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REACH
New Transmission Fluid Labeling Requirements
On January 1, 2018, updated labeling and documentation mandates for transmission fluids go into effect automatically in 19 States based on amendments to
NIST Handbook 130
adopted in the summer of 2017 by the National Conference on Weights and Measures (NCWM). The regulations recognize that many oil marketers make and sell “suitable for use” or “multi-vehicle” ATFs. Suitable-for-use performance claims, including for multi-vehicle ATFs, are to be based on appropriate field, bench and/or transmission rig testing, including such testing done by additive suppliers. If the product performance claims are based on the claim(s) of one or more additive suppliers, documentation from the additive supplier(s) can be submitted upon request to the state agency.
ILMA members should ensure that, unless they have conducted their own testing, they have or have access to additive company test data for their suitable for use or multi-vehicle ATF performance claims. ILMA members should also be aware that
Handbook 130
does not provide for a “sell-through” period for any “old” transmission fluid labels; therefore, on the face of the amendments, all products must meet the applicable labeling and documentation requirements in the 19 identified States by January 1, 2018, regardless of when they were manufactured or distributed.
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