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What You Need to Know
The following provides an update of the REACH status of Shell Lubricants companies.
Please advertise this page to relevant collegues, such as REACH focal points, HSE advisors, industrial hygienists or product stewards.
Shell Lubricants companies have completed the registration of substances manufactured and/or imported at >1000 tpa. Please also check the product inventory page of this website.
We confirm that Shell Lubricants companies have either:
- pre-registered substances they manufacture or import in Europe (including substances in preparations) that have a later registration deadline of either 31st May 2013 or 31st May 2018 (e.g. grease thickeners) or
- have ensured that where a pre-registration does not exist, these substances are covered by an appropriate Only Representative arrangement.
Reformulation or Discontinuation of Shell Branded Lubricants
As Shell Lubricants products are typically complex mixtures comprising substances with different registration deadlines, it is not possible to provide a definitive registration deadline for most products.
However, we can confirm that there are currently no plans to reformulate or discontinue any of these products as a result of any REACH requirements.
Furthermore, to the best of our knowledge, we do not anticipate this situation changing in the foreseeable future.
If there are changes in our supply plans as a result of REACH requirements and impacting the products you purchase from Shell Lubricants companies, we will inform you at the earliest possible opportunity and work with you to minimize the impact of our decision on your supply chain.
We also continue to request assurances from our EU suppliers of purchased components that they remain on schedule to meet the required registration deadlines. At this time, we have no indication that any substances procured by Shell Lubricants companies will not be available beyond 31st May 2013. Accordingly, we do not expect that the Shell Branded Lubricants products you purchase will be withdrawn as a result of REACH requirements applicable on substances procured by Shell Lubricants companies.
Use and Exposure
Please read this section carefully, as you might need to take action.
To determine whether your use(s) of Shell Lubricants products are suitably covered under our REACH activities - please review the guidance and actions we have proposed on our website:
REACH requires an understanding of how chemical substances are used, specifically, how they are handled throughout their life cycle from manufacture to disposal. For those substances that are hazardous to both human health and environment, a Chemical Safety Assessment, including the development of exposure scenarios, is required for each use to demonstrate that it is safe. This is part of the REACH registration process.
For substances we manufacture (for example base oils, process oils, foots oils, aromatic extracts) we continue to work actively with CONCAWE (the Oil Companies’ European Association for Environment, Health and Safety in Refining and Distribution) who are collating information on product uses for the development of exposure scenarios for use in the Chemical Safety Assessments.
For our blended lubricants (i.e. preparations/mixtures) – we are working in a similar way with the Technical Association of the European Lubricants Industry (ATIEL) and the Technical Committee of Petroleum Additive Manufacturers in Europe (ATC) to map the uses of lubricant products throughout the supply chain for input into the development of generic exposure scenarios.
Shell Lubricants companies have not appointed an Only Representative to cover the imports of our customers.
If you would like to discuss your import of a Shell Lubricants product into Europe, please contact your usual Shell Lubricants representative.
Substances of Very High Concern (SVHC).
Most of the substances in the EChA Candidate List of SVHC for authorisation, available on the ECHA website have been included in our own Shell Lubricants Restricted Substances List for well over 10 years. This means that, during this time, the use of these SVHC in new formulations developed for Shell Branded Lubricant Products has been discouraged. Where they are known to be used in existing formulations, they are high priority for replacement.
As the EChA Candidate List of SVHC for authorisation is frequently updated to include new substances, we have issued a separate “SVHC communication” that will be kept aligned with the latest version of the EChA List.
Please visit the SVHC status section on this website where you can read and download the communication.
Safety Data Sheets (SDS)
For the substances that Shell Lubricants companies have registered in 2010 –revised eSDSs are available.
Please refer to www.epc.shell.com.
If we identify a significant change to the information in risk management or classification based on new hazard information – a revised eSDS will be re-issued without delay.
For the mixtures we place on the market – if we receive any information that causes a significant change to the advice provided on our SDS – we shall re-issue a revised SDS without delay.
Generic exposure scenarios will be appended to classified mixtures for which we have received an incoming eSDS on one of the risk determining substances in the mixture.
We look forward to working closely with you to ensure REACH compliance of our products.
In the meantime, please contact your usual Shell Lubricants representative if you would like to discuss any aspect of REACH in more detail.
In addition to manufacture, Shell lubricants companies blend finished lubricants (i.e. preparations) for which we also procure many substances. The REACH regulation does not require the pre-registration of preparations. However, all component substances must be pre-registered.
As Shell Lubricants products are typically complex mixtures comprising substances with different registration deadlines, it is not possible to provide a definitive registration date for most products because of the complexity of the supply chain.
We can, however, confirm that there are currently no plans to reformulate or discontinue any products as a result of any REACH requirements and furthermore we do not anticipate this situation changing in the foreseeable future.
If there are changes in our supply plans as a result of REACH and impacting the products you purchase, you have our assurance that we will inform you at the earliest possible opportunity and work with you to minimize the impact of our decision.
We continue to request assurances from our EU suppliers of purchased components that they remain on schedule to meet the required deadline. At this time, we have no indication that any substances procured by Shell Lubricants companies will not be available beyond 31st May 2013 and accordingly, we do not expect that the products you purchase will be withdrawn for REACH purposes.
More information on our products can be found at the Shell Lubricants website
If you have any questions about (pre-) registration, please address them to your usual Shell Lubricants representative or contact us.
Important Note: these expected registrations DO NOT cover the following:
The manufacture of these products by Shell outside the EU
The importation of these products into Europe by non-Shell companies.