What You Need to Know

Use and Exposure

To determine whether your use(s) of Shell Lubricants products are suitably covered under our REACH activities - we urge you to review the guidance and actions we have proposed in the Use and Exposure section of this 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 are actively working 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 lubricants/lubricant products throughout the supply chain for input into the development of exposure scenarios.

Confirmation of Pre-registration

We confirm that Shell Lubricants companies have pre-registered substances they manufacture in Europe (e.g. base oils, process oils, grease thickeners). This marks the first step towards full registration of these substances.

Relevant substances imported by Shell Lubricants companies (including substances in preparations) have been pre-registered by the importing Shell company or have been covered by an appropriate Only Representative arrangement.

In addition to manufacture, Shell Lubricants companies blend finished lubricants (i.e. preparations) for which we also procure many 3rd party substances. The REACH regulation does not require the pre-registration of preparations. However, all component substances must be pre-registered.

We are in the final stages of receiving confirmation of substance pre-registration from all our suppliers. This confirmation may be received in the form of pre-registration numbers or by documented statements that they, or the relevant actor in the supply chain, have pre-registered the substances supplied to Shell companies.

In summary, Shell lubricants companies do not expect the supply of the products in the current Shell Lubricants European portfolio to be disrupted. Note that this will not include products you are importing directly.

Only Representative

Shell Lubricants companies have not appointed an Only Representative 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.

Pre-registration Numbers

There is no legal obligation to communicate pre-registration numbers through the supply chain. Indeed, a pre-registration number alone is not sufficient to guarantee compliance within REACH.

However, for the substances we manufacture - the pre-registration numbers will be available at the website given in this letter.

As indicated above - we expect our suppliers to confirm pre-registration of the substances we procure in different ways. This may or may not include sharing of pre-registration numbers.

As such, we do not intend to share the pre-registration numbers for all the substances contained in the finished lubricants that we market.

Substances of Very High Concern (SVHC)

All of the substances in the Candidate List of SVHC for authorisation (published on 28th October 2008), have been included in our own Shell Lubricants Restricted Substances List for well over 10 years. This means that, during this time, they have been prohibited from use in new formulations developed for Shell Branded Lubricant products, and where they were known to be used in existing formulations, they were high priority for replacement.

Based on our current level of knowledge, we are not aware of any Shell Lubricant products which include any of these 15 substances.  However, we are continuing to work with our component suppliers to ensure that these substances are not used in any materials supplied to Shell, and therefore we are able to provide specific product declarations on a case-by-case basis.

We are also currently undertaking a survey of our packaging suppliers to establish the presence of SVHC. This survey is not complete, but based on the responses received so far - we do not anticipate the listed SVHCs to be present at > 0.1%

Material Safety Data Sheets (MSDS)
 
MSDS for Shell Lubricants products are being amended to the new format (i.e. Sections 2 and 3 are reversed and a contact email address has been added).

The additional, more significant changes to MSDS required by REACH (e.g. inclusion of Exposure Scenarios) will take place from 2010.

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.

1. www.atiel.org - opens in new window  and www.atc-europe.org - opens in new window
2. As promoted by the European Chemical Industry Council (CEFIC), the Distributors
Association (FECC) and the Downstream Users Association (DUCC).  For further details of
the model and exposure scenario development see CEFIC REACH document ‘Guidance on ES development & Supply Chain Communication’ - www.cefic.org - opens in new window