Spécifications VLS et allégations de performances – des conseils mis à jour.

VLS recognises the right of lubricant blenders, manufacturers, and marketers to make
performance claims in connection with the description of their products against OEM
specifications and ACEA engine oil sequences. However, the use of these claims within the
industry is complex and there is little consistency in the use of the terms applied to
performance claims.

The aim of the guidance is to bring clarity in the use of the terms applied to performance
claims, and promote consistency in their use, thereby supporting the end user to better
understand these terms and how they are applied in connection with the description and
specification of lubricant products.

A. Making performance claims against OEM specifications and non ACEA industry
specifications
VLS considers that there are three types of generic performance claim of which two are
common.

1. Approved. This means that the product name has been registered with the approval
   authority and a reblend approval sought and obtained.

• The approval must be managed and updated as necessary, per the individual OEM’s
  procedures.

• ‘Approval pending’ or similar claims should not be used.

2. ‘Recommended for use’, ‘Suitable for use’ or ‘Meets the requirements of’, amongst
   other terms. These terms indicate that the marketer is making an informed, professional
   judgement based on supporting technical evidence as to the suitability of a given lubricant
   to a stated application. These terms can include the following cases:

− The technology supplier can demonstrate an appropriate original OEM approval, but
the lubricant marketer has decided not to pursue a reblend approval. Alternately the
Lubricant Marketer has submitted data for a reblend approval, which is awaiting
confirmation by the OEM.

− a formulation has clear evidenced support that it conforms to an industry standard,
but the marketer has decided not to apply for a formal license as is the case with the
API Engine Oil Licensing Certification System (EOLOCS)

− the specification is technically obsolete, or one or more tests are currently unavailable
but, on the basis of a technical judgement e.g. similarity with previously tested materials,
the product would fully meet all the requirements of the specification.

− the lubricant marketer or technology provider has sufficient robust and relevant
supporting data for the recommended application. This should be on the basis of test data against the requirements of the OEM specifications and/or data from substantial field trials where appropriate.

− In cases where OEM’s stipulate how these terms may be used, the OEM guidance must
be respected.

3. Not suitable for use. In practice this would normally be indicated simply by the omission
   to claim one of the above classifications for the product.

B.Making performance claims against the ACEA engine oil sequences

ACEA requires that any claims for oil performance to meet these sequences must be based
on credible data and controlled tests in accredited test laboratories.

ACEA requires that engine performance testing used to support a claim of compliance with
these ACEA sequences should be generated according to the European Engine Lubricants
Quality Management System, EELQMS, but ACEA reserves the right to define alternatives
in exceptional cases.

As such all ACEA claims are absolute and it is not possible to make claims such as ‘meets
the requirements of’, or ‘suitable for use’ against ACEA engine oil sequences.

For more guidance, please visit http://www.eelqms.eu

In all cases involving performance claims, 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 such claims as the marketer is liable for the product.

VLS Process in the event of a complaint relating to a Performance Claim

If a complaint is received that relates to a quantifiable aspect of a performance claim, then the Technical Review Panel (TRP) to the VLS will be asked to make an assessment.

In the case of claims made against OEM specifications, if the product claims an approval,
then this will be checked with reference to an approval authority, such as an OEM’s website. If this is not possible the product marketer will be asked to provide documentary evidence that a valid and current approval exists.

If the product is ‘Recommended for use’, ‘Suitable for use’ or ‘Meets the requirements of’, amongst other terms the TRP will ask the Lubricant Marketer (through the VLS Secretariat) to provide details of the technical assessment that underpins the marketing claims.

In the case of claims for suitability against OEM requirements, the Lubricant Marketer would be asked for a letter from their Technology Provider indicating how they support the suitability of the actual formulation being blended by Lubricant Marketer against the OEM claim.

If the Lubricant Marketer can provide the correct information to show that either an approval has been granted or that their technology provider can robustly underwrite their claims this would be reported to the VLS Supervisory Board through the TRP.

In the case of claims made against the ACEA engine oil sequences or current API claims, then the Lubricant Marketer would be asked to have their Technology Provider provide the Candidate Data Package underpinning these claims.

In both cases the TRP will assess the overall coverage of any performance claim made to ensure that they are not mutually exclusive in terms, for example, of viscometrics or chemical composition.

In the same way that the identity of both the Lubricant Marketer and the lubricant are withheld from members of the TRP, the identity of the technology provider will also be withheld from the general membership of the TRP. The request for information from the Lubricant Marketer will be managed through the VLS Secretariat, and the response received will be passed to a member of the TRP who has no affiliation with any single oil marketer, blender or technology provider.

If the Lubricant Marketer cannot or does not provide suitable technical information to support the claims being made, the complaint would be considered valid. Established VLS processes would then be followed where details of the complaint are made public, involving reporting on the VLS website, publication in Lube Magazine and the potential escalation to the Trading Standards Additionally, in the case of ACEA claims the details would be passed onto ATIEL/SAIL as they would not be compliant with the requirements of EELQMS.