Food Grade Lubricant Approval & Compliance

Justin Christensen |

Download PDF Dealing with lubricants that will be around food is not taken lightly.

When it comes to protecting the health of the masses, the food and beverage processing industry is probably one of the most carefully controlled in terms of regulations and standards. From facility and equipment to process and product, everything must be met with a stamp of approval.

One classification of products with very precise specifications is food grade lubricants. Based on the probability that they will come into contact with food, National Sanitary Foundation (NSF) International has divided them into three main categories:

  1. H1 Lubricant – Also known as “above the line” lubricants, are used where there may be incidental contact with food. Applied as anti-rust film on equipment, as a release agent on gaskets and seals, or as a lubricant on machine parts and equipment. 
  2. H2 Lubricant – Used on equipment, machine parts or in closed systems where there is no possibility of food contact.
  3. H3 Lubricant – Otherwise known as soluble or edible oils, are used to clean and prevent rust on hooks, trolleys and similar equipment. Areas that contact edible products must be cleaned of the oil before re-use.

Further to their use, food grade lubricants are also distinguished by formulation. The list of ingredients, as defined by the US Code of Federal Regulations (CFR) Title 21, is what determines their approval and under which category they will be registered.

         i.     HX-1:  May only be comprised of one or more base stocks, additives or thickeners
        ii.     HX-2:  No specified ingredients, but may not contain heavy metals such as: antimony, arsenic, cadmium, lead, mercury or selenium; nor carcinogens, mutagens, teratogens or mineral acids.
       iii.     HX-3:  May be comprised of corn, cottonseed or soybean oil, mineral oil and Generally-Recognized-As-Safe (GRAS) substances.

Regulation Changes

Prior to 1998 – US Department of Agriculture (USDA) is responsible for approval of food grade lubricants. No testing is done and manufacturers only have to verify that the product contained allowable substances. Those in compliance receive a letter of authorization.

—February 1998 – USDA implements the Hazard Analysis & Critical Control Point (HACCP) program. Manufacturers were required to assess the risk points of contamination throughout their operation.  In essence, they became self-regulating bodies of lubricant certification. However, since many of them did not recognize the significance of lubrication analysis, suppliers offered to manage that step.

—1999 – USDA relinquishes responsibilities to NSF due to its lack of resources. NSF provides a registered database for nonfood compounds in the food processing industry.  Although it is not yet legally required to register a food grade lubricant in the United States, registration with NSF is becoming recognized as a worldwide standard. 

—2006 – ISO Standard 21469 comes into affect.  It only addresses category H1 lubricants, however, it also covers lubricant design, manufacturing, packaging and transportation.

Stamp of Approval

If you’re in the market for food grade lubricants and are unsure of the quality you’re purchasing, look for the “NSF” certification mark. Their symbol is your guarantee that the product has gone through the seven-step registration process, been tested and complies with all standard requirements.

An independent, accredited organization, NSF International is respected by manufacturers, retailers and regulatory agencies at global levels. They have been developing standards and certifications that help protect food, water, consumer products and the environment since 1944.

Certification with ISO Standard 21469 is a six-step process and has become a valued supplement to NSF H1 for manufacturers.


Meeting compliance requirements is not a quick and easy task.  However, engaging the professional services of a reliable fuel distributor can help smooth the process.  With their industry experience, product knowledge, strategy and support, your equipment and your business will be certified for long term success.