Lubricant marketers remain legally responsible for the claims made on their products. Marketing claims must be correct to enable end users to make informed decisions on the correct lubricants for a vehicle and be confident that a lubricant is suitable for use in their vehicle or application. Greater technical awareness has been needed throughout the industry to ensure that marketers understand the claims they are making on particular products. It is the responsibility of the product marketer to ensure that they have sufficient data from a technically competent individual or organisation to justify any performance or application claims.


It is understandable that with margins under pressure, lubricant marketers are keen to service the maximum number of specifications with the minimum number of products. But they must be able to evidence their marketing claims so that technicians and end users can have confidence that the products they select really can deliver.


2. Lubricant marketers are responsible for updating all publicly facing materials, websites, print and labels


The information being given to end users at any point must be accurate and genuinely reflect the product currently being sold. Companies must also advise distributors and agents of any changes and stress the importance of them updating any marketing materials and websites they have for the product so that information is consistent and correct.


3. Lubricant marketers must regularly audit product claims to ensure compliance Marketers should not assume that because something was correct once, it is correct forever. Regular product testing and claim checking are vital to ensure continued compliance throughout a product’s lifecycle.


4. Lubricant marketers should consider proactive quality assurance programmes to assess product performance to a given range of standards to support performance claims Most marketers and manufacturers have quality control procedures in place, but not all are as rigorous as others. ISO standards, such as 9001 for a quality management system, are regularly used. Lubricant blenders will likely use quick


physical Quality Control (QC) tests such as Low Shear Rate Kinematic Viscosity at 100°C (KV) and Low Temperature Cranking Viscosity (CCS) and elemental analyses to verify the correct additive treat rate. But they do not always invest in longer QC tests such as the Low Temperature Pumping Viscosity or MRV test. This involves the measurement of yield stress and low temperature viscosity aftercooling at controlled rates over a period exceeding 45 hours. Several VLS cases have been related to this test. If more comprehensive quality assurance programmes were in place in all manufacturers, these failures would likely have been picked up, appropriate action could have been taken, and the risk of potential damage to customers’ vehicles would have been reduced.


5. Lubricant marketers claiming any ACEA performance standards must be signatories of the European Engine Lubricant Quality Management System (EELQMS) marketers Letter of Conformance Any manufacturer claiming any ACEA standards must be a signatory, and this can be simply and easily checked by anyone via https://www.sail-europe.eu/ registrations/lubricant-marketers.


6. Additive companies must provide appropriate support for current claims Most lubricant manufacturers rely on Additive companies for their technical assistance in developing products to meet particular industry and OEM specifications. These Additives companies should be able to readily provide technical evidence such as candidate data Packages or performance test data that detail results to given test standards and prove that the technology they are supplying can meet the specifications claimed. Evidence should be clearly documented and easily accessed by both the marketer and manufacturer.


Throughout these investigations, VLS procedures have proven to be robust. They have supported positive case outcomes, stimulating the required action to ensure products have been brought into compliance. The Primary Authority relationship with Buckinghamshire and Surrey Trading Standards entered into in 2020, has proved effective in concluding certain cases where escalation by exception has been required to prompt action.


Continued on page 48 LUBE MAGAZINE NO.177 OCTOBER 2023 47


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