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Eco Mark Product Category No. 110 “ Biodegradable Lubricating Oil“ Biodegradable Lubricating Oil“ Biodegradable Lubricating Oil“ Biodegradable Lubricating Oil Version2.0 Version2.0 Version2.0 Version2.0””””

Japan Environment Association Eco Mark Office

1. Environmental Background1. Environmental Background1. Environmental Background1. Environmental Background Lubricating oil is classified into two basic categories based on how it is used, namely, open system (2-cycle engine oil, grease, chain saw oil etc.) and closed system (hydraulic oil, 4-cycle engine oil, grease, etc.). It could be said that the former, open system oil, will affect the environment considerably, since most of the oil will be emitted into the nature. The latter, closed system oil, is also likely to be emitted into the nature by accident. Typical oils of closed system that will greatly affect the environment for animals and plants are hydraulic oil used for construction machinery, 4-cycle engine oil and grease. Sales of lubricating oil in 2001 amounted to 2.09 million kiloliters (ex-cluding grease), and the amount of oil waste generated totaled 1.20 million kiloliters, of which 0.88 million kiloliters were thought to be recycled or dis-posed after being collected by collection businesses, and 0.32 million kiloliters were recycled or incinerated by generators themselves within the company. For lubricating oil not taken as waste oil, it is estimated that a large amount is discharged into the environment through open use and accidents. Various additives are used in lubricating oil and grease in order to im-prove their quality, but these additives might have a negative effect on the environment because some additives contain hazardous materials even though they are in tiny amount. Furthermore, chlorinated additives may cause the generation of dioxins during energy recovery of waste oil and incineration. It is therefore of great significance to certify lubricating oil with high biodegradability that uses or discharges few harmful substances as environ-mental load with the Eco Mark, and spread awareness and use of these prod-ucts. Biodegradable lubricating oil that gives consideration to the environment in terms of manufacturing, distribution, and consumption was therefore in-cluded in this product category. NOTE: This document is a translation of the criteria written in Japanese. In the event of dispute, the original document should be taken as authoritative.

Annex 1

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2. Applicable Products2. Applicable Products2. Applicable Products2. Applicable Products Hydraulic oil, 2-cycle engine oil, grease and other lubricating oil in the following. Excluding spray type oils; (1) Hydraulic oil: “Machinery oil” included in “lubricating oil” designated as the object items of survey in the” Dynamic statistics of supply and demand of petroleum products concerning petroleum related products (designated statistics No. 51).” Or, “hydraulic oil” out of (high-grade) lubricating oil and machinery oil included in “lubricating oil and grease,” “lubricating oil and grease” in accor-dance with the “Standard Commodity Classification for Japan” issued by the General Affairs Agency. (2) 2-cycle engine oil: “Gasoline engine oil” included in “lubricating oil” designated as the object items of survey in the “Dynamic statistics of supply and demand of petroleum products concerning petroleum related products (designated statistics No. 51).” Or, “2-cycle engine oil” out of “(high quality) lubricating oil,” “gasoline engine oil” included in “lubricating oil and grease” in accordance with the “Standard Commodity Classification for Japan” issued by the General Affairs Agency. (3) Grease: “Grease” designated as the object items of survey in the “Dynamic statis-tics of supply and demand of petroleum products concerning petroleum related products (designated statistics No. 51)” or “grease” out of “lubricating oil and grease” in accordance with the “Standard Commodity Classification for Ja-pan.” (4) Other lubricating oil: “Lubricating oil” other than the above mentioned “hydraulic oil,” “2-cycle engine oil” and “grease,” out of “lubricating oil” and “grease” designated as the object items of survey in the “Dynamic statistics of supply and demand of pe-troleum products concerning related petroleum products (designated statistics No. 51),” or out of “lubricating oil and grease” in accordance with the “Japan Standard Commodity Classification” issued by the General Affairs Agency. 3. Terminology3. Terminology3. Terminology3. Terminology -Base oil: the main component of lubricating oil. With general lubricating oil, mineral oil is mainly used; examples of base oil for lubricating oil with high biodegradability include vegetable oil, synthetic ester, PAG (polyalkylene glycol), etc.

-Additive: added to base oil to give new properties to products or complement insufficient properties. There are various types according to purpose.

-Constituents: component added intentionally with the purpose of rendering a certain characteristic to the product. Does not include impurities that may be unavoidably mixed in.

-Biodegradability: the extent by which organic compound is biodegraded by

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microbes to be finally converted into inorganic compound, or the degree of difficulty of biodegradability. In other words, carbon and hydrogen, which organic compound is composed of, are biodegraded into carbon dioxide and water.

-LC50 value: 50% fatal density. Volume (density) of a substance in the solution which will kill half of an animal population regarded as homogeneous.

-EC50 value: 50% influential concentration. Amount (concentration) of sub-stances in liquid affecting half of parent population considered as consistent.

-EL50 value: 50% influential concentration load rate. Percentage of test sub-stances in water affecting half of the parent population considered as consis-tent. Used when creating liquid extract of soluble components from hardly soluble substances, and performing toxic tests. (*Refer to definition of ASTM D6081.)

4. Certification Criteria4. Certification Criteria4. Certification Criteria4. Certification Criteria 4-1. Environmental criteria (1) The production process shall conform to relevant environmental regula-tions and agreements on preventing air pollution, water contamination, wastes, and emission of hazardous materials. (2) In manufacturing, the use of chemical substances must be managed appro-priately. Specifically, submit MSDSs (Material Safety Data Sheets) of products based on PRTR Law (Law Concerning Reporting, etc. of Release to the Envi-ronment of Specific Chemical Substances and Promoting Improvements in Their Management). (3) EDTA (ethylenediaminetetraacetic acid) and alkylphenol ethoxylates whose number of carbon atoms attached to the alkyl group are 5 to 9 shall not be added as constituents. (4) If the product uses Class 1 specified chemical substances in the PRTR Law, this shall be reported. However, this does not apply to substances containing less than 1% for both base oil and additives. (5) Chlorinated additives shall not be added to the product as constituents. (6) For products using the following mineral oil as the base oil, the mineral oil shall not be classified as carcinogenic by the OSHA HCS (the Hazard Commu-nication Standard issued by the Occupational Safety and Health Administra-tion, Department of Labor, U.S.A.) and EU Directive 94/69/EC (laws, regula-tions, and administrative standards on classification, packaging, and labeling of hazardous substances, corresponding protocols for 21st technical adaptation in directive 67/548/EEC). “Oil obtained by the reduced-pressure distillation of the sediments of atmos-pheric distillation of crude oil, oil obtained by refining this (including brightstock) where kinematic viscosity in 40°C is 7 mm2/s or above. Aluminum rolling oil obtained by re-distilling light oil and kerosene is excluded. Syn-thetic oil is also not included in this definition.” (7) Biodegradability of products measured by one of the following methods

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shall be 60% or more within 28 days. However, 10-d window does not apply to these methods. *OECD (Organization for Economic Cooperation and Development)Chemical

Product Test Guidelines ・ 301B (CO2 Evolution) ・ 301C (Modified MITI(I)) ・ 301F (Manometric Respirometry)

*ASTM(American Material Test Association) ・ D 5864 (Standard test method determining aerobic biodegradability

of lubricating oil and lubricating oil components) ・ D 6731 (Standard test method determining aerobic biodegradability

of lubricating oil or lubricating oil components sealed in the respi-rometer in water.)

(8) As for influence of the product on the ecosystem, the 96-hour LC50 value shall be 100 mg/liter or above in acute toxic tests in fish measured by one of the following tests. *JIS (Japan Industrial Standards)

・ K 0102 (Plant Sewage Test Method) ・ K 0420-71 series (10, 20, 30)

(Measurement of acute toxicity of chemical substances for water qual-ity-fresh water fish [zebra fish (bony fish, cyprinid)-Part 1: stationary water, Part 2: Semi-stationary water, Part 3: Flowing water]*OECD

・ 203 (Fish Acute Toxicity Test) <Additional note> In addition to acute toxicity tests in fish, the condition of satisfying “48 hour EC50 value to be 100 mg/liter or above in tests for determination of the inhibition of the mobility of Daphnia by chemicals measured by one of the fol-lowing methods” shall continue to be reviewed. This item shall not applied at this time, the starting date of application shall be reviewed and notified when set. Notification shall be done at least 6 months prior to the starting date. *JIS

・ K 0229 (Testing methods for determination of the inhibition of the mobility of Daphnia by chemicals)

*OECD ・ 202 Part I (test for determination of the inhibition of the mobility of Daphnia by chemicals and multiplication part 1 “24 hours EC50 mobility inhibition test”)

In implementing the mobility inhibition test for products with low solu-bility, liquid extract made by ASTM D6081 (standard implementation method for toxic tests of lubricating oil in water environment: preparation of sample and interpretation of results) can be used as samples. In this case, the 48 hour EL50 value must be 100mg/liter or above.

(9) Precautions on the appropriate handling of products, such as “biodegrad-

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able oil has little impact on the environment compared to normal oil, but this does not mean that it has none. Minimize discharge and leakage into the en-vironment” and precautions on waste disposal such as “appropriate waste dis-posal required also for biodegradable oil” shall be indicated on MSDS, con-tainers, and labels (PL labels) for users. (10) Plastic materials used for containers and packaging shall not contain resins made of halogenides and organic halogenides as constituents. 4-2. Quality criteria (11) Hydraulic oil: Products with JIS standards shall conform to the corresponding JIS stan-dards. If the above standard does not apply to the product, it shall be of a quality conforming a standard similar to JIS, etc. standards. (12) 2-cycle engine oil: Oil shall conform to one of the following standards (a), (b) and (c). (a) JASO (Japan Automobile Standards) M345:2002 (lubricating oil for 2

stroke cycle gasoline) FC grade and above (b) NMMA (National Marine Manufacturers Association) TC-W3TM (certifica-

tion test of lubricating oil for 2 stroke cycle gasoline)

If the above provisions do not apply to the product, it shall be of a quality conforming to a standard similar to the JIS standard. (13) Grease: Grease shall conform “JIS K 2220 (Grease)” If the above provision is not applied to the product, it shall be of a quality conforming to a standard similar to the JIS standard. (14) Other lubricating oil: The products to which the Japan Industrial Standard (JIS) applies shall conform to the provisions of the JIS. If the above provision does not apply to the product, it shall be of a quality conforming to a standard similar to the JIS standard. 5. Certification Procedure5. Certification Procedure5. Certification Procedure5. Certification Procedure (1) Regarding environmental criterion 4-1(1), a written self-proclaimed cer-tificate by the plant manager showing the plant's five-year compliance with agreements on environmental regulations and etc. applicable to the area in which the plant is located shall be submitted. (2) Regarding environmental criterion 4-1(2), the MSDS issued by the manu-facturer shall be submitted. (3) Regarding environmental criteria 4-1(3), (4), (5), lists indicating whether the corresponding substances are added shall be submitted. (4) Regarding environmental criterion 4-1(6), the type of base oil shall be re-ported. If base oil prescribed in 4-1(6) is used, documents certifying that the base oil is not carcinogenic in accordance with OSHA HCS and the results of

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the IP346 test (measuring method of polycyclic aromatic in oil residue not containing unused lubricating base oil and asphaltene-dimethylsulfoxide ex-tract refraction rate method), DMSO (dimethylsulfoxide extract amount) shall be submitted. (6) Regarding environmental criterion 4-1(7) and (8), certificates of test re-sults implemented by a third party test organization or public test organiza-tion shall be submitted. (7) Regarding environmental criterion 4-1(9), design samples of labels and containers shall be submitted. (8) Regarding environmental criterion 4-1(11) to (14), lists indicating whether the concerned substances are added shall be submitted. 6. Other Requirements6. Other Requirements6. Other Requirements6. Other Requirements (1) Product categorization shall be done by series of brand (product) for each oil type in (1) to (4) of 2, and not by volume. (2) The following environmental information shall be indicated below the mark. The planned location and details of the Eco Mark to be indicated when applying for Eco Mark product certification shall also be submitted. The environmental information indicated shall consist of three lines aligned to the left and en-closed in a rectangular box, where the first line shall state “ (environmentally degradable oil)” and the second line shall state “ (biodegradability 60% or more in 28 days)”. For the third line, of the test methods prescribed in 4-1-(7), the test method implemented shall be inserted in the form of “ (in ac-cordance with XX test)”. For example, if OECD 301 B was implemented, it shall be indicated as “ (in accordance with OECD 301 B test)”. For grease, the first line shall state “ (envi-ronmentally degradable grease)”. Be sure to indicate the certification number near the Eco Mark. The fol-lowing shows an example.

(3) The eco mark certification number, name of user, and address (or tele-

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phone number) shall be indicated on the eco mark product or pack-age/container with the eco mark. However, if difficult to indicate these due to novelty goods, product with name labeled, or due to lack of space, indicate the eco mark certification number near the eco mark. In this case, be sure to con-firm what to indicate with the Eco Mark Secretariat. (Eco Mark Usage Regu-lations Article 7) (4) The applied product shall as a rule not use fire retardants and antibacte-rial agents. Also “biodegradable plastics” shall not be indicated. However if using or labeling due to special reasons, standards on “fire retardants”, “anti-bacterial agents” and “indication of biodegradable plastics” based on the “Eco Mark Program Guidelines” shall be satisfied. Specifically, indicate whether used in the Eco Mark Product Certification and using Application Form, and if used, attach the separate documents. (Quoted from “A Guide to Eco Mark: ex-clusion clause corresponding to Article 3.7 of “Eco Mark Program Guidelines for Eco Mark Implementation”)

Established: January 10, 2004 (Version2.0) Validity Period: January 9, 2009 These certification criteria and/or the product category will be revised or abolished when deemed necessary.

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Interpretation

Product Certification Criteria forProduct Certification Criteria forProduct Certification Criteria forProduct Certification Criteria for

““““Biodegradable Lubricating Oil Version2.0Biodegradable Lubricating Oil Version2.0Biodegradable Lubricating Oil Version2.0Biodegradable Lubricating Oil Version2.0””””

Established: January 10, 2004 1. Environmental Background1. Environmental Background1. Environmental Background1. Environmental Background Oils such as lubricating oil are widely acknowledged as environmental pollutants, being difficult to collect if leaked into the environment due to its liquid form. According to an investigation by the Japan Lubricating Oil Society, it is estimated that of the 2.09 million kiloliters (excluding grease) of lubricating oil sold in 2001, 1.20 million kiloliters is waste oil. Though the survey did not track the amount of lubricating oil leaked into the environment, it is believed that a considerable amount occurred due to use of open types or accidents. There are “grease” and “the 2 cycle-engine oil” as the typical lubrication oils which are used in the opening system, the 2 cycle-engine which uses the former “2 cycle-engine oil” is light-weight compared with the 4 cycle-engine and has a characteristic that the maintenance and the management are excellent, too. Therefore, it is used for a motorcycle, a mower and a glass cutter etc. in the land business, it is used for the outboard engine etc. on water. However, as 2 cycle-engine oil is usually mixed with gasoline, and partially emitted into the atmosphere and water as non-fuel oil, it poses a major environmental problem, especially in closed water areas. The “Ordinance on Appropriate Use of Shiga Prefecture Lake Biwa for Leisure” enforced in April 2003 prohibits pleasure boats equipped with 2 cycle-engines as the propulsion engine (excluding 2 cycle-engines prescribed in the standards). However, the prefectural government permits the use of 2 cycle-engines in the lake until the end of March 2008 at the latest through transitional measures. Additionally, 2 cycle-engines may continue to be used in water areas where their use is not prohibited by such an ordinance. Therefore, the switch to a 2 cycle-engine oil with high biodegradability and little burden on the environment is significant in the reduction of environmental impact. But also, though the latter “grease”, which is mainly used outdoors, is rarely leaked out in the environment because of its semisolid state at the normal temperature, along with the degradation of the quality (viscosity) by the exposure among long-range, it exerts the influence on the natural environment largely by being mixed with water and soil etc. 2. Applicable Products2. Applicable Products2. Applicable Products2. Applicable Products The classification of the whole lubrication oil is mentioned in “The petroleum product supply and demand dynamic statistic investigation (Designated statistics No. 51 Jan. 2002 Edition)” and this classification has been adopted because it is general

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in the petroleum industry. However, as for the details of “the item (oil species)”, “hydraulic oil”, “2 cycle-engine oil”, “grease” and “other lubrication oil” defined in “the classification of the Japanese standard products” which is published by Management and Coordination Agency in June 1990 along with the above “Designated statistics No. 51” were decided to deal with because of the various classification of each company. Because the necessity to apply lubrication oil using gas is small, sprayer-type lubrication oil was decided to be out of the coverage. 3. Terminology3. Terminology3. Terminology3. Terminology The biodegradability is divided broadly into two types by the degree of degradation. One is primary biodegradability, which is to lose behavior of the material. The other is ultimate biodegradability, which means that organic substance is resolved by the microbe and mineralized. In other words, carbon and hydrogen, which are the composition elements of the organic substance, resolve into carbon dioxide and water respectively. (C CO2, H H2O) It was decided to consider ultimate biodegradability of the latter in this criteria because it was cited as the major area which was given priority that the “lubrication oil itself” leaked in the environment should not exert an influence on the ecology system. LC50 (median lethal concentration) is used in the concept which is the same as LD50 (median lethal dose). The smaller the numerical value of LC50 is, the stronger the toxicity is. Similarly, the level of toxicity of EC50 (50% influence concentration) is conversely proportionate to its numerical value. 4. Certification4. Certification4. Certification4. Certification Criteria Criteria Criteria Criteria 4-1. Environmental criteria For setting up the criteria, environmental impact over the whole life cycle of a products was considered, using Table: Chart for Selecting Environmental Impact at Each Stage of Product Life Cycle. As a result, impact items that are considered to be important to establish criteria for Eco Mark certification were selected in view of environmental impacts over the whole life cycle of the product. For these items, qualitative or quantitative criteria were considered. Environment impact items considered for the category of “Clothes” are as shown in Table: Chart for Selecting Environmental Impact at Each Stage of Product Life Cycle (X in the table). Out of these items were finally selected as the environmental criteria: B-5, B-6, B-7, B-8, C-1, C-8, D-4, and D-8 (XX in the table). The blank columns in the table show items that were out of the scope of review or that were reviewed in combination with other items. Following is the details of establishing the environment-related criteria.

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Table: Chart for Selecting Environmental Impact Items at Each Stage of Product Cycle

Product Life Stage

Environmental Impact Items

A. Re- source Extra- ction

B. Manu- Factu-ring

C. Dis- Tribu- tion

D. Use and Consump- tion

E. Dis- posal

F. Re- cycling

1. Resource Consumption X X XX X X X 2. Discharge of greenhouse

gases X X

3. Discharge of the ozone layer depleting substances X

4. Destruction of ecosystems X XX X 5. Discharge of atmospheric

pollutants XX X

6. Discharge of water pollutants XX X X

7 Discharge/disposal of wastes XX X

8. Use/discharge of hazardous materials XX XX XX X X

9. Other environmental impacts

X

A. A. A. A. Resource Extraction StageResource Extraction StageResource Extraction StageResource Extraction Stage A-1 (Resource consumption) The following points were reviewed under this item:

(1) Resources which can be sustainably produced such as animal and plant oil or synthetic ester produced from animals and plants shall make up more than a uniform percentage of the raw material. (2) Recycled material shall be used.

Point (1) was considered in this product category because some biodegradable lubricating oil products use plant oil or synthetic ester produced from plants and animals as the base oil. However, the inclusion of this point in the criteria was considered difficult for those resources which can be sustainably produced due to the lack of information on the required percentage to ensure biodegradability. In addition, biodegradable lubricating oil made of synthetic ester produced from oil chemical products or PAG (polyalkylene glycol) are presently widely available. Therefore this item was not selected as a criterion. For (2), since the material recycling of lubricating oil is currently not carried out, there were comments that this item should be included in the criteria as a strategy to

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promote recycling. However, considering that quality problems may occur in the mixing of recycled mineral oil with biodegradable lubricating oil and that sizeable costs are incurred in the separation of additives, this item was eventually not selected as a criterion. A-4 (Destruction of Eco Systems) The following points were reviewed under this item:

(1) Exotic animal and plant species shall not be used as a raw material (2) Gene-recombinant products shall not be used as a raw material

For (1), since most plant oil raw materials are imported, it is not realistic to prohibit the use of exotic species. Consequently, this item was not selected as a criterion. For (2), it is not possible to survey whether imported plant oil raw materials are gene-recombinant products. In addition, since no methods exist for evaluating the influence of genetically engineered products on the ecosystem, this item was not selected as a criterion. B. Manufacturing StageB. Manufacturing StageB. Manufacturing StageB. Manufacturing Stage B-1 (Resource consumption) The following point was reviewed under this item:

(1) Resources and energies such as sub-raw materials and water resources shall not be consumed as much as possible when manufacturing.

For (1), the raw material for the base oil of lubricating oils made of petrochemical products is manufactured together with other oil products in plants as a co-product. This makes it difficult to evaluate the consumption of resources and energy in the manufacturing stage. For this reason, this item was not selected as a criterion. B-5 (Exhaust of air pollutants) The following point was reviewed under this item: (1) Air pollutants shall not be exhausted when manufacturing. Because Air Pollution Control Law should be conformed to when manufacturing, this point was selected as the item to establish criteria. B-6 (Discharge of Water Contaminants) The following point was reviewed under this item:

(1) Water contaminants shall not be discharged when manufacturing.

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Because Water Pollution Control Law should be conformed to when manufacturing, this point was selected as the item to establish criteria. B-7 (Discharge/disposal of wastes) The following point was reviewed under this item:

(1) Low discharge of wastes during manufacturing

Considering the need for observance of laws on the disposal and cleaning of wastes during manufacturing, this item was selected as a criterion. B-8 (Use and Discharge of Hazardous Materials) The following points were reviewed under this item:

(1) Observance of the PRTR law on the supply of MSDS, etc. (2) Observance of related environmental laws and pollution control agreements. (3) No harmful substances shall be used during manufacturing.

Regarding (1)-(2), generally the above laws are obviously observed, but because it was deemed better to verify these laws in Eco Mark certification, this item was selected as a criterion. Regarding (3), EDTA and nonylphenol surfactants were again reviewed in continuation from Version1.0. In certain EDTAs, their derivatives can be used as antioxidants, and poly (oxyethylene) = alkylphenol ethoxylates such as nonylphenyl ether, etc. can be added to lubricants as non-ionic surfactants for anti-emulsifying agents. EDTAs have adverse effects on human health by causing respiratory disorders, etc. Difficult to break down, they tend to accumulate in the environment, and are therefore prohibited from use by criteria for paper, detergents in overseas eco labels such as the German Blue Angel. It was thus decided that the use of EDTAs should be prohibited as in the Version 1.0. On the other hand, alkylphenol ethoxylates are known to break down in the environment, and generate alkylphenol. Alkylphenols whose number of carbon atoms attached to the alkyl group are 5 to 9,including nonylphenol, were listed as substances suspected of having endocrine disrupting effects in Ministry of the Environment’s “Strategic Programs on Environmental Endocrine Disruptors SPEED ’98”. Alkylphenol ethoxylates whose number of carbon atoms attached to the alkyl group are 5 to 9 are considered to break down in the environment into these alkylphenols listed. In particular, poly (oxyethylene)=nonylphenyl ether is the most frequently used surfactants amongst alkylphenol ethoxylates, and breaks down when discharged into water areas, producing nonylphenol. This nonylphenol is listed as a substance suspected of having endocrine disrupting effects in the “Strategic Programs on Environmental Endocrine Disruptors SPEED ’98” and has been studied since 2000

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as a substance requiring prior risk assessment. The Nordic Swan also prohibits the use of alkylphenol ethoxylates in criteria for lubricants. For these reasons, in addition to nonylphenol surfactants, it has been decided that alkylphenol ethoxylates whose number of carbon atoms attached to the alkyl group are 5 to 9 will be prohibited from use as a more comprehensive attempt. Since October 2003, the Ministry of the Environment has considered revisions of the “Strategic Programs on Environmental Endocrine Disruptors SPEED ‘98”. If new findings are acquired in the future, this criteria shall be reviewed. For other harmful substances, substances designated as Class 1 chemical substances of the PRTR Law are used as components in certain lubricants. Currently, though it is technically difficult to prohibit use of all these substances, in the future, switch to substances with equivalent functions but lower environment burden is desirable. It was therefore decided that in the use of these substances as components, it shall be reported that they are designated Class 1 chemical substances of the PRTR Law. The PRTR Law that prescribes products containing less than 1% of the concerned chemical substances (less than 0.1% for the designated Class 1 chemical substances) shall not be subject to MSDS. However, substances comprised of 1% or more in base oils and additives shall be reported regardless of the content rate in products. Implementation of toxic tests for D-4 was also reviewed. C. Distribution StageC. Distribution StageC. Distribution StageC. Distribution Stage C-1 (Resource Consumption) The following points were reviewed under this item:

(1) Containers and packaging shall give consideration to resource consumption. (2) The packaging shall be able to be used repeatedly. (3) Outer casings shall be made of recycled material.

For (1) and (2), most lubricating oil containers in Japan are made of steel and recycled. In addition, since plastic is widely used in bellows containers for grease and import containers, their inclusion in this product category was accepted. However, since plastic containers are difficult to recycle due to the adhesion of oil and other problems, their use should be limited to one time. In consideration of resource consumption, though promoting the use of recycled materials for these containers is essential, it should be difficult to establish standards for them taking into account quality requirements on durability, etc. and the current situation of plastic containers using recycled materials available on the market. In addition, given that plastic containers are repeatedly used for lubricating oils bottled from larger containers, this item was not selected as a criterion. For (3), outer casings are rarely used, and those used are usually made of recycled materials, therefore this item was not selected as a criterion. C-2 (Discharge of greenhouse gases) The following point was reviewed under this item:

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(1) Joint delivery and modal shift shall be implemented.

Since (1) is obviously implemented by manufacturers, no special criterion was deemed necessary. C-8 (Use/discharge of hazardous materials) The following point was reviewed under this item:

(1) Use of hazardous materials for containers and packaging shall be controlled, and discharge shall be minimum.

For (1), since plastic containers are often subject to thermal recycling or incineration, there is a need to take into account the discharge of hazardous materials in incineration. Consequently, this item was selected as a criterion. D. Use and Consumption StageD. Use and Consumption StageD. Use and Consumption StageD. Use and Consumption Stage D-1 (Resource consumption) The following point was reviewed under this item:

(1) The product shall be designed for a long life cycle in order to ensure a long consumption cycle.

Point (1) was considered difficult to establish as a criterion due to the difficulty in defining long life-cycle, and the absence of objective test methods. Thus it was not selected as a criterion. D-2 (Discharge of greenhouse gases) The following points were reviewed under this item:

(1) The fossil fuel consumption shall be less than that of the other products which have an identical function. (2) The criteria about the discharge of greenhouse gases in the burning shall be furnished.

Regarding (1) and (2), these points were not selected as the items to establish criteria because it is difficult to establish a criterion about consumption of energy and fossil fuel, the discharge of greenhouse gases and make the manufacturer guarantee it when burned. D-3 (Discharge of the ozone layer depleting substances) The following point was reviewed under this item:

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(1) No discharge of chlorofluorocarbon compounds

For (1), the use of fluorine additives was reviewed. However, considering that use reduces biodegradability and fluorine additives can only be used for lubricating oils for special purposes that require high performance, this item would never be added to biodegradable lubricating oil. Thus it was decided that no special criteria are needed for this item. D-4 (Destruction of eco systems) The following point was reviewed under this item:

(1) By having low toxicity on the ecosystem and biodegradability, it shall not affect the ecosystem during use and leakage.

As for (1), it was decided to adopt a biodegradability examination and a toxicity examination to the index which evaluates an ecology influence. The OECD301B and 301C adopted as biodegradable tests in Version 1.0 are intended to determine products which are readily biodegrade based on rigid test conditions. According to the definition of OECD, products which pass these tests are considered to be readily biodegradable, and are thought to decompose promptly in actual aerobic water environments. It has been pointed out that reproducibility is poor when these tests are implemented on lubricating oils with poor dispersal in water, and the switch to inherent biodegradability tests such as OECD302 B or C, which is based on more moderate test conditions or extension of the test duration, were reviewed. However, due to the need to consider the speed of dispersal into water and biodegradability when impact on aquatic organisms are taken into account, tests to determine products which are readily biodegradable such as OECD301C were again adopted in Version2.0. Since the principle of these tests is the same as OECD301C, OECD301F and ASTM D6731 were also adopted. The pass level was set at 60%, in accordance with the following criteria: criteria on hydraulic oil ISO15380 (lubricating oil, industrial lubricating oil (industrial oil), and related products (Class L) –H series (hydraulic systems)-categories HETG, HEPG, HEES, and HEPR) and OECD. Though OECD301B prescribes the 10-d window measurement, final biodegradation (within 28 days) was adequate here, and as with Version 1.0, it was not adopted in Version 2.0. For toxicity, fishery acute toxicity tests were adopted following Version 1.0 in accordance with the JIS “Testing methods for industrial wastewater (JIS K0102)” and OECD203. Furthermore, the need to observe the impact on lower organisms in the ecosystem was pointed out, and considering that the test for determination of the inhibition of the mobility of Daphnia by chemicals and multiplication is prescribed in the Eco Operating Oil Standard ISO15380, its adoption was reviewed. As a national policy, the basic environment plan established in December 2000 focuses on giving

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consideration to the ecosystem through the preservation of the water environment and countermeasures for chemical substances, and promotes toxicity evaluation tests of present chemical substances for types of seaweed, daphnia, and fish to obtain basic data. In the partially revised Law Concerning the Examination and Regulation of Manufacture, etc. of Chemical Substances issued in May 2003, the influence of chemical substances on animals and plants was also prescribed. Due to these reasons, fishery acute toxicity tests were added to Version 2.0, and test for determination of the inhibition of the mobility of Daphnia by chemicals and multiplication was also considered for adoption. Considering that there exist no cases of daphnia toxicity tests implemented on oils at this point in the country, test methods are currently being reviewed according to the above law. However, owing to such reasons as the need to determine the outcome of this review, and the time required for developing substitute products cannot be forecast as yet, it was decided that the daphnia mobility inhibition test shall not apply as of this point. Regarding the starting time of application, it shall continue to be reviewed while observing the trends of the above law. Accurate evaluation of toxicity may not be possible with this test because lubricating oil has a large physical inhibition impact on daphnia. Tests using liquid extracts of only soluble components were therefore approved. The test time was set at 48 hours in accordance with the ISO15380 criteria. D-6 (Discharge of water contaminants) The following points were reviewed under this item:

(1) Water contaminants shall not be discharged. (2) When slipped in the environment during use, influence to water quality shall be scarcely exerted.

As for (1)-(2), they were decided to consider in D-4. D-8 (Use and discharge of hazardous materials) The following points were reviewed under this item:

(1) Low discharge of dioxins by burning during use (no chlorinated additive shall be contained)

(2) Low generation of polycyclic aromatic hydrocarbons (PAHs) (3) MSDS shall be provided (4) Cautions to users shall be labeled

For (1), since chlorinated lubricating oils may discharge dioxins when burnt after use, etc. efforts are currently being made to avoid industrial use. In the criteria on cutting fluid JIS K2241-01, products using chlorinated additives were excluded in the December 2000 revision. However, these products are still available on the market, and for the purpose of promoting the anti-chlorination trends, the prohibition of chlorinated additives was selected as a criterion.

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Point (2) was reviewed from the viewpoint of whether it is carcinogenic. Vegetable oil, synthetic esters and PAG used as the base oil of biodegradable lubricating oil, are thought to contain no PAH. However due to the future possibility that the base oil of biodegradable lubricating oils may be made of mineral oil, this item was selected as a criterion. In the EU Directive 94/69/EC (laws, regulations, and administrative standards on classification, packaging, and labeling of hazardous substances, corresponding protocols for 21st technical adaptation in directive 67/548/EEC), compounds containing the three condensed aromatic rings or more; aromatic hydrocarbons, sulfurs, and nitrogen compounds were defined as PCAs (polycyclic aromatic) requiring the establishment of laws on determing whether oil products are carcinogenic from the amount of DMSO (dimethyl sulphoxide) extracted by the IP346 method, a method of measuring PCAs, and prescribes that oil products containing less than 3% mass of DMSO shall not be considered as cancerous substances. Moreover, in OSHA HCS, hazard warning criteria were set down based on the severity of the petroleum processing, and petroleum products not corresponding to these criteria were considered carcinogenic. In Japan, no laws or regulations on carcinogenic properties exist. In the petroleum industry, since voluntary efforts have been made by the Petroleum Association of Japan and other organizations to ensure compliance with the hazard warning criteria of OSHA HCS and the EU Directive, this item was selected as a criterion. For (3), the provision of MSDS is required in the transfer and sales of commercial lubricating oil based on the PRTR law, but not in sales to general consumers. However, since MSDS should be provided when requested by consumers, this item was selected as a criterion. For (4), most petroleum products already conform to the PL (Product Liability) Law, and corresponding warnings are labeled on containers or products. These are labeled under the responsibility of manufacturers and sales distributors, and widely used as a means of calling users to practice caution in use and disposal. However, since environmental influence cannot be completely denied for biodegradable lubricating oil depending on use, it was argued that users must be further reminded of the need for appropriate disposal. The addition of cautions on the handling and disposal of biodegradable lubricating oil to warning labels was therefore selected as a criterion. For grease contained in bellows containers, due to the difficulty in labeling each container, those manufacturers shipping products in outer casings shall be asked to label on the outer casings. D-9 (Other environmental impacts) The following points were reviewed under this item:

(1) Products shall not be intended for 2 cycle-engine use. (2) Products shall not be for leisure purposes.

For (1)-(2), because 2 cycle-engines discharge unburnt fuel and oil due to their

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structure, use in closed water areas can incur enormous impact on aquatic organisms. The “Ordinance on Appropriate Use of Shiga Prefecture Lake Biwa for Leisure” issued in October 2002 prohibits pleasure boats equipped with 2 cycle-engines as the propulsion engine from cruising water areas. There were opinions that it would be inappropriate to label the Eco Mark on products for the 2 cycle-engine, considering the need to promote a transfer to the 4 cycle-engine, which has less environmental burden in terms of discharge of volatile organic compounds, etc. However, excluding 2 cycle-engines oils from the Eco Mark products does not mean that 2 cycle-engines would not be used; on the contrary, the absence of guidelines may lead to increased environmental burden, and no objective data that 4 cycle-engines have lower environmental burden than 2 cycle-engines exist. Therefore, it was decided that the inclusion of 2 cycle-engines would remain in Version2.0. E. Disposal StageE. Disposal StageE. Disposal StageE. Disposal Stage E-1 (Resource consumption) The following point was reviewed under this item:

(1) The system of waste oil collecting and processing shall be furnished. For the recovery, processing, and recycling of waste oil, efforts are being by the whole industry for appropriate disposal, separation of chlorinated and non-chlorinated lubricating oil by outsourcing to members of the National Oil Recycling Joint Union. In addition, since information to promote user awareness is also distributed through pamphlets, etc., no special criteria were considered required for this item. E-2 (Discharge of greenhouse gases) The following point was reviewed under this item:

(1) The criteria about the discharge of greenhouse gases in the incineration disposal shall be furnished.

For (1), since outsourcing to appropriate businesses is being promoted, and disposal at incineration sites is strictly controlled by the Air Pollution Control Law, etc no special criteria were considered required for this item. E-4 (Destruction of eco systems) The following points were reviewed under this item:

(1) Disposed in form with low risk of leakage to soil and hydrosphere (2) Minimum influence in the event of illegal disposal

As for (1), they were decided to consider in E-1, E-2. As for (2), they were decided to consider in D-4.

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E-5 (Exhaust of air pollutants) The following point was reviewed under this item:

(1) Air pollutants shall not be exhausted when incinerated. As for (1), they were decided to consider in D-4. E-6 (Discharge of water contaminants) The following point was reviewed under this item:

(1) Minimum influence in the event of illegal disposal As for (1), they were decided to consider in D-4. E-7 (Discharge and disposal of wastes) The following points were reviewed under this item:

(1) Recovery system is available. (2) Disposal shall cause minimum burden to the environment.

As for (1)(2), they were decided to consider in E-1, E-2. E-8 (Use and discharge of hazardous materials) The following points were reviewed under this item:

(1) No discharge of hazardous materials (2) Related environmental laws and pollution control agreements shall be observed.

For (1), though dioxins may be generated in incineration, it was decided in D-8 that this item shall be incorporated as a criterion to prohibit the use of chlorinated additives. For products already available on the market, as reviewed in E-1 and E-2, separation of chlorinated and non-chlorinated products shall be promoted by the industry. As for (2), they were decided to consider in B-8. F. Recycling stageF. Recycling stageF. Recycling stageF. Recycling stage F-1 (Resource consumption) The following points were reviewed under this item:

(1) Waste oil recovery and recycling systems shall be made available. (2) Efficient recycling method shall be developed.

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As for (1) (2), they were decided to consider in E-1. F-8 (Use and discharge of hazardous materials) The following point was reviewed under this item:

(1) Non-generation of dioxins For (1), since lubricating oil is mainly recycled by thermal recycling, dioxins may be generated during recycling. The prohibition of chlorinated additives was therefore selected as a criterion in D-8. For products already available on the market, as reviewed in E-1 and E-2, separation of chlorinated and non-chlorinated products shall be promoted by the industry. 4-2 Quality criteria (1) When domestic standards were set (e.g. JIS), it was decided to follow the standards in order to secure the minimum quality level according to ISO 14024. Also, when domestic standards were not set, it was decided to secure the quality equal to the similar standard to promote the spread of the Eco Mark products. (2) Automobile standard “lubrication oil for 2 cycle gasoline engine, JASO M345-93” of 2 cycle-engine oil was revised in March 2003. According to the modified JASO M345: 2002, the former FA was discontinued, with the three grades FB, FC, and FD remaining. The FC grade after modification is equivalent to the former quality criteria. As with the Version1.0, quality grade of the products in this category should be limited to those above FC in the aim to reduce environmental burden by exhaust smoke performance. Although Version1.0 adopted NMA TC-W, TC-WII, and TC-W3, it was decided that Version2.0 will adopt only the latest standard, TC-W3. 5. Others5. Others5. Others5. Others (1) On display in the lower column of Eco Mark In Version1.0, only “biodegradable oil” and “biodegradable grease” were displayed. In Version2.0, it was decided that the test method used and test results shall be indicated taking into consideration the significance in providing accurate and quantitative information to users. According to the definition of OECD, the test method adopted in this product category considers products to be easily biodegradable if they biodegrade by 60% or more within 28 days. For this reason, it was decided that the second line shall indicate “biodegradability of 60% or more in 28 days”, and not individual values obtained from tests. Since most consumers are not familiar with test methods and results, it was decided that the first line shall indicate “environmentally biodegradable oil”.

21

Company seal <Preparing Attached Certificates> 1. Indicate details of the product under application for certification in ”Fill in this Column.”

Shaded areas in “Fill in this Column” do not require entry. 2. Prepare yourself or have other interests prepare the certificates specified in “Documents to

be Submitted.” Submit these certificates with this document when applying for Eco Mark Product certification or use.

3. Prepare certificates referring to the examples provided. 4. The issuer(s) in the ”Issued by” column must prepare “Documents to be Submitted.”

Item Fill in this Column Documents to be Submitted

Issued by

Classification of Product Applied

< > Hydraulic oil < > 2 cycle-engine oil < > grease < > Other lubricating oil (Purpose: )

(Select where appropriate)

Type of base oil (select all of several types if

they are used blended)

< > Vegetable oil < > Synthetic ester

(Made from vegetable oil) < > Synthetic ester

(Petrochemical product) < > polyalkylene glycol < > Mineral oil < > Others

( ) (Select where appropriate)

Product pamphlet, etc. Applicant

Manufacturer of product

< > Other companies < > Own company

(Select where appropriate)

If developed by other companies,

attach Application Consent Form.

Lubricating oil manufacturer

6.(2) Display of intended location of Eco Mark, display of

environment information below mark, display of

certification number

6.(3) Display of Eco Mark user name and address (Article 7 of Usage Regulations)

Design drawing to be provided

(Format free, text) Applicant

No.110 Version2.0

Attached Certificate

22

4-1Certification Criteria

Item Fill in this Column Documents to be Submitted

Issued by

4-1.(1) Environmental laws

and regulations Certification

Example 2

Manager of final

manufacturing plant

4-1.(2) Chemical substances MSDS Manufacturer

Use of EDTA < > Used/< > Not used

4-1.(3) Chemical substances Use of

alkylphenol ethoxylates （alkyl group carbon number: 5 to 9）

< > Used/< > Not used

This document

4-1.(4) Use of PRTR Law Class 1

designated chemical substance

< > Used/< > Not used If “Used”, submit

list of corresponding

additives Manufacturer

4-1.(5) Chlorinated additives not used < > Used/< > Not used This document Applicant

4-1.(6) Not classified as carcinogenic by

OSHA HCS and EC Directives.

Corresponding mineral oil shall not be classified as carcinogenic by OSHA HCS as

well as EU Directive (dimethylsulfoxide extract amount in oil shall be less than

3%). < > Complies/ < > Does not comply

< > Not applicable

Documents certifying

non-carcinogenic in accordance with

OSHA HCS and IP346 test results.

Third party test

organization or in-house test

Biodegradation test method

< > OECD 301B < > OECD 301C/ < > ASTM D5864 < > OECD 301F/ < > ASTM D6731

* Please check

4-1.(7) Biodegradability

Biodegradability is ( )% in 28 days

Certificate of results of tests by

third party organization (any one test method indicated on the

left).

Third party or public

organization

Attached Certificate

23

Fishery acute toxicity test method

< > JIS K 0102 / < > OECD 203 < > JIS K 0420-71 series

(10,20,30) * Please check

4-1.(8) Impact on ecosystem (Fishery

acute toxicity)

96 hour LC50 value of acute toxic tests ( )mg/L or above

Test certificate (any one test

method on the left).

Third party or public

organization

4-1.(9) Rousing caution to handling

and disposal of product

Product handling, and disposal precautions shall be indicated on MSDS

and container or label (PL label). < > Indicated / < > Not indicated

Submission of design sample of label or container

Applicant

4-1.(10) Container/packaging

Containers containing resins composed of halogens and halogenides as constituents

shall not be used. < > Complies / < > Does not comply

Type and material of packaging container

( ) Packaging method

( )

This document Applicant

4-2 Quality Criteria

Item Fill in this Column Documents to be Submitted

Certifying Entity

4-2. (11) to (14) Product quality

Are there corresponding quality criteria such as JIS, etc. < > Yes

(Name: )

< > Other similar criteria (Name: )

Documents certifying

conformance to corresponding

quality criteria or similar quality

criteria

Applicant or third party

24

Example 1 Date Mr./Ms. Eco Mark Office Japan Environmental Association

XXXXX XXXXX Company name Seal

*Issuer: Applicant

Approval of Eco Mark Use Application

This is to consent to the application for Eco Mark certification and use of XXX (your company name) (Eco Mark certified) brand name XXXX (certification no. XX) by XXX (applicant) as brand name XXXX.

Issuer ofcertificate

Date of issue of this certificate

Address to send this certificate

25

Example 2 Date Mr./Ms. Division/Department Company

XXXXX XXXXX Manager Name Plant Name Plant Seal

Compliance CertificateCompliance CertificateCompliance CertificateCompliance Certificate

This is to certify that XXX (the company handling the final manufacturing process of the product under application) has observed the following in the manufacturing process of ZZZ (name of product under application). 1. Observed environmental laws and regulations pertaining to air pollution, water pollution, noise, vibration, odor, and emission of harmful substances, as well pollution control agreements in the manufacturing process of the product for a period of xx years(*) until the date of application. Examples of related laws and regulations Air Pollution Control Law Water Pollution Control Law Noise Regulation Law Vibration Regulation Law Offensive Odor Control Law XX Prefecture XX Environmental Protection Ordinance XX City Agreement on Pollution Prevention 2. Observed laws and regulations on handling of chemical substances such as Poisonous and Deleterious Substances Control Law and the Law Concerning the Examination and Regulation of Manufacture, etc. of Chemical Substances for a period of xx years(*) until the date of application. (*) Otherwise, provide a statement indicating no laws and regulations have been violated since establishment of company. Indicate that the issuer is the plant manager or someone in an executive position equivalent

Date of issue of this certificate

Indicate laws applicable to plant

Indicate local regulations and agreements of district in which plant is located, if any.

Address to send this certificate: If applicant is manufacturer, address to:

Eco Mark Secretariat Director Japan Environment Association

If applicant is not manufacturer, address to: Applicant

Issuer of certificate

26

Example 3 Date Mr./Ms. Eco Mark Office Japan Environmental Association

XXXXX XXXXX Company name Seal

*Issuer: Applicant

Report on Use of Class 1 Substances of PRTR Law This is to report that the product XXX (name of the product under application) contains, as constituents, the following substances listed as Class 1 Substances specified by the Law Concerning Reporting, etc. of Release to the Environment of Specific Chemical Substances and Promoting Improvements in Their Management (PRTR law).

Substance CAS No.

Address to send this certificate: If applicant is manufacturer, address to:

Eco Mark Secretariat Director Japan Environment Association

If applicant is not manufacturer, address to: Applicant

Issuer ofcertificate

Date of issue of this certificate