July 26, 2017
Volume 17 Issue 52
ATF Labels Face a Rewrite
Labels on automatic transmission fluid should be clearer in some states starting in January, following recent handbook amendments adopted by the National Conference on Weights and Measures that also provide criteria for how to substantiate performance claims for multi-vehicle and “suitable-for-use” ATFs.
The NCWM adopted changes to the labeling and documentation requirements in NIST Handbook 130 for transmission fluids. These fall under two sections: Uniform Regulation for the Method of Sale Commodities, and Uniform Engine Fuels and Automotive Lubricants Regulation. The Independent Lubricant Manufacturers Association noted in a legislative alert July 20 that “because some states adopt only the method of sale provisions in their jurisdictions, the adopted amendments cover both sections and are internally consistent.” Some states automatically codify the latest version of Handbook 130, while others go through legislative or rule-making processes to adopt the latest revisions.
NCWM adopted the amendments at its annual meeting held July 16-20 in Pittsburgh, Pennsylvania, and they become enforceable Jan. 1, 2018. NIST Handbook 130 contains model laws and regulations, including ones covering engine fuels and lubricants.
The American Petroleum Institute first proposed the two amendments about two years ago. “It was at the request of the conference's Fuels and Lubricants Subcommittee,” Kevin Ferrick, who manages engine oil licensing at API, told Lube Report. “The committee wanted requirements in place for transmission fluid that were consistent with requirements adopted for engine oils.” API, ILMA and the Automotive Oil Change Association then developed the amendments in conjunction with the subcommittee.
The amendments specify labeling for containers (including bottles, cans, multi-quart or liter containers, pails, kegs, drums and intermediate bulk containers) and also for storage tanks. The changes also include directions for documenting transmission fluid sold in bulk, and for how service providers should document transmission fluid installed from a bulk tank at time of vehicle service.
In a July 11 letter to NCWM’s Laws and Regulations Committee, ILMA CEO Holly Alfano said the critical provision in the two items up for adoption “is how oil marketers, including ILMA members, demonstrate their transmission fluid performance claims. ILMA supports the language that allows the oil marketer to rely upon the field testing and other validation conducted by its additive supplier(s), including data provided in confidence by the additive supplier(s) to the enforcement agency.”
Alfano emphasized that the two items “are not intended to address performance issues with transmission fluids, especially multi-vehicle ATFs. Based on automotive market research by IMR Inc., transmission replacements accounted for only one percent of all vehicle repairs in 2016. With some 12 million vehicles serviced annually with multi-vehicle ATF technologies, these fluids are providing the proper level of protection against transmission failure.”
She pointed out that more than 100 ATF types or technologies are available in today’s market. “Multi-vehicle ATFs technologies have been developed and are used by both OEM dealerships and independent repair shops to manage effectively this increasingly complex market, reduce inventories, reduce potential misapplication and increase customer choice,” she said. “Based on additive company estimates, including an average vehicle mileage of 10,000 miles per year, multi-vehicle ATF technologies have accumulated over 5.5 trillion miles of real-world experience since their introduction.”
She noted the two referenced voting items before the NCWM are intended to address the proper labeling of transmission fluids as they travel down the distribution chain to the end user. OEMs current transmission performance specifications for factory and service fill generally are not publicly available. “Some of ILMA’s manufacturing members make and market OEM-licensed transmission fluids for service fill,” she said in the letter. “Other ILMA members will rely on their additive suppliers who typically run field trials in the specific application to validate performance and demonstrate no harm for ‘suitable for use’ transmission fluids.”
Alfano added that, because multi-vehicle ATFs are now in the mainstream in the United States, and because they are helping to manage the increasingly complex service-fill market, NIST Handbook 130 should not discriminate against these fluids. “At the same time, ILMA agrees that multi-vehicle ATFs, along with ‘suitable for use’ transmission fluids, need to be properly labeled for performance claims. ILMA supports labeling that directs the end user to the manufacturer’s web site for specifications and other information.”
The Automotive Oil Change Association said yesterday that the Handbook 130 amendments are a win-win situation for ATF consumers, automotive service providers, aftermarket manufacturers and weights and measures regulators alike. In a news release, the group hailed the conference’s official recognition of the performance-based standard commonly referred to as “suitable for use.” The new regulations will allow both OEM specification fluids and aftermarket fluids demonstrated to be “suitable for use” by performance evidence, whether or not they meet the exact OEM specification recipe, the association noted.
“Since approximately 92 percent of automotive services are delivered by aftermarket companies, there has never been a practical way to distribute exclusively 100+ OEM-licensed products to meet all consumers’ needs, let alone their preference for lower cost competition,” AOCA stated. “Moreover, with transmission replacements amounting to only 1 percent of all automotive repairs on an annual basis, clearly aftermarket fluid manufacturers and installers have been taking care of business all along.”
AOCA plans to hold its first Transmission Fluid Subcommittee meeting on Sept. 12 to assure its members have access to all aspects of compliance with the new rules.
The amended proposal for changes and related letters are available under Committee Items 2302-9 and 2307-1 at the NCWM web site: http://www.ncwm.net/meetings/annual/publication-16.