KEY CONCEPTS
• The challenges for adoption of biolubricants also present opportunities for innovation in the industry. 
• Regulation is the single biggest driver in the biolubricants market. 
• Lubricant manufacturers must learn to educate and communicate with end-users about the value proposition of biolubricants. 

---

Meet the Presenter
This article is based on an Industry Insights presented by STLE member Dr. Larry Beaver on April 24, 2024, titled Trending Concepts in Biolubricants - My Experience. Industry Insights is a monthly virtual event series available for free to STLE members. These events provide a forum for members to collaborate with STLE industry peers and experts on a specific topic who give a brief presentation, then facilitate conversation by asking discussion questions and providing actionable takeaways. For more information, click here. 

Dr. Larry Beaver has been in the lubricant industry for 24 years, first in the field of conventional lubricants and now for the past seven years focused on “biolubricants” development for a variety of markets served by RSC Bio Solutions. You can reach him at lbeaver@rscbio.com. 

Dr. Larry Beaver 

---

When it comes to biodegradable lubricants, Dr. Larry Beaver believes that every challenge also is an opportunity: “In most cases, those two are virtually the two sides of the same coin. You have to look at almost every challenge as an opportunity to differentiate your product line or your technology from the competition.” Even if regulatory changes reduce or phase out the use of certain ingredients, the market will demand innovation to find replacements. Developing the optimal replacements is often complicated by unclear definitions, and implementing replacements can be difficult if end-users lack understanding, which they often do. Beaver shares his advice for others in the field on turning these challenges into opportunities in the evolving biolubricants market. 

Current challenges for biolubricants include: 
• Evolving customer needs demand new base oil technologies and formulations 
• Lack of a clear definition for sustainability 
• Need for more data, more quickly 
• End-users do not understand tribology 
• Regulatory concerns and changes 

Evolving customer needs demand new base oil technologies and formulations 
As regulations create more demand for environmentally acceptable lubricants (EALs), formulators must continue to develop products that meet both regulatory and performance demands. This is no simple task; Beaver notes, “It’s not easy to get the combination of base oil and antioxidants that offers the best performance.”  

Beaver notes that while many additive companies offer pre-selected additive packages, he doesn’t recommend going this route. “It is really to your advantage to control your own destiny when it comes to additive systems. The ‘jack of all trades’ additive package is truly the master of none, and you are, in most cases, better off developing your own internal packages.” 

An important consideration when choosing additives is finding base oils that meet all of the requirements for industry standards yet offer enough stability for long-term use. Beaver recommends using the LuSC-list when selecting ingredients. The LuSC-list is the Lubricant Substance Classification list, which is part of the European Ecolabel program for EALs. It provides a list of components and packages that meet stringent requirements for biodegradation, aquatic toxicity and renewability, and can aid formulators in ensuring their finished lubricant products will meet the standards required for the Ecolabel.¹ 

“You can think of the LuSC-list as a box of Legos from which you can build things. If you build your lubricants with ingredients from the LuSC-list, within the ranges of use cited on the LuSC-list, it is much easier, if not outright guaranteed, to get an Ecolabel listing based on that. The challenge is that there are ingredients always coming on to the list and there are ingredients always going off of the list,” explains Beaver. He cautions that formulators also must consider the maximum concentration requirements, and the particular application is another major factor. 

“The key with all of these formulas is to look holistically to find an inherently stable base oil, and then you have to find the right antioxidant cocktail to stabilize it. And that’s not trivial when you’re dealing with something like the Ecolabel, which has very low limits,” Beaver explains. 

Lack of a clear definition for sustainability 
Defining “sustainability” is a challenge in itself. Beaver notes that sustainability means different things to different people—formulation, disposal, lifecycle analysis and other factors all contribute. Even the various regulatory bodies have not reached a consensus as to what qualifies as sustainable, even though there is overlap in many of their qualifications. As an example, Beaver says, “The Ecolabel standard requirements overlap the Vessel General Permit (VGP) enough that as of right now, if you have an Ecolabel, you qualify as a VGP-compliant lubricant.” In addition to varying in their definitions of sustainability and qualification parameters, geography also impacts which regulations apply to a particular lubricant application.  

Beaver mentions the following regulations impacting the lubricant market: 

• VGP 
• Ecolabel 
• Swedish Standard (SS 155470) 
• OSPAR Commission 
• Harmonised Offshore Chemical Notification Format (HOCNF) 

Other related terminology also can be unclear, with different regulatory bodies following different definitions. Beaver notes that biobased lubricants, biodegradable lubricants and EALs are different names for similar but not necessarily identical lubricant technologies. He gives the example of biodegradability: “You can ask eight people what biodegradable means and you’ll get eight different answers.” “Biodegradable” is even defined differently by VGP and Ecolabel; each has a slightly different threshold for the percentage of dissolved organic carbon removed.  

Additionally, end-users may have their own differences in how they define sustainability. Beaver explains that sustainability can be assessed from a business standpoint, a formulation standpoint, a disposal standpoint or even a lifecycle analysis, and none of these will be exactly the same. This is where communication becomes critical for the EAL formulator, who must balance the regulatory definitions with customer expectations—and the performance requirements of the finished product. 

Need for more data, more quickly 
Then there is the matter of which data to consider in assessing sustainability. Unfortunately, suppliers often lack meaningful data about their products. “One of my experiences has been that when you go to additive suppliers or base oil suppliers and ask for product carbon footprint information, with few exceptions, most will tell you, ‘We’re working on it.’ So, the data that we need to do our calculations for our customers is lagging the demand,” Beaver explains. 

Choosing which data to collect can be a challenge in itself. Depending on the end-user’s sustainability goals, they might be looking at one or more categories of emissions. Emissions are typically divided into three categories:  

• Scope 1 emissions are direct greenhouse gas (GHG) emissions that occur from sources that are controlled or owned by an organization (e.g., emissions associated with fuel combustion in boilers, furnaces, vehicles). 
• Scope 2 emissions are indirect GHG emissions associated with the purchase of electricity, steam, heat or cooling. 
• Scope 3 emissions are the result of activities from assets not owned or controlled by the reporting organization, but that the organization indirectly impacts its value chain. 

Beaver calls Scope 3 emissions “hidden GHG emissions” and notes that Scope 3 emissions can be the hardest ones to identify. Beaver points out that OEMs often look at an incomplete picture: “OEMs tend to look at GHG reductions more from the standpoint of eliminating GHG emissions, rather than avoiding the use of products that cause GHG emissions during manufacture. So, there’s a big focus on Scope 1 and Scope 2 emissions, and there’s not so much right now on Scope 3 and avoidance.”  

End-users do not understand tribology 
According to Beaver, education is part of the solution to the challenges with adopting EALs, and educating the industry about base oil technology and additive technology can even lead to reduced GHG emissions. Beaver says, “There’s a good bit of education needed for end-users and OEMs on what lubricants can and can’t do in their systems. Many times, they’re going on archived information and not new technology.” When the end-user doesn’t understand how the lubricant works, they don’t understand the value of choosing the right lubricant for the right application. Their expectations might even be out of touch with the current lubricant technology. 

“There are customers who set extremely high hurdles for EALs. That’s actually one of the biggest hurdles we have right now.” These customers may have been early adopters of biolubricants that did not perform well, Beaver explains. They may expect that sustainability is a trade-off for performance, but this is no longer true. “The most stable option is not always the most costly option, and it’s possible to gain a stable formula without spending a ton of money to do it. Drain intervals can be extended and the value proposition is there now for the biolubricant. You no longer have to compromise performance to get sustainability to the way you once did.” 

Beaver identifies communication as another obstacle: “Communication from and with customers has been a real challenge, and it’s not a challenge just for a smaller company—it’s a challenge for even the larger companies.” Factors that contribute include high turnover in the OEM industry and a lack of understanding about tribology in general. “It’s not unusual to be dealing with an OEM on an approval for a gear oil and for the person that you’ve been working with for the last 12 to 18 months on a long-term project to be reassigned, and then to have to almost literally start over again with a new person.”  

When it comes to the lack of knowledge about tribology, Beaver sees this as one of the opportunities wrapped up in a challenge. He notes that customers and OEMs don’t know that STLE exists or the resources it provides, but new outreach strategies can target this audience with the goal of improving sustainability in the industry. As Beaver says, “We’re going to have to be diligent in our education efforts. We have to figure out a way to educate end-use customers and OEMs in the benefits of biolubricants and what they can offer long-term for the value proposition.” 

Regulatory concerns and changes 
As discussed earlier, the various regulatory bodies involved are a challenge for defining sustainability, but the hurdles involved don’t end there. Regulations are in a constant state of development. The EPA is currently updating the regulations known as 2013 VGP with legislation known as The Vessel Incident Discharge Act (VIDA).² Beaver explains that this is not a simple process: “The regulations are still being written and rewritten and modified and argued about. The standards of performance have to be officially adopted, and they have not been, and they have to officially be transmitted to the U.S. Coast Guard, which they have not been. And then the Coast Guard needs to write and publish regulations based on those standards of performance. So, it’s going to be, I think, a while before we get to that point.” 

The 2013 VGP regulations require all vessels to use EALs in all oil-to-sea interfaces unless technically infeasible, and are applicable to all commercial vessels larger than 79 feet operating within three nautical miles of either the U.S. coastline or any one of the Great Lakes.³ The 2013 VGP establishes effluent limits, sampling, inspection, reporting, recordkeeping and other requirements for 27 specific types of incidental discharges from vessels.² The VIDA legislation extends the VGP regulations until the new regulations are final and enforceable.² 

While changing regulations can cause headaches for end-users, the challenge can be a huge opportunity for formulators to create new products. According to Beaver, VGP compliance is the single biggest driver in the marine industry. “Probably one of the largest incentives to adopting EALs was the VGP 2013 that opened up markets,” he explains. “We do recognize that niche markets will continue to expand as the regulations increase.” 

Conclusions 
Beaver emphasizes that his feedback is based on his personal experiences over the years working in the industry. However, the issues he discusses—unclear definitions of sustainability and related terms, demand for faster data, need for customer education, regulatory changes and evolving customer demands—are shared by many in the industry as sustainability becomes a more urgent requirement. Beaver recommends following the activities of the new STLE Sustainability Committee to keep up to date on developments in the industry. 

REFERENCES 
1. https://environment.ec.europa.eu/topics/circular-economy/eu-ecolabel/product-groups-and-criteria/lubricants_en  
2. www.epa.gov/vessels-marinas-and-ports/vessels-vgp 
3. https://rscbio.com/resources/vgp/  

You can reach TLT editorial coordinator Nicole Gleeson at ngleeson@stle.org.