Outsourcing of lubricant production
The outsourcing of lubricant production, as well as regulatory consolidation and guidance on the new Product Movement System – SIMP, were topics addressed by the Superintendent of Distribution and Logistics of the National Agency for Petroleum Natural Gas and Biofuels – ANP, Diogo Valério, in a lecture given at the 14th International Meeting with the Market – South America, on July 2, 2024.
New table for SIMP
The SDL Superintendent recalled that October 2024 will be the first month in which the information given to SIMP must be made using the new, much leaner product table. After publishing the new table, the ANP will publish a manual explaining how the necessary changes should be made.
“After sending the SIMP-ANP in October 2024, to be carried out in November 2024, regulated agents, mainly producers, foreign trade agents, re-refiners and collectors, will now inform their operations with the new codes”, recalled Diogo Valerio.
The idea of starting in October is to not interfere with the determination of compliance with targets relating to the reverse logistics of lubricants and to avoid information problems that could impact the companies’ achievement of targets.
Regulatory consolidation in SDL
Diogo confirmed the entry into force on April 10, 2024 of the new resolutions that consolidated the activities of Production of Finished Lubricating Oil, Re-refining of OLUC, Collection of OLUC and Foreign Trade of Biofuels, Oil and its derivatives and Natural Gas Derivatives .
Production Outsourcing: Revocations and Further Investigations
Article 5 of ANP Resolution 941/2023 allows the granting of Authorization to Carry Out an Activity through the presentation of an Outsourced production contract, as long as the other requirements are met. However, since October 2022, the ANP has been intensifying inspection in the lubricants sector, causing the issuance of 65 infraction notices by April 2024.
In July 2023, two companies were notified that had 30 outsourcing contracts. The requested documentation includes production contracts in force from January to July 2023 and production reports for out
sourcers, covering the quantity produced for each of the contracts in force.
“This year, until June 10th alone, more than 122 thousand liters of lubricants were seized, 98 thousand of which were finished oil and 24 thousand of used or contaminated oil (OLUC) in 75 establishments, with bans in 5 of them”, commented Diogo .
A new authorization model for production outsourcing
In his presentation, Diogo Valerio showed that the ANP’s new authorization model for production outsourcing includes the name of the company contracted for manufacturing and the contracted monthly production capacity. The new analysis system – CRAT/SDL (under improvement) for third-party production authorization includes:
- Copy of the finished lubricating oil production contract signed between the parties – must detail the type of finished lubricating oil to be produced and the respective monthly volume.
- Descriptive memorial exclusively highlighting the updated nominal monthly production capacity of finished lubricating oil, accompanied by technical engineering documentation proving the values presented.
- Environmental Operating License (LO) issued by the competent state environmental agency, in the name of the interested party, within the validity period, at the installation address and detailing the production capacity.
- List of outsourcing contracts for the production of finished lubricants currently in force, with the respective contracted monthly volumes.
With these measures, the ANP hopes to increasingly improve not only the quality of the data reported but also increase morale in the lubricants market.
