The Petroleum Quality Institute of America (PQIA) received a number of phone calls over the past month about some of the new labels seen on pails of Tractor Hydraulic Fluid (THF) in the two states (Georgia and Missouri) that issued stop sale orders on “303” tractor hydraulic fluid. Of concern is that although stop sale orders have been issued, the new labels continue to display “303.” The PQIA looked into this and here is what we found.
It is in fact true, some of the new labels on pails of THF continue to display the 303 designation. In addition, however, on some of the new labels PQIA observed, the 303 is now preceded by J20A and/or J14B. This is an important distinction since the action taken by the state of Missouri on Nov 20, 2017 ordered that “effective immediately Tractor Hydraulic Fluid (THF) labeled only as ‘303’ can no longer be sold in the state.” The reason for the action was because the JD 303 designation is 57 years old and has been obsolete for 43 years. In addition, there are no specifications available for 303 THF, and as such products making only “303” claims cannot be tested to assure compliance.
Understanding that specifications do exist for J20C, J20A, and J14B, products making these claims can be tested to determine if they in fact meet these claims. Further, since each of these specifications superseded the 303 designation, they are considered backward compatible.
With that said, the next obvious question is, why would the new labels include “303” along with the other JD specifications? For that matter, why would the labels include J20A and J14B when these specifications were also discontinued and superseded by J20C?
The short answer is that although discontinued and replaced by J20C, the 303 designation and other discontinued specs have not been forgotten. This is because they remain in the owner’s manuals of many older tractors and equipment. Consequently, those servicing older tractors and equipment often look for products with these designations when they purchase THF. And although many in the lubricants business understand that J20C is backward compatible, it’s not as well known to end users. Further, even if understood, the price for a product formulated to meet J20C is typically significantly higher than THF meeting older specifications.
So, the reason some might elect to include the older designations on the labels of THF is to provide what their customers are looking for. In some cases it’s a product meeting an older specification or application (303), at a price point reflective of the older technologies of both the equipment and the THF.
While PQIA considers this a reasonable approach to labeling, and it is now acceptable in the state of Missouri, PQIA’s position is that it is also incumbent on suppliers to speak to the limited use of THF’s meeting only J20A or J14B. As an example, if the label states the product only meets J20A, J14B and for use in 303 applications, it should also include language to advise consumers that it does not meet the JD THF specification for tractors built after 1989. Such labeling provides consumers with what they need to make an informed buying decision.
But there is more.
In addition to what PQIA encourages to include on THF labels, there is language that should not be there when the only specifications on the label are defunct. This includes the use of such terms as “Premium” and others that communicate high quality and can easily be confused to suggest a product is formulated with current additive and base oil technology and meets current specifications.
Although it is an unfortunate reality that some will likely fail to, or fall short of providing responsible labeling, the good news is that positive changes are already being observed on THF labels. The PQIA hopes this will continue and you can be sure PQIA and a number of states will be monitoring the quality of THF in the market. In addition to looking at the JD specifications, such monitoring also examines conformance to the specifications of other tractor manufacturers.
- Missouri Orders 303 Tractor Hydraulic Fluids Out of the State – November 20, 2017
- Tractor Hydraulic Fluid Timeline – November 28, 2017
- Georgia Issues Stop Sale Order for All J303 Tractor Hydraulic Fluid – February 12, 2018
- The Yellow Bucket
- The Games People Play with THF