Europe's lubricants trade body, UEIL, is urgently lobbying EU legislators to change the terms of EMCS legislation.
The organisation has written to the European Commission, as summarised in its latest member Bulletin, in an effort to change both taxation and movement regulations. The UEIL believes the inclusion of lubricant additives into the Excise Movement and Control System (EMCS) was an unintended consequence of the new legislation.
The electronic EMCS will need to be implemented by all EU states from July 2012 onwards and currently includes lubricant additives (CN 3811) in the Control and Movement section of the existing Energy Taxation Directive.
However, the UEIL has noted that lubricant additives, none of which are subject to duty under the Directive, remain included in the Directive and EMCS schedule. While recognising that this has been an unintentional oversight by the legislation committee and the EU states, the UEIL estimates that, if enforced, the legislation could cost European lubes distributors as much as €15-20m in additional time and resource.