Running a Shop Law

Is that Label Correct? There’s More to it Than You Might Think

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There’s a whole supply chain for the oils and fluids that come into a shop. From the manufacturers, distributors, shops and anyone in between, it’s a chain of custody.

But if a driver has an issue with the engine oil or transmission fluid, it’s the shop that’s going to be held responsible, and enforcement is stepping up across the country.

That’s why proper product labeling and tracking is important, and quick lube operators play a huge role in that quality control. In addition to that, it protects shops from liability by making sure they’re installing the fluids with the specs as advertised.

At iFLEX in May, the Automotive Oil Change Association announced a new training program for the updated weights and measures requirements found in the National Institute of Standards & Technology (NIST) Handbook 130.

For a quick lube shop, the handbook regulates the labeling of engine oils and automatic transmission fluids. The requirements can be specific. One passage requires that engine oil packages or storage tanks have labels with lettering that’s at least 3.18 mm, or one-eighth of an inch, tall.

Joanna Johnson, policy advisor for the AOCA, explained the reasons behind new labeling requirements and what operators should know in a Q&A with NOLN.


NOLN: Why are these labeling rules important for operators and their customers?

Johnson: It’s crucial for installers and their customers to get the premium products they purchase. Historically, engine oil and transmission fluids sold in bulk were often delivered without any receipt at the time of delivery or, if provided, the receipts were vague.

It was then up to the installer to vouch for the products as being the ones contracted for and provided to the ultimate consumer. If anything went wrong with the bulk delivery, the burden was on the installer to prove the distributor knew exactly what product they were supposed to deliver and also manage any damages experienced by customers. 

Given that the average consumer no longer lifts the hood or reads the owner’s manual, let alone ever had the opportunity to take advantage of the now virtually extinct high school auto shop class, customers may not even know what the acronyms “ATF” or “CVT” mean. 

An installer would know, but how could they be sure they were installing the right product if they didn’t even receive a bulk delivery receipt describing exactly what they purchased? And what about packaged products?


How have regulators responded?

As engine oil and transmission fluid specifications became increasingly complex, weights and measures regulators also took notice. 

Was it enough to include an SAE grade for engine oil once there was a radical difference between SAE 5W-30 API SN and SAE 5W-30 SH?
The National Conference on Weights & Measures thought definitely not, and, in 2012, it began amending the National Institute of Standards Technology (“NIST”) Handbook 130 to include new labeling and receipt rules for engine oil and transmission products.

The majority of states have adopted the code and the rest either have similar requirements in other statutes or use the code as a reference guide when a related issue comes up. It can also be used as a standard of care in lawsuits. 

Enforcement varies from state to state, but can be such a nightmare that no professional operator would want to risk it.


What is required in labeling for engine oil?

Johnson: I can’t give you an “always” answer, unfortunately, because there are nuances between the types of fluids and containers, and regulators expect all of those varying labeling factors to be accounted for. This was a major motivating factor in creating detailed compliance training for this subject. The broadest way to describe it would be the following:

For engine oil packaging:

  • Quantity
  • SAE viscosity
  • Brand 
  • Engine service category
  • Vehicle or engine manufacturer standard with additional requirements where the product is not also licensed by API (American Petroleum Institute) or ACEA (European Automobile Manufacturers' Association)
  • Obsolete cautionary statement when applicable


Why are regulations moving away from labeling for “universal” application?

“Universal” transmission fluid was previously considered akin to the general concept of multi-vehicle fluid.

However, using the product description “universal” has been challenged as misleading in recent years because the vehicle fleet now includes vehicles with significantly different fluid requirements, including viscosity. If a regulator interprets the term “universal” literally rather than as a term of art, it is virtually impossible for one fluid to meet all implicated specifications and could be considered misleading to be labeled as such. 


How can a shop owner begin checking to make sure they're compliant?

First, make sure all bulk product measuring and dispensing devices are properly calibrated. Second, review all product labels. That’s all containers including tanks, reels and pre-packaged goods.  Third, check bulk engine oil and transmission fluid distributor receipts for complete product identification, and in the case of transmission fluid either the primary performance claims or website reference where those claims can be viewed in their entirety.

They may also want to make sure their distribution agreements include compliance with the latest version of NIST Handbook 130. Bulk distributors are required to provide detailed receipts upon delivery and installers are required to keep those receipts for a year. Therefore, a distributor’s failure to comply becomes a compliance risk for the installer, too.

Lastly, make sure the required product identification also appears on fast lube customer receipts. They can always access the latest version of NIST Handbook 130 online, and AOCA members can also use the association’s State by State Enforcement Guide. Neither can provide what the training program offers but would be helpful until that program is rolled out.

What is required in labeling for automatic transmission fluids?

The broadest way to describe it would be the following for ATF:

  • Quantity
  • Brand name
  • Name and place of business of the manufacturer, packer, seller or distributor
  • The words “transmission fluid,” which may be incorporated into a more specific description of transmission type such as “automatic transmission fluid” or “continuously variable transmission fluid,” but never only “ATF” or “CVT” alone
  • Primary performance claim or claims met by the fluid and reference to where any supplemental claims may be viewed (e.g., website reference)

The requirements vary depending on the type of container and also with respect to bulk distributor and installer receipts, which have a special rule for transmission fluid performance claims.

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