TLT: What is the role of third-party certification in the lubricants industry?
Gawel: Third-party certification helps improve quality, safety and trust by assuring that a product or process has undergone rigorous testing and meets standard requirements. NSF standards are often accepted across the industry and globally. This is crucial, as companies can make unvalidated marketing claims that can be false. Third-party certification from bodies like NSF verifies not only product quality but entire manufacturing processes. 

Companies may have internal quality assurance programs. While quality assurance is important, independent certification removes any vested interest in products passing industry benchmarks. Rigorous testing procedures can evaluate qualities ranging from a product’s material makeup to its performance capabilities under real-world conditions.

The industry benefits from NSF certification, as it creates a layer of trust for suppliers, manufacturers and consumers, ultimately creating a competitive advantage for certified companies. Certification often helps organizations become preferred suppliers for major food processors who understand certification reduces their liability exposure and demonstrates due diligence in supplier selection. We’ve seen companies transform their market position through certification, moving from commodity suppliers to trusted partners in food safety.

Our certification process for food-grade lubricants spans a range of requirements, including testing potential food contaminants, temperature and pressure performance capabilities and compatibility with various food processing equipment. Additionally, we test lubricants for their potential impact on food safety throughout the entire production chain. This includes assessing migration potential and long-term stability under storage conditions. This widespread approach addresses concerns beyond the immediate contact that can occur with lubrication and food but also includes the food production process as a whole.



TLT: What are some third-party standards the industry should know about?
Gawel: ISO 21469: Safety of Machinery, Lubricants with Incidental Product Contact-Hygiene¹ certification is the international benchmark standard for food-grade lubricants. This certification is an upgrade from H1 registration, as it covers additional scope requirements. While both ISO 21469 and H1 registrations review product ingredients and labeling, ISO 21469 goes in-depth to a product’s manufacturing quality. It does so by including onsite formulation validations and audits. This reviews the risk assessment and packaging accuracy. In addition to conducting a product test, it also includes reviewing labels for traceability.

It is important to note that ISO 9001: Quality Management Systems² certification is a prerequisite for ISO 21469 certification. ISO 21469 looks at three different causes of food-grade lubricant contamination, including chemical risks, manufacturing risks and storage and handling risks. The standard outlines rigorous requirements to verify that the H1 formulation has not changed and that the ingredients match what is in the actual product. It also outlines requirements for following Good Manufacturing Practices (GMP) to reduce the risk of cross-contamination and product degradation. It includes checking for manufacturing environment factors like storage temperature, dirt, dust, moisture and airborne particles.

NSF 537: PFAS-Free Certification for Nonfood Compounds and Food Equipment Materials³ is a new standard that was launched in 2025. It is a groundbreaking standard as we continue to learn more about the harmful effects of PFAS on our bodies and our environment. This standard covers food-grade lubricants in addition to other nonfood compounds and food equipment materials. Certification includes a thorough formulation review, comprehensive testing and rigorous disclosures. Certification to NSF 537 helps reduce human exposure to PFAS while demonstrating a manufacturer’s commitment to evolving regulations.

NSF 538: MOAH-Free⁴ certification addresses critical safety concerns across nonfood compounds and food equipment materials, setting new industry standards for consumer protection. It involves comprehensive product testing to ensure MOAH content is less than 100 ppm, verification that no mineral oil, paraffin, naphthenes, polycyclic aromatic hydrocarbons or wax are intentionally added, and confirmation that manufacturing facilities have procedures to minimize contamination. 

NSF P525: Safe Food Packaging⁵ assesses food contact materials against rigorous, science-based requirements and industry standards, protecting the public and brands from toxins such as PFAS, BPA, phtalates and heavy metals. NSF P525 certifies single-use, primary and secondary packaging intended for contact with food and beverages. 

TLT: What are some of the trends you are seeing in lubricant manufacturing?
Gawel: Regulatory requirements and sustainability requirements and initiatives are the two main factors that I see impacting manufacturers, not just in the food-grade lubricants industry, but across the board. These trends impact how the industry approaches sustainability while also keeping safety and performance in mind.

Sustainability. With food-grade lubricant manufacturers continuing to adopt circular economy practices, their focus has shifted to trying to reduce manufacturing waste by optimizing resources. Manufacturers can implement environmentally friendly practices, like Landfill-Free and Waste Diversion Leader verification,⁶ to reduce their carbon footprint. This can go beyond helping the planet, as it could cut operational costs, bolstering the lubricant manufacturing industry reputationally.

In addition to shifting manufacturing practices to a more sustainable method, manufacturers are also evaluating the products themselves. They utilize Life Cycle Assessments (LCAs)⁷ to identify additional areas for improvement in their sustainability scores. Many companies also utilize third-party expertise to help document and validate their sustainability claims, providing transparency to customers, investors and internal stakeholders.

A challenge to improving sustainability is variations in the supply chain. As we saw with significant disruptions in 2020 and beyond, raw material availability and pricing have forced manufacturers to diversify their supplier networks and develop more resilient sourcing strategies. Keeping all suppliers in line with the same level of sustainability requirements can sometimes make supply chain management complex.

Regulatory compliance. Many manufacturers sell their products in several different countries around the world. Navigating the regulatory landscape in each country can be complex, as companies work to ensure they meet varying requirements. Regulatory bodies, including the FDA, USDA and international standards organizations, have set requirements for food-grade lubricant manufacturers that are sometimes updated or changed altogether. An example of this is the recent regulatory and policy shifts concerning PFAS and our food supply. It can be challenging for manufacturers to anticipate future requirements and adjust operations to meet documentation requirements, management processes and more. 

Manufacturers need in-house experts who can primarily focus on the regulatory landscape to ensure compliance or must be prepared to utilize third-party experts for help. Proactivity is imperative to continue operations, market access and avoid costly delays.

Formulation innovations. The industry continues to innovate new products that improve performance while maintaining food safety. Biobased lubricants are an example of a new approach to traditional petroleum-based products. I believe the industry will continue to see new products that help improve temperature stability, shelf-life duration and environmental impact.

Additive technology is another area I believe we will see additional improvements to lubricant performance in challenging food processing environments. As with any new product, these innovations will require rigorous testing and validation to ensure they meet stringent food safety requirements while delivering the performance that equipment manufacturers demand.

While I see new technology coming that will address challenges, they may not be quick to market, due to the time and cost associated with obtaining approvals for new formulations. It can also be tricky for product manufacturers to navigate multiple regulatory jurisdictions and challenging for those innovating to balance food safety requirements with performance demands without significant trade-offs. Some applications will require extreme performance characteristics that push the boundaries of what’s achievable with food-safe ingredients.

Overall, the future of food-grade lubricant manufacturing will be defined by companies that successfully integrate sustainability, compliance and innovation. Independent, science-based certifications will become increasingly critical as manufacturers seek to differentiate their products in a competitive marketplace.

TLT: How is the current regulatory landscape impacting manufacturers?
Gawel: Regulatory frameworks. It is no surprise that the regulatory landscape for our industry has experienced significant changes over the last 10 years. Regulations have adjusted how manufacturers approach their operations, ranging from ingredient sourcing to product delivery. The regulation that has impacted the industry the most is the FDA Food Safety Modernization Act (FSMA), which outlines enhanced labeling requirements and strengthened allergen management rules, proactively approaching food safety management. This represents a change compared to the historical reactive method.

FSMA has completely shifted how food safety is considered in daily operations. To comply, manufacturers must implement preventative controls and monitor their effectiveness. In addition to maintaining detailed records, they must also conduct hard analyses for food safety. This has led companies to adjust how they operate, train staff and manage their supply chains. 

Labeling requirements. Allergen management rules have shifted operations to meet allergen declaration requirements. To do so, many have redesigned their production lines and enhanced cleaning and segregation protocols, which has significantly helped with allergen control.

This comes as consumers, regardless of allergen needs, have demanded more transparency in what they are eating. In fact, NSF’s recent consumer research⁸ shows that 83% of U.S. consumers read food labels before making a purchase decision. Additionally, 64% pay more attention to labels compared to five years ago, specifically looking for the expiration date (86%), ingredients list (79%), health claims (78%), allergen warnings (77%) and country of origin (77%).

What’s particularly interesting is how these labeling changes have created a ripple effect throughout the supply chain. Manufacturers now require much more detailed information from their ingredient suppliers, creating a cascade of documentation requirements that extends far beyond the final product manufacturer.

Manufacturing processes. The impact of regulation on manufacturing processes has also been interesting as we see a shift from traditional quality control focused on testing finished products to today’s real-time monitoring and predictive controls. If they haven’t already, manufacturers should consider implementing systems that monitor critical control points continuously, using data analytics to predict potential issues before they occur. Risk-based thinking has adjusted manufacturers’ thinking to focus on hazard analyses that consider everything from raw material contamination risks to equipment design flaws that could harbor pathogens.

TLT: In what ways is the industry incorporating more sustainable practices?
Gawel: Reducing manufacturing waste is one of the main ways the industry moves to more sustainable practices. Landfill-free practices can help companies improve their results through documenting where waste ends up, implementing systems that help reduce or recycle materials. This effort is compounded by generating less CO₂ emissions and creating cleaner operations. 

Additionally, advanced heat recovery systems, refrigeration cycles and upgrading variable frequency drives on motors help companies increase their energy-efficiency during processing. Artificial intelligence (AI)-driven energy management optimization helps companies monitor energy consumption in real time, minimizing energy use by automatically adjusting parameters as needed. This helps organizations become more efficient while maintaining product quality standards.

While we have already seen this in practice, we will continue to see sustainable packaging innovations at the forefront of sustainability. In addition, innovative recyclable materials, including compostable films, edible packaging and packaging optimization that reduce material use without compromising food safety or shelf life, will continue. 

Lastly, water conservation will be a point of focus, especially in water-stressed regions. Closed-loop water systems will prove critical to reducing water consumption. Advanced water treatment technologies will enable water reuse and maintain food safety while improving operations.

REFERENCES
1. www.nsf.org/knowledge-library/iso-21469-certified-lubricants
2. www.nsf.org/management-systems/quality-management/iso-9001
3. www.nsf.org/food-beverage/commercial-food-equipment/nsf-537-pfas-free-certification-nonfood-compounds-food-equipment-materials
4. www.nsf.org/news/nsf-launches-groundbreaking-moah-free-certification-for-food-industry-materials
5. www.nsf.org/news/nsf-launches-safe-food-packaging-certification-reduce-human-exposure-synthetic-chemicals
6. www.nsf.org/sustainability/circularity-waste-materials-management/landfill-free-verification
7. https://d2evkimvhatqav.cloudfront.net/documents/su_pcr_epd_lca_insert.pdf?v=1594930083
8. www.nsf.org/news/americans-demand-greater-clarity-standardization-food-labeling
You can reach Robyn Gawel at rgawel@nsf.org.