EU lithium salt classification: what it means for lithium grease

This analysis covers EU CLP, REACH and worker protection rules as they apply to lithium carbonate, chloride and hydroxide used to make grease thickeners, and to finished lithium greases sold in the EU. It does not cover GB CLP in Great Britain, US OSHA hazard communication, other jurisdictions or battery uses, and it is not legal advice for a specific product.

What is changing for lithium salts under EU CLP, and when?

Under EU CLP, Regulation (EC) No 1272/2008, the change for lithium salts is a new harmonised entry in Annex VI that classifies lithium carbonate, lithium chloride and lithium hydroxide as Repr. 1A with hazard statement H360FD and as Lact. with H362, with pictogram GHS08 and signal word Danger (European Commission, draft 24th ATP annex, 2025). The Commission describes the classification as category 1A for effects on foetal development and category 1B for effects on male fertility (European Union, WTO reply, 2026). ANSES, which proposed the entry, summarised the label as "May damage fertility or the unborn child: Category 1A (H360FD)" (ANSES, 2020).

The entry sits in the draft 24th adaptation to technical progress (ATP) of CLP. Article 2 of the draft sets the timing: "This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union." It then applies from the first day of the month following 18 months from entry into force, and suppliers may apply the new classification voluntarily from entry into force (European Commission, draft 24th ATP, 2025).

As an illustrative example, publication on 1 December 2026 would mean entry into force on 21 December 2026 and application from 1 July 2028. Real dates depend on the Official Journal. Until the application date, this entry creates no legal duty in the EU to label lithium salts or lithium greases as Repr. 1A.

What is the status of the CLP classification of lithium carbonate, hydroxide and chloride?

Status as of 14 October 2026: the CLP classification of lithium carbonate, hydroxide and chloride is proposed, confirmed twice by the ECHA Risk Assessment Committee (RAC) and backed by the Commission, but not published in the Official Journal or in force in the EU. In replies to WTO members signed on 3 July 2026, the EU stated that it had concluded the proposed classification of the lithium salts is appropriate and that it "is currently in the process of adopting the Commission Delegated Regulation" (European Union, WTO reply, 2026). In the sources checked for this article, no Official Journal publication had appeared by 14 October 2026, so no entry into force or application date can be stated yet. The timeline below shows each step from proposal to the latest official statement.

The deciding row is the last: until the delegated regulation is published, the lithium salt classification has no legal effect on lithium greases in the EU.

Which lithium grease products are affected?

Lithium grease products are affected in two different ways: the thickener raw materials lithium hydroxide and lithium carbonate are named in the draft entry, while finished lithium greases are affected only through the CLP rules for mixtures. Lithium hydroxide is used as an intermediate to manufacture lithium 12-hydroxystearate, the soap that thickens the finished grease (ANSES, 2024). Grease, lubricant and battery associations stated that thickeners made from lithium hydroxide make up around 70% of the grease market (Joint industry statement, 2022). The table below sorts the products a grease maker or distributor handles by how the draft entry reaches them.

The key row for most buyers is the fourth: a finished lithium grease is classified under this entry only when its content of a named salt reaches 0.3%, and in our reading of the draft table no lower specific concentration limit is set for these salts. The draft entry lists lithium hydroxide as CAS 1310-65-2 and, in our reading, does not name the monohydrate (CAS 1310-66-3) separately (European Commission, draft 24th ATP annex, 2025); ask the raw material supplier how its SDS classifies the form it ships. Lithium chloride, the third named salt, is used in fluxes and humidity control (ANSES, 2024) and is not a grease raw material in the sources checked.

Would finished lithium greases need new hazard labels?

Finished lithium greases would need new Repr. 1A hazard labels in the EU only if they contain lithium carbonate, chloride or hydroxide at or above the classification threshold once the 24th ATP applies. CLP classifies a mixture from its ingredients. For a Repr. 1A ingredient without a specific concentration limit, the draft French risk management option analysis (RMOA) states that "the relevant generic concentration will apply as in Part 3 of Annex I of the regulation No 1272/2008 meaning 0.3%" (ANSES, 2024). From 0.1%, a mixture that is not classified must still have a safety data sheet available on request when it contains a substance toxic to reproduction category 1A or one with effects on or via lactation (Regulation (EC) No 1907/2006, Article 31(3)).

In a lithium soap grease, lithium hydroxide is the intermediate that becomes the soap thickener (ANSES, 2024), so the question for each product is how much listed salt remains unreacted in the finished grease. That is a formulation and process value that only the grease maker can state. ASTM D128-24a, Standard Test Methods for Analysis of Lubricating Grease, lists free alkalinity among the constituents it can determine in conventional soap greases (ASTM International, 2024), which gives makers one way to check. Free alkalinity is an indicator, not a direct lithium hydroxide content; how a maker converts one into the other is its own judgement, in our reading.

The soap itself, lithium 12-hydroxystearate, is not one of the three salts named in the draft entry (European Commission, draft 24th ATP annex, 2025). A lithium grease whose listed salt content stays below 0.3% would keep its present label under this entry, unless the supplier's classification of other ingredients changes it.

What are the technical consequences for lithium grease supply?

The main technical consequences for lithium grease supply fall on grease plants that charge lithium hydroxide into kettles, not on bearings or grease users. Once the classification applies, the draft French RMOA states that the three salts "will be subject to control under the CMRD", the EU Carcinogens, Mutagens or Reprotoxic substances Directive 2004/37/EC (ANSES, 2024). That directive asks employers to replace a reprotoxic substance where technically possible, to use a closed system where replacement is not possible, and otherwise to keep exposure as low as possible (ANSES, 2024, citing Articles 4 and 5). The Article 5(3) wording "as low a level as is technically possible" is written for carcinogens, mutagens and non-threshold reprotoxic substances (ANSES, 2024).

Exposure limits for lithium salts are still being set. ECHA opened a consultation on 1 April 2026 on a scientific report that gives candidate 8-hour limits and proposes a short-term limit for lithium hydroxide because it is corrosive (CIRS Group, 2026). At its 7 to 11 September 2026 meeting, the ECHA Risk Assessment Committee agreed 8-hour values of 1.3 and 3.8 mg Li/m3 and moved the short-term limits to its next meeting (ChemRadar, 2026).

The Commission expects limited change for plants that already handle substances with equivalent classifications, stating that "current risk mitigation measures already in place may suffice" (European Union, WTO reply, 2026). Grease, lubricant, vehicle and battery associations argued in 2022 that a Repr. 1A classification could severely affect investment in the European lithium value chain and that obstacles to lithium greases could push users toward less efficient lubricants (Joint industry statement, 2022). Effects on grease supply beyond the plant are therefore a forecast by interested parties, not an observed result; that is our inference from the sources.

Which grease thickeners could replace lithium if classification applies?

The grease thickeners most often named as replacements for lithium are calcium sulfonate, polyurea, aluminium complex and hybrid lithium-calcium, and each fits a different duty (STLE TLT, 2022). In the Society of Tribologists and Lubrication Engineers (STLE) magazine in 2022, one grease formulator said calcium sulfonate can outperform most lithium products "except for very low temperatures and very high speed/high temperature bearing applications" (STLE TLT, 2022). Another said polyurea greases have an edge for long-life and fill-for-life uses, while calcium sulfonate greases generally stand out in heavy-duty industrial service (STLE TLT, 2022). The same article reports NLGI production surveys showing calcium sulfonate grease output growing and lithium grease output declining (STLE TLT, 2022).

A replacement is a product decision, not a regulatory requirement: a finished lithium grease below the classification threshold keeps its status under this entry. Where a site does switch thickener, compatibility with the grease left in the equipment decides whether the change is safe for the bearing. ASTM D6185-24, Standard Practice for Evaluating Compatibility of Binary Mixtures of Lubricating Greases, covers "a protocol for evaluating the compatibility of one or three binary mixtures of lubricating greases" (ASTM International, 2024). The practice also notes that "equipment manufacturers recommend completely cleaning the grease from equipment before installing a different grease" (ASTM International, 2024). Equipment maker approvals still govern which grease a machine may use.

What should grease users and makers do now about lithium salt classification?

Grease makers should prepare for lithium salt classification before publication, because the 18-month transition starts at entry into force (European Commission, draft 24th ATP, 2025), while distributors and users mainly need current product data. The table assigns each step to the party that owns it.

The first row decides every other deadline, because no application date exists until publication. Consumer packs matter because REACH Annex XVII entry 30 bars supply to the general public of mixtures that contain a listed Repr. 1A substance at or above the relevant concentration limit, according to the draft French RMOA (ANSES, 2024). Entry 30 covers Repr. 1A substances that are also listed in Appendix 5 of Annex XVII (ANSES, 2024), so in our reading it reaches the lithium salts only after a separate amendment adds them to that appendix. This touches retail grease cartridges only if the grease itself reaches the limit. Users of lithium greases in bearings face no new duty from this entry; their part is to keep supplier SDS on file, check any changed classification when the updates arrive, and avoid an unplanned thickener switch that could mix incompatible greases in the same bearing. Distributors sit in between: they pass updated SDS and labels down the chain and must not supply a classified grease to the public where entry 30 bars it.

What is still open on lithium salt classification?

Four points are still open on lithium salt classification as of 14 October 2026. The first is the adoption and publication date. On 3 July 2026 the Commission was still "in the process of adopting" the act (European Union, WTO reply, 2026), and after adoption the European Parliament and Council review the draft before it can be published (KFT, 2025).

The second is the workplace limit. At its 7 to 11 September 2026 meeting, the ECHA Risk Assessment Committee agreed 8-hour values of 1.3 mg Li/m3 for developmental toxicity and 3.8 mg Li/m3 for kidney and other organ effects, and left the short-term limits, biological monitoring and analytical methods to its next meeting (ChemRadar, 2026, from the RAC-78 minutes). Once adopted, the Committee's opinion will give the Commission a basis to set binding limits for the three lithium salts (CIRS Group, 2026).

The third is further REACH action. The draft French RMOA notes that once the classification is in an ATP, identification as a substance of very high concern could be envisaged, depending on how far users substitute the salts, and that authorisation "does not apply to applications where lithium and its salts are used as intermediates" (ANSES, 2024). Whether every step of grease thickener manufacture counts as intermediate use is not settled in the sources checked.

The fourth is the lithium soap. Lithium 12-hydroxystearate has no harmonised entry, and whether its suppliers will change their own classification after the salts are classified is not known; this is an open question, not a forecast.

Lubinpla, an applied AI company, works cases like this from a company's own documents, such as SDS and certificates, and returns one cited document for review, with each step approved by the user.