- has a MM > 800 g/mol, or 

- has a molecular diameter > 1,5 nm (> 15 Å), or 

- has an octanol-water partition coefficient, log Kow, value of < 3 or > 7, or 

- has a measured BCF of ≤ 100 L/kg, or 

- is a polymer and its molecular weight fraction below 1000 g/mol is less than 1%. 

Since most substances used in lubricants are quite hydrophobic the BCF-value should be 

based on the lipid weight content and care must be shown to ensure a sufficient exposure 

time.

The bioconcentration factor (BCF) shall be assessed according to Part C.13. of the Annex to 

Regulation (EC) No 440/2008 or equivalent test methods. 

The log octanol/water partition coefficient (log Kow) shall be assessed according to Part A.8. 

of the Annex to Regulation (EC) No 440/2008 or OECD 123 or equivalent test methods. In 

case of an organic substance other than a surfactant where no experimental value is 

available, a calculation method can be used. The following calculation methods are allowed: 

CLOGP, LOGKOW, (KOWWIN) and SPARC. Estimated log Kow values by any of these 

calculation methods < 3 or >7 indicates that the substance is not expected to bioaccumulate. 
EN 14 EN 

Log Kow values are applicable to organic chemicals only. To assess the bioaccumulation 

potential of non-organic compounds, surfactants, and some organo-metallic compounds, BCF 

measurements shall be carried out. 

Criterion 5 - Renewable raw materials 

The formulated product shall have a carbon content derived from renewable raw materials 

that shall be: 

≥ 50 % (m/m) for Category 1, 

≥ 45 % (m/m) for Category 2, 

≥ 70 % (m/m) for Category 3, 

≥ 50 % (m/m) for Category 4, 

≥ 50 % (m/m) for Category 5. 

Carbon content derived from renewable raw material means the mass percentage of 

component A × [number of C-atoms in component A, which are derived from (vegetable) oils 

or (animal) fats divided by the total number of C-atoms in component A] plus mass 

percentage of component B × [number of C-atoms in component B, which are derived from 

(vegetable) oils or (animal) fats divided by the total number of C-atoms in component B] plus 

the mass percentage of component C × [number of C-atoms in component C, which are 

derived from (vegetable) oils or (animal) fats divided by the total number of C-atoms in 

component C], and so on. 

The applicant shall indicate on the application form the type (s), source(s) and origin of the 

renewable material(s) of the main components. 

Assessment and verification: the applicant shall provide the competent body with a 

declaration of compliance with this criterion. 

Criterion 6 - Minimum technical performance 

(a) For Hydraulic fluids: at least the technical performance criteria as laid down in the 

current ISO 15380, Tables 2 to 5. The supplier shall list on his product information 

sheet which 2 elastomers have been tested. 

(b) For Industrial and marine gear oils: at least the technical performance requirements 

as in the DIN 51517. The supplier shall list on his product information sheet which 

section (I, II or III) was selected. 

(c) For chainsaw oils: at least the technical performance criteria as laid down in the RAL 

UZ 48 of the Blue Angel 

(d) For two-stroke oils for marine applications: at least the technical performance criteria 

laid down in "NMMA Certification for Two-Stroke Cycle Gasoline Engine 

Lubricants" of NMMA TC-W3. 

(e) For two-stroke oils for terrestrial applications: at least meet the EGD level of 

technical performance criteria laid down in ISO 13738:2000. 
EN 15 EN 

(f) For all other lubricants: fit for purpose.

Assessment and verification: the applicant shall provide the competent body with a 

declaration of compliance with this criterion, together with related documentation.

Criterion 7: Information appearing on the eco-label 

Optional label with text box shall contain the following text: 

“- Reduced harm for water and soil during use 

- Contain a large fraction of biobased material”. 

The guidelines for the use of the optional label with text box can be found in the "Guidelines 

for the use of the EU Ecolabel logo" on the website: 

http://ec.europa.eu/environment/ecolabel/promo/logos_en.htm

Assessment and verification: the applicant shall provide the competent body with a sample of 

the product packaging showing the label, together with a declaration of compliance with this 

criterion.
EN 16 EN 

Table 1: Criteria for the lubricant and each stated substance 
EN 17 EN 

Category 1 Category 2 Category 3 Category 4 Category 5 

Category 

Criteria 

Hydraulic fluids, 

tractor transmission 

oils 

Greases, stern 

tube greases 

Chain saw oils, 

concrete release 

agents, wire rope 

lubricants and 

other total loss 

lubricants

Terrestrial and 

marine twostroke oils 

Industrial and 

marine gear oils 

Hazard statements and R-phrases indicating 

environmental and human health hazards 

(Derogation for Criterion 1a) 

Category 1 Category 2 Category 3 Category 4 Category 5

Health or Environmental Hazard statement or 

R-phrase of the lubricant at the time of 

application 

None 

(Lowest 

classification limit in 

Regulation (EC) No 

1272/2008 or 

Council Directive 

99/45/EC) 

None 

(Lowest 

classification 

limit in 

Regulation (EC) 

No 1272/2008 

or Council 

Directive 

99/45/EC) 

None 

(Lowest 

classification limit 

in Regulation (EC) 

No 1272/2008 or 

Council Directive 

99/45/EC) 

None 

(Lowest 

classification 

limit in 

Regulation 

(EC) No 

1272/2008 or 

Council 

Directive 

99/45/EC) 

None 

(Lowest 

classification limit 

in Regulation (EC) 

No 1272/2008 or 

Council Directive 

99/45/EC) 

Exclusion of specific substances 

(Criterion 1b and 2) 

Category 1 Category 2 Category 3 Category 4 Category 5 

OSPAR-listed; the Union list of priority 

substances in the field of water policy; organic 

halogens; nitrites; metals and metallic 

compounds except Na, K, Mg, Ca and for 

thickeners Li, Al; CMR cat 1,2 (R45, R46, R49, 

R60 or R61); Annex XIV to Regulation (EC) 

No 1907/2006; 

< 0.010% < 0.010% < 0.010% < 0.010% < 0.010% 

Aquatic toxicity Cumulative mass percentages (% w/w) of substances present in 

(Criterion 3.2 only) Category 1 Category 2 Category 3 Category 4 Category 5 

Not 

toxic 

(D) 

Acute toxicity > 100 mg/L 

or 

NOEC > 10 mg/L 

Not limited 

Harmful 

(E) 

10 mg/L < Acute toxicity ≤ 100 

mg/L 

or 

1 mg/L < NOEC ≤ 10 mg/L 

≤ 20 ≤ 25 ≤ 5 ≤ 25 ≤ 20 

Toxic 

(F) 

1 mg/L < Acute toxicity ≤ 10 mg/L 

or 

0.1 mg/L < NOEC ≤ 1 mg/L 

≤ 5 ≤ 1 ≤ 0.5 ≤ 1 ≤ 5 

Very 

toxic 

(G) 

Acute toxicity ≤ 1 mg/L 

or 

NOEC ≤ 0.1 mg/L 

≤ 0.1/M(*) ≤ 0.1/M(*) ≤ 0.1/M(*) ≤ 0.1/M(*) ≤ 1/M(*)

Biodegradation and Bioaccumulation Cumulative mass percentages (%w/w) of substances present in 

(Criterion 4) Category 1 Category 2 Category 3 Category 4 Category 5 

Ultimately aerobically biodegradable (A) > 90 > 75 > 90 > 75 > 90 

Inherently aerobically biodegradable (B) ≤ 5 ≤ 5 ≤ 20 ≤ 5 

Non-biodegradable AND non-bioaccumulative 

(C) 

≤ 5 

≤ 25 

≤ 5 ≤ 10 ≤ 5 

Non-biodegradable AND bioaccumulative (X) ≤ 0.1 ≤ 0.1 ≤ 0.1 ≤ 0.1 ≤ 0.1 

Fraction not assessed on aquatic toxicity Cumulative mass percentages (%w/w) of substances present in

(Criterion 3.2) or 

biodegradation/bioaccumulation (Criterion 

4) 

Category 1 Category 2 Category 3 Category 4 Category 5 

 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 
EN 18 EN 

(*) M is the multiplication factor of 10 for substances that are very toxic to the aquatic 

environment as from Table 1b in Directive 2006/8/EC. 

multiplication 

factor (M) 

LC50 or EC50 value (“L(E)C50”) of 

substance 

1 0.1 < L(E)C50 ≤1 

10 0.01 < L(E)C50 ≤ 0.1 

100 0.001 < L(E)C50 ≤ 0.01 

1000 0.0001 < L(E)C50 ≤ 0.001 

For substances with a lower LC50 or EC50 value than 

0.0001 mg/l, the corresponding concentration limits are 

calculated accordingly (in factor 10 intervals). 

Table 2: Aquatic toxicity requirements for the different lubricant categories – Data 

requirements for the lubricant and its main components.

Criterion 3.1 Category 1 Category 

2 

Category 

3 

Category 4 Category 5 

Acute aquatic toxicity for 

the freshly prepared 

lubricant on three trophic 

levels, algae, daphnia and 

fish 

> 100 mg/L > 1000 

mg/L 

> 1000 

mg/L 

> 1000 

mg/L > 100 mg/L 

Acute aquatic toxicity for 

each main component on 

each of two trophic levels, 

algae and daphnia 

> 100 mg/L > 100 

mg/L 

> 100 

mg/L > 100 mg/L > 100 mg/L 

Renewability Cumulative mass percentages (%w/w) of substances present in

(Criterion 5) Category 1 Category 2 Category 3 Category 4 Category 5 

Based on carbon ≥ 50% ≥ 45% ≥ 70% ≥ 50% ≥ 50% 

 Category 1 Category 2 Category 3 Category 4 Category 5 

Minimal Technical performance 

(Criterion 6)

Hydraulic fluids: ISO 

15380 Tables 2 to 5. 

Tractor transmission 

oils: fit for purpose. 

Fit for 

purpose 

Chain saw oils: as in 

RAL UZ 48. 

Others: fit for purpose 

Marine 2T-oils: 

as in NMMA 

TC-W3. 

Terrestrial 2Toils: as the 

EGD level in 

ISO 

13738:2000. 

Industrial and 

marine gear oils 

DIN 51517