July 24, 2019
Volume 3 Issue 4
Transparency Mandated for Obsolete Tractor Fluids
Starting in January, tractor hydraulic fluids sold in the United States that do not meet current specifications will need to be clearly labeled as “obsolete” and accompanied by an explanatory warning on their package fronts, following handbook amendments adopted last week by the U.S. National Conference on Weights and Measures.
The NCWM adopted changes to requirements in NIST Handbook 130 for tractor hydraulic fluids, with the stated purpose of preventing product misrepresentation and equipment failure. The key amendment requires that any obsolete manufacturer specifications be clearly identified as such and be accompanied by a specific warning on the front package label in clearly legible font and color. This warning must state that some of the specifications are no longer deemed active by the original equipment manufacturer. The warning isn’t required if the fluid claims to meet current original equipment manufacturers’ specifications.
Industry observers lauded the change as an important protection for consumers.
“Particularly helpful in protecting consumers’ equipment is the requirement that a cautionary statement is displayed on the front label of THF that only meets obsolete specifications,” said Tom Glenn, president of the Petroleum Quality Institute of America, which has been prominent in bringing scrutiny to supply of 303 tractor fluids, named for a former John Deere specification that is now obsolete.
“The language required in the statement is unambiguous and needed, especially the wording that, ‘Significant harm to the transmission, hydraulic system, seals, final drive or axles is possible when using this product in applications in which it is not intended.’ In addition to informing and protecting consumers, PQIA believes the amendments will help promote fair business competition in a product line that for years many have been describing as the Wild West of lubricants.”
Lubricant additives maker Lubrizol and the State of Missouri sponsored the amendments.
“Lubrizol is happy to see that there was broad support for the passage of the new language regarding the definition of a tractor hydraulic fluid,” Stephen Eck, Lubrizol global product manager for off highway, said in an emailed statement. “We believe that this will better protect the end consumers with proper product representation aligning with current OEM specifications, which their significant investments in equipment require for optimum durability and functionality.
“This language also requires proper data to back up the claims on the product which should give the industry confidence that the fluids servicing the equipment do in fact align with the OEM requirements. Finally, the language in this amendment will allow the consumer to benefit from clear labelling on containers with regard to which claims are current and which are obsolete.”
The new regulations become effective Jan. 1 and will be included in the Uniform Regulation for the Method of Sale of Commodities in the 2020 Edition of NIST Handbook 130 under “Uniform Laws and Regulations in the areas of Legal Metrology and Fuel Quality,” Kenneth Butcher, program leader for the National Institute of Standards and Technology’s Office of Weights and Measures/Laws and Metric Program, confirmed in an emailed statement.
NCWM adopted the amendments at its annual meeting held July 14-18 in Milwaukee, Wisconsin. NIST Handbook 130 contains model laws and regulations, including ones covering engine fuels and lubricants. The states of Missouri, North Carolina and Georgia have all taken legal action against companies offering 303 tractor hydraulic fluids, and some companies offering the fluids have been the targets of class action suits by customers.
Products labeled as 303 THF have been common offers for economy tractor fluids, but while JD 303 was at one time an active specification, it was long ago declared obsolete and is no longer administered, meaning there is no verification that products meet the specification or that the specification provides adequate protection.
John Deere developed JD 303 nearly 60 years ago and replaced it in 1974 with J14B, which was replaced in 1978 with J20A. John Deere has declared all of those specifications obsolete and has two current specs – JDM-J20C and J20D – along with its genuine Hy-Gard fluid. Critics say JD 303 fluids do not meet the lubrication requirements of modern tractors and in fact can harm them.
“This NCWM initiative will create new labeling requirements for tractor hydraulic fluids,” ILMA President Holly Alfano told Lube Report. “ILMA supported it because it is time to end the vague, confusing and often misleading claims made for 303-type fluids. We’ve seen industry estimates that less than two percent of in-use tractors today were designed to run on 303 fluids, so demand for the products should be low. Cost-conscious equipment owners and operator need to have appropriate information on the performance of the products they are buying.”
A key requirement in the amendments is that tractor hydraulic fluids must meet at least one current or verifiable original equipment manufacturer specification for respective tractors. “A specification is deemed verifiable if all necessary bench and laboratory tests are available to verify the fluid’s ability to pass those requirements set out by the original equipment manufacturer,” the amendments stipulate.
The provisions further explain that a specification is deemed verifiable if all necessary bench and laboratory tests are available to verify the fluid’s ability to pass those requirements set out by the original equipment manufacturer. The amendment wording notes that a list of current and verifiable specifications will be located in the online version of Handbook 130’s Uniform Fuels and Automotive Lubricant Regulation section on the NIST OWM Publications website.
The amendment section on tractor hydraulic fluid additives stipulates any material offered for sale or sold as an additive to tractor hydraulic fluids “shall be compatible with the tractor hydraulic fluid to which it is added and shall meet all performance claims as stated on the label or published on any website referenced by the label.” The amendment also requires performance claims to be documented.
The container labeling section of the amendments requires that the label on a container of tractor hydraulic fluid not contain any information that is false or misleading. Containers include bottles, cans, multi-quart or liter containers, pails, kegs, drums and intermediate bulk containers. The amendments also include similar stipulations for identification on service provider documentation for bulk tanks and requirements for storage tank labeling.
The amendment documents and related letters are available at the NCWM website under the Additional Letters, Presentations and Data section, Block 4: https://www.ncwm.net/meetings/annual/publication-16