ILMA Compoundings - April 2019 - 36

FROM BOTH A REGULATORY
STANDPOINT AND A REASONABLE
CONSUMER STANDPOINT, LUBRICANT MANUFACTURERS FACE
CHALLENGES THAT THEY MUST
ADDRESS TO ENSURE COMPLIANCE
AND CUSTOMER SATISFACTION.

that they must address to ensure compliance and customer satisfaction. It's
a balancing act that ILMA members
navigate regularly.
Here's a look at how they're
handling some of the other challenges
related to labeling requirements.

SPACE RESTRICTION
CHALLENGES

Not unsurprisingly, this can represent
some space limitation issues for manufacturers. "The concern always is the
amount of space available on a label,"
said Ferrick. "Oil marketers are always
keenly aware of how much information
they have to put on the labels because
they don't have a lot of space - that's
probably their biggest challenge."
Since it's likely that manufacturers
will sell products in multiple states,
Ferrick noted that a best practice
would be designing their labels to
meet the most stringent requirements.

OBSOLETE PRODUCT
REQUIREMENTS

There are also labeling requirements
specific to products which have
become obsolete, said Ferrick. These
requirements come through the SAE.
"If you're making an engine oil that
is considered obsolete, API no longer

36

APRIL 2019

| COMPOUNDINGS | ILMA.ORG

licenses against that standard; we
usually declare a standard as obsolete
when the tests that are used to validate
an oil or verify it meets the standard
are not available."
Obsolete oils, said Ferrick, must
have room on their labeling for a
warning statement that, in this case,
is provided by SAE. It's just an added
consideration in terms of effectively
using the limited space that's sometimes available on a label.

OLDER PRODUCTS

One issue that may come into play for
some manufacturers are products that
were correctly labeled at the time they
were produced, but which are still
sitting on shelves with labels that
are no longer correct. Their current
labeling may no longer be in compliance with newer regulations, but the
labeling was correct at the time the
product was produced.
This concern, said Ferrick, is generally addressed through a traceability
code that appears either on the bottom
or side of the container. "It's basically
an identifier that tells them when the
produce was packaged. That actually
gives them some protection so they
can demonstrate that the product was

packaged in accordance with the law
that was in effect at the time."
Still, these obsolete oils are problematic from a consumer standpoint.
ILMA CEO Holly Alfano says that the
Association has been working to require
cautionary language on the container
label. ILMA has a proposal pending in
the National Conference on Weights
and Measures (NCWM) which would
require language on the front of the
container informing consumers that the
product could damage the consumer's
vehicle engine or emissions system.
The language is pending review
by NCWM's Laws and Regulations
Committee. "We are hopeful that we
will be able to advance the measure to
voting status in the coming months,"
Alfano said.

BRANDING
CONSIDERATIONS

Branding and compliance can be
two considerations that often fall at
far ends of the spectrum in terms of
the aesthetic nature of a product's
label. Marketers want to sell product;
graphic designers like to exercise their
creativity. Manufacturing company
leaders, though, need to ensure that
marketing practices meet regulatory
requirements. It's a challenge, but not
one that is insurmountable.
In some cases, organizations like
API are stepping up to help close
the gap. In 2016, API introduced a
special Service Symbol Donut to help
consumers identify API FA-4 diesel
engine oil, which was designed to
protect the next generation of diesel
engines, according to a news release.
It's critical for both manufacturers
and their marketers to be monitoring
these requirements to ensure that their
labels, and their communications, are
both up to date and compliant, keeping both regulations and reasonable
consumers in mind.
Grensing-Pophal is a Wisconsin-based
freelance writer.


http://www.ILMA.ORG

ILMA Compoundings - April 2019

Table of Contents for the Digital Edition of ILMA Compoundings - April 2019

Letter From the President
Letter From the Ceo
Inside Ilma
What’s Coming Up
New Members
Industry Rundown
International Insight
Tackling 303 Thfs
Labeling Conundrum
Business Hub
Counsel Compound
Washington Landscape
In Network
Portrait
ILMA Compoundings - April 2019 - Cover1
ILMA Compoundings - April 2019 - Cover2
ILMA Compoundings - April 2019 - 1
ILMA Compoundings - April 2019 - 2
ILMA Compoundings - April 2019 - Letter From the President
ILMA Compoundings - April 2019 - 4
ILMA Compoundings - April 2019 - Letter From the Ceo
ILMA Compoundings - April 2019 - Inside Ilma
ILMA Compoundings - April 2019 - 7
ILMA Compoundings - April 2019 - 8
ILMA Compoundings - April 2019 - 9
ILMA Compoundings - April 2019 - 10
ILMA Compoundings - April 2019 - 11
ILMA Compoundings - April 2019 - What’s Coming Up
ILMA Compoundings - April 2019 - 13
ILMA Compoundings - April 2019 - 14
ILMA Compoundings - April 2019 - New Members
ILMA Compoundings - April 2019 - Industry Rundown
ILMA Compoundings - April 2019 - 17
ILMA Compoundings - April 2019 - 18
ILMA Compoundings - April 2019 - 19
ILMA Compoundings - April 2019 - International Insight
ILMA Compoundings - April 2019 - 21
ILMA Compoundings - April 2019 - 22
ILMA Compoundings - April 2019 - 23
ILMA Compoundings - April 2019 - 24
ILMA Compoundings - April 2019 - 25
ILMA Compoundings - April 2019 - Tackling 303 Thfs
ILMA Compoundings - April 2019 - 27
ILMA Compoundings - April 2019 - 28
ILMA Compoundings - April 2019 - 29
ILMA Compoundings - April 2019 - 30
ILMA Compoundings - April 2019 - 31
ILMA Compoundings - April 2019 - Labeling Conundrum
ILMA Compoundings - April 2019 - 33
ILMA Compoundings - April 2019 - 34
ILMA Compoundings - April 2019 - 35
ILMA Compoundings - April 2019 - 36
ILMA Compoundings - April 2019 - 37
ILMA Compoundings - April 2019 - Business Hub
ILMA Compoundings - April 2019 - 39
ILMA Compoundings - April 2019 - 40
ILMA Compoundings - April 2019 - 41
ILMA Compoundings - April 2019 - Counsel Compound
ILMA Compoundings - April 2019 - 43
ILMA Compoundings - April 2019 - Washington Landscape
ILMA Compoundings - April 2019 - 45
ILMA Compoundings - April 2019 - In Network
ILMA Compoundings - April 2019 - 47
ILMA Compoundings - April 2019 - 48
ILMA Compoundings - April 2019 - 49
ILMA Compoundings - April 2019 - 50
ILMA Compoundings - April 2019 - 51
ILMA Compoundings - April 2019 - 52
ILMA Compoundings - April 2019 - 53
ILMA Compoundings - April 2019 - 54
ILMA Compoundings - April 2019 - 55
ILMA Compoundings - April 2019 - Portrait
ILMA Compoundings - April 2019 - Cover3
ILMA Compoundings - April 2019 - Cover4
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