DETERMINATION OF FATTY ACID METHYL ESTERS

The State Enterprise "State Fuel Company 'MASMA'" (SE SFC "MASMA") provides services for the preparation and issuance of documents (decisions, conclusions) approving the use of additives in motor fuels. These services include testing physicochemical parameters and preparing the necessary documentation package.

SE SFC "MASMA" is authorized to provide these services in accordance with its Charter, which has been approved by the Ministry of Energy of Ukraine, specifically:

2.2. The scope of the Enterprise’s activities includes:

2.2.6. Chemotological research, testing, and provision of scientific and technical recommendations, as well as approval for the use of petroleum products, including fuels and lubricants and their additives, along with other products. It also involves developing technologies for their use and efficient application across all sectors of the economy and in the Armed Forces of Ukraine.

Explanatory Note to the Commercial Offer

Paragraph 18 of the Technical Regulation on the requirements for automotive gasoline, diesel, marine, and boiler fuels (hereinafter referred to as the Technical Regulation) states:

"The manufacturer or an authorized representative develops technical documentation that must contain information on the production and use of fuels, based on which it is possible to assess the compliance of the fuels with the requirements of this Technical Regulation..."

When making a decision on the approval of an additive, the requirements outlined in paragraphs 12, 13, 14, and 15 of the Technical Regulation must also be fulfilled.

For fuels that contain additives, the technical documentation must further include: A document confirming the approval for the use of the additive in the relevant type of fuel, along with data on the additive’s content in the fuel.

By Order No. 744 of the Ministry of Energy and Coal Industry of Ukraine, dated December 14, 2017, the personal composition of the departmental commission for the production, supply, and use of fuels, oils, lubricants, special fluids, and additives was approved.

This commission was established by Order No. 851 of the Ministry of Energy and Coal Industry, dated November 18, 2013, "On the Establishment of the Departmental Commission on the Issues of Production, Supply, and Use of Fuels, Oils, Lubricants, Special Fluids, and Additives," which was registered by the Ministry of Justice of Ukraine on January 10, 2014, under No. 12/24789. The commission ceased its activities following changes to its personnel.

Currently, there are no legislatively established requirements for enterprises authorized to issue documents approving the use of additives in specific types of fuels or data on additive content in fuels.

There is also no state registry or official list of enterprises authorized to issue such documents. Moreover, there are no normative requirements for documents confirming such authority for enterprises to issue approvals for fuel additives.

Instruction 281/171 does not contain any requirements regarding the authorization of state executive bodies to monitor its implementation.

Therefore, a document (decision, conclusion) approving the use of an additive in a specific type of fuel, along with data on its content, may be issued by an enterprise (institution) that is authorized to carry out such activities according to its Charter, provided it also has an accredited testing laboratory and specialized experts. This must be based on testing the physicochemical parameters of both the additive and the motor fuel, before and after the addition of the additive. Additionally, information on the safety of the additive, as provided in the product’s safety data sheet, must be taken into account.