EAL Lubricants: How to Formulate Environmentally Acceptable Greases and Oils

Environmentally Acceptable Lubricants (EALs) are required on commercial vessels in US and EU waters, near waterways and ecologically sensitive areas, and increasingly in forestry and offshore applications. For formulators developing EAL-compliant products, the additive package is often the most difficult component to qualify.

What Defines an EAL Additive?

The EPA Vessel General Permit (VGP) and the EU Ecolabel define EAL criteria around three core properties:

  • Biodegradability: Readily biodegradable (>60% in 28 days, OECD 301B) or inherently biodegradable (>20% in 28 days)
  • Non-bioaccumulation: Low octanol-water partition coefficient (log Kow < 3) or high molecular weight (>700 g/mol)
  • Low aquatic toxicity: LC50/EC50 > 100 mg/L in standard fish, daphnia, and algae tests

Traditional EP additives — chlorinated paraffins, ZDDP, sulfurized fatty acids — fail one or more of these criteria. Finding HX1-certified additives that are also EAL-compliant is particularly challenging for food-grade marine lubricant formulators.

Desilube EAL-Certified Grades

Desilube 88, 98F, and 99FEL are registered on the EU LuSC list (Lubricant Substance Classification list), confirming their EAL-suitability under European standards. They are also EPA VGP-compliant as EAL additive components. This makes them uniquely positioned as both NSF HX1-certified and EAL-certified EP/AW additives — suitable for food-grade marine vessel lubricants (stern tube, thruster, deck equipment) that must meet both food safety and environmental requirements simultaneously.

Desilube AEP — The Bio-Based Option

For formulators seeking the most sustainable additive profile, Desilube AEP is a lignin-derived EP additive — naturally occurring, non-toxic, and fully biodegradable. It provides EP and antioxidant performance while qualifying under the strictest bio-based content requirements of EU Ecolabel and Nordic Swan certifications. Used at 1–15% in bio-based ester or PAG base fluids, it enables fully renewable EAL formulations with strong EP performance.

Contact Desilube Inc. for EAL certification documentation and technical support: desilubeinc.com/contact

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