Metalworking Fluids and REACH: How to Ensure Legislative Compliance and Safety in Production

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Metalworking fluids are an essential part of modern metal processing, but their use is subject to strict legislative requirements. The REACH and CLP/GHS regulations set rules for the registration, classification, and labelling of chemical substances, including additives and mixtures used in metalworking fluids. For manufacturers and buyers, it is crucial not only to select a technically suitable product but also to ensure its legislative compliance and safe handling. Incorrect interpretation of safety data sheets (SDS) or failure to comply with labelling requirements can lead to fines, operational risks, or unnecessary costs for alternative solutions. This article explains how to navigate the legislation and what to specifically monitor when selecting and using metalworking fluids.

REACH and metalworking fluids: Basic obligations of manufacturers and users

Metalworking fluids, whether emulsions, synthetic, or semi-synthetic mixtures, fall under the REACH regulation as chemical mixtures. This means that every substance contained in the fluid at a concentration above 0.1% must be registered with the European Chemicals Agency (ECHA) if its annual volume exceeds one tonne. Manufacturers and importers of fluids are obliged to ensure the registration of all relevant components, while users – i.e., manufacturing companies – must verify that the supplier has fulfilled this obligation. Without valid registration, metalworking fluids cannot be legally used or supplied on the EU market.

In addition to registration, risk assessment and communication within the supply chain are also crucial. Fluid manufacturers must provide Safety Data Sheets (SDS) in accordance with the CLP regulation, which include information on classification, labelling, and safe handling. Users must then incorporate this information into their internal processes, such as employee training or the implementation of protective measures. Furthermore, REACH requires that substances of very high concern (SVHC), which may be present in fluids even at lower concentrations, are also monitored.

Classification and Labelling According to CLP/GHS: How to Read Safety Data Sheets

Safety Data Sheets (SDS) for metalworking fluids must be prepared in accordance with the CLP regulation, which implements the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). This means that each fluid must be classified according to its hazardous properties – for example, skin irritation, aquatic toxicity, or flammability. The classification is reflected in warning symbols, signal words ("Danger" or "Warning"), and standardized hazard statements (H-phrases) and safety instructions (P-phrases).

For users of liquids, it is crucial to correctly interpret this information. For example, a liquid marked with the "corrosive" symbol requires the use of protective gloves and goggles, while a liquid with the H412 statement ("Harmful to aquatic life with long-lasting effects") must be disposed of as hazardous waste. Safety data sheets also contain instructions for first aid, fire-fighting, and spill handling, which must be followed. Regular updates to SDS are mandatory – suppliers must inform about changes in classification or new risks.

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Safety documentation and internal processes: How to ensure compliance in production

Legislative compliance in the field of metalworking fluids does not end with safety data sheets. Manufacturing companies must have internal processes in place for chemical management, including records of fluids used, employee training, and regular inspections. The foundation is the creation of an internal chemical register, where all fluids used are recorded, including their SDS and classification. This register serves as a basis for workplace risk assessments and for potential inspections by labour or environmental authorities.

An important part of the documentation is also the work procedures for handling fluids. These should include instructions for storage (e.g., separately from food or flammable materials), the use of personal protective equipment (PPE), and procedures in case of spills or accidents. Employees must be regularly trained in chemical safety, and the training should be documented. If there are changes in fluid composition or new legislative requirements, processes must be updated and staff retrained.

Replacement of hazardous substances and sustainable alternatives in metalworking fluids

REACH and other legislation are pushing manufacturers and users of metalworking fluids to gradually replace hazardous substances with less risky alternatives. Typical examples include borates, formaldehyde releasers, or certain chlorinated paraffins, which were commonly used in the past as additives to improve lubricity or corrosion protection. These substances are now often included on the SVHC list or have restricted use. Fluid manufacturers are therefore seeking replacements, such as those based on vegetable oils, synthetic esters, or boron-free corrosion inhibitors.

However, when selecting alternatives, it is essential to consider not only legislative requirements but also technical performance. For example, plant-based fluids may be more environmentally friendly, but they often have lower stability at high temperatures or poorer resistance to microbial contamination. Users should collaborate with suppliers to test new fluids under real-world conditions and verify whether they meet machining quality requirements, tool longevity, and employee health protection. A long-term sustainable solution requires a balanced approach between regulatory compliance, safety, and technical efficiency.

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Monitoring exposure and protecting employee health when working with metalworking fluids

Metalworking fluids, particularly those based on mineral oils or synthetic mixtures, may contain substances with potentially harmful effects on health. The most common risks include skin irritation, respiratory tract irritation, or long-term effects from repeated exposure. Under the REACH regulation, employers are required to ensure regular monitoring of the working environment to ensure that concentrations of hazardous substances do not exceed the established limits. This includes measuring aerosols, vapours, or contact substances using standard methods that comply with applicable hygiene standards.

Personal protective equipment (PPE) also plays a key role. Employees should be equipped with appropriate gloves, protective goggles, and respirators where necessary. Training employees on the correct use of PPE and handling of fluids, including procedures for spills or contamination, is essential. Regular inspection of fluid condition and replacement according to the manufacturer’s recommendations helps minimise the risk of contamination and degradation, which can increase toxicity.

Management of Waste Metalworking Fluids and Environmental Requirements

Waste metalworking fluids are classified as hazardous waste, and their disposal is subject to strict legislative requirements. According to current regulations, fluids must be collected in sealed containers with clear labelling and handed over to specialised companies for recycling or environmentally safe disposal. Mixing different types of fluids or discharging them into the sewage system is prohibited and may result in severe penalties.

To reduce environmental impact, it is recommended to use fluids with a longer lifespan or biodegradable alternatives. Modern filtration and fluid treatment systems enable their repeated use, which reduces waste volume and disposal costs. It is also important to maintain records of the quantity and type of fluids disposed of to demonstrate compliance with regulations during potential inspections.

Digital Tools for Managing Safety Documentation and REACH Compliance

Managing Safety Data Sheets (SDS) and REACH-related documentation can be challenging for manufacturing companies, especially if they work with dozens of different machining fluids. Digital tools, such as specialized software for chemical management, allow centralized storage and easy access to up-to-date versions of SDS, certificates, and training records. These systems often include automatic notifications for upcoming deadlines for document updates or fluid revisions.

Another advantage is the possibility of integration with internal quality management and occupational safety systems. For example, when the composition of a fluid changes, the software can automatically update risk assessments or employee instructions. This not only saves time but also minimizes the risk of errors caused by human factors. For companies with multiple production sites, data synchronization across all locations is key to ensuring a uniform level of compliance.

Do you have questions about legislative compliance?

GCG Group provides up-to-date Safety Data Sheets (SDS) and technical documentation for every supplied raw material in accordance with REACH and CLP. Our experts will advise you on selecting machining fluids that meet both the technical and legislative requirements of your production. Contact us – or browse our catalog of over 1,300 products right away.