EU REACH PETCO ASSESSMENT
The European Chemicals Agency (ECHA) published a screening assessment on 8 September 2026 examining whether REACH restrictions may be appropriate for petroleum and coal stream (PetCo) substances in professional and consumer lubricant uses with high environmental release. The report identifies a potential environmental risk from non-readily biodegradable lubricants and recommends further investigation of specific total loss and partial loss applications, with forestry and marine uses as possible starting points.
ECHA's assessment report does not itself introduce a new lubricant ban, concentration limit or compliance deadline. The next stage recommended in the report is to investigate whether restriction would be an appropriate regulatory tool and which uses it should address.
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Why composition and end use matter
PetCo substances are complex streams identified as substances of unknown or variable composition, complex reaction products or biological origin (UVCBs). Their constituents can vary with feedstock and processing. A commercial description such as mineral base oil therefore provides insufficient detail for a product-specific assessment.
ECHA's April 2025 paper on PetCo regulatory management identified concerns involving hazardous constituents, including certain polycyclic aromatic hydrocarbons (PAHs), and considered restriction potentially more suitable than authorisation for addressing shared hazardous constituents across different substances. The September 2026 report focuses more closely on environmental releases from lubricant uses and the role of biodegradability.
For a lubricant portfolio review, the useful unit of analysis is the formulation in its intended application. The same ingredient can present different release pathways in an enclosed system and in equipment that loses lubricant during normal operation.
Products in scopeWhich products should suppliers review first
The report uses the EU Ecolabel categories of total loss lubricants, such as chainsaw oils and wire-rope lubricants, and partial loss lubricants, such as marine stern-tube oils and two-stroke oils. These categories describe releases during normal use. Accidental loss lubricants used in closed systems, such as hydraulic fluids and closed gear oils, fall outside the high-release scope defined in the report. The assessment concerns unused lubricants; used lubricating oils covered by waste legislation are excluded.
Manufacturers, importers and formulators should prioritise products for which releases to soil or water cannot be avoided or significantly reduced. The report identifies forestry machinery and marine applications as possible starting points for further investigation; it also highlights rail-track lubrication where water bodies could be contaminated. For each product, ask the customer or equipment operator how the lubricant is applied, how much is retained or collected, and where losses occur. These examples do not establish the scope of a future restriction.
Volumes and releasesWhat the report found about volumes and releases
Using registration dossier information retrieved in June 2025, section 4.2.1 and Table 2 report approximately 3.2 million tonnes of PetCo substances used annually in lubricants by professionals and consumers. Of this, approximately 800,000 tonnes per year are assigned to uses with high environmental release, around 95% of which are lubricant base oils. These figures describe substance use volumes, rather than measured environmental emissions or the tonnage of finished lubricant formulations. Tonnage for the identified coal-stream substance is confidential, and no volume information is provided for orphan substances.
ECHA questions whether the release factors used in exposure assessments adequately reflect these applications. For the Concawe high-release scenarios, the report describes a combined factor of 10.5% to air, water and soil. Total loss applications can involve releases of up to 100%. ECHA therefore considers that exposure and risk may be underestimated; the 10.5% figure should not be presented as a measured release rate across all lubricant products.
PAH screeningWhy existing PAH screening does not resolve the environmental question
The report questions whether the existing carcinogenicity screening approach also protects the environment. For relevant lubricant base oils, CLP Note L refers to less than 3% dimethyl sulphoxide (DMSO) extract measured by IP 346. This is an extract-based classification criterion, rather than a general 3% limit on total PAHs in finished lubricants. The report also notes that IP 346 was designed for unused, additive-free lubricating base oils and is unsuitable for lubricants containing additives.
ECHA recommends investigating whether broader PAH marker approaches would better address environmental effects. It has not established a new lubricant PAH limit in this report. Biodegradability, aquatic toxicity and bioaccumulation potential remain separate considerations when evaluating the environmental profile of a product.
Preparation stepsPreparing evidence and assessing alternatives
Regulatory, procurement and formulation teams can use the following work programme to identify gaps before committing to reformulation or new studies. These are preparation recommendations, rather than requirements created by the assessment announcement.
Build a product and use inventory. Link each formulation to its PetCo ingredient identities, suppliers, annual volumes, customer sectors and intended uses. Separate uses with potential direct environmental release from those with effective containment.
Review the supporting substance data. Obtain available composition information and evidence relevant to PAHs, biodegradation and environmental hazards. Identify what the data actually cover before deciding whether further analysis or testing is needed.
Evaluate alternatives against the application. Compare environmental performance with lubrication performance, equipment compatibility, availability and cost. A change in feedstock or a claim that a product is bio-based should not replace an assessment of its constituents and properties.
Check existing national rules and procurement specifications separately. The report identifies an Austrian restriction on mineral oil-based chainsaw oils, alongside other national and voluntary measures. Confirm the requirements applicable to the intended market and use. Where an EU Ecolabel or an environmentally acceptable lubricant specification is requested, establish the applicable criteria and evidence. The report itself does not create a universal certification obligation.
Keep supply-chain records aligned. Review whether substance information, identified uses and safety data sheets remain consistent with the formulation supplied. Where a consortium such as Concawe supports shared data, confirm which information is available for the substance concerned and which responsibilities remain with the individual company.
For a broader review of the records supporting EU imports, see REACH24H's REACH and CLP evidence checklist for chemical mixtures.
Regulatory next stepsFollow the formal regulatory steps
ECHA recommends further work to identify uses for possible restriction and define suitable biodegradability criteria, taking account of testing difficulties for complex UVCBs. The report also suggests examining other EU legislative options and surveying Member States on existing measures and enforcement experience. These are recommendations for further investigation, rather than an announced EU-wide enforcement project. Suppliers should monitor any subsequent restriction intention, Annex XV dossier or consultation for the proposed scope and conditions.
How REACH24H can help
REACH24H's EU chemical compliance services support reviews of applicable REACH and CLP obligations and related compliance documentation. Contact our team to discuss your lubricant portfolio, supply-chain roles and the evidence needed for an EU compliance review.
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