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Trading Standards legislation. Since its formation, VLS continues to work very closely with Trading Standards as a statutory body to provide assured advice on lubricant marketing issues and the basis of claims in consumer law.
With space at motor factors, workshops and forecourts at a premium, the temptation is to create lubricant products which can claim to cover huge swathes of the car parc. However, any claims made by a lubricant product must be backed up by evidence to ensure that end users can make informed choices and be confident the oil they are buying is fit for purpose.
The number of cases received each year has varied quite significantly
genuine complaints to be investigated. Of the 90 cases, 25 cases have involved VLS member products, underlining the importance of anonymity during the investigation process. In many cases, VLS members were grateful to VLS for highlighting internal process errors and giving companies the opportunity to take swift corrective action. Cases have been received regarding products manufactured and distributed by companies across the lubricants industry, including Private Label brands, lubricant blenders and OEMs. VLS is focused on what is best for the consumer, regardless of who has produced the product, and every company involved in the industry can be subject to scrutiny.
Landmark case: VLS010167
One of the longest and most complex cases investigated by VLS, VLS010167 led to a change in the VLS process. The Technical Review Panel, a committee of independent experts drawn from across the lubricant supply chain providing technical advice and guidance to the VLS Supervisory Board of Directors, produced a set of advisories as part of a case investigation outside of the initial complaint.
The launch of VLS was met with an expected influx of cases due to pent-up demand. This kept the Technical Review Panel very busy for the first few years. Levels of education increased throughout the industry, and manufacturers and blenders were left with no doubt that their products would be policed if needed.
COVID-19 had a clear impact on the number of cases received as the industry dealt with shutdowns and closures. Since 2013, VLS had been investigating complaints made on lubricant products it had received. In 2022, VLS also began to proactively purchase independent product reports and investigate products that had been found to be non-compliant, leading to a rise in cases that year. The cases received to date in 2023 have already doubled the total for 2021.
Five of the ninety cases investigated were found to have no case to answer, being either compliant from the start or could not be found available for sale in the UK market. This reinforces the importance of the rigorous nature of the VLS process, allowing only
46 LUBE MAGAZINE NO.177 OCTOBER 2023
The initial VLS process only allowed for investigations regarding the original complaint made. However, in this case, several other issues were uncovered during the investigation process. The Technical Review Panel felt it was part of their responsibility to highlight, not ignore, these other possible causes for complaint. In discussion with the Board, the VLS process was subsequently amended to allow for any other issues uncovered during an investigation to be highlighted to the Named Party as ‘advisories’, ensuring this vital information was not lost.
Case Learnings VLS’s primary role is encouraging compliance and educating the end user. Case investigations have produced information valuable not just for individual parties being investigated but for the entire industry.
When looking back over all the cases investigated over the past 10 years, some of the key learnings have been:
1. Lubricant marketers must avoid making mutually exclusive performance claims or sweeping statements about which applications/vehicle marks lubricants are suitable for
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