Key Takeaways

• EPL does not allow blanket base oil substitution and does not redefine how “synthetic” products are marketed.
• Group II+ use in synthetic blends is common, but extending it to “full synthetic” raises technical and positioning questions.
• OEM specifications such as GM dexos1™ may limit the practical use of EPL, even where temporary substitutions are allowed.

In a March 25 announcement, the Independent Lubricant Manufacturers Association confirmed that the American Petroleum Institute has activated Emergency Provisional Licensing (EPL) under API 1509 Section 6.9. ILMA emphasized a critical point: it did not request—and API’s approval does not authorize—any blanket substitution of base oil groups in licensed formulations.

The statement also makes clear that EPL is not intended to enable broad-based base oil substitution in products marketed as “synthetic,” and does not apply to how such products are defined or marketed.

API’s EPL framework provides licensed formulators with a structured, case-by-case pathway for temporary base oil substitutions for up to 90 days, while they gather supporting data and complete required testing within 180 days. The provision was implemented in response to ongoing Group III base oil supply disruptions linked to geopolitical developments in the Middle East.

Importantly, API’s role is limited to licensing and performance standards. Marketing terminology such as “synthetic,” “synthetic blend,” or “full synthetic” falls outside the scope of API 1509 and is not defined within it.

This distinction has renewed attention on a long-standing area of interpretation in the lubricants market.

As Steve Haffner, of SGH Consulting LLC and a former industry formulator with more than 40 years of experience, noted, “Pandora’s box was opened long ago on the 2-plus issue.”

Group II+—high-viscosity-index hydrocracked base stocks positioned between conventional Group II and Group III—is not defined as “synthetic” under industry standards. However, some technical interpretations suggest that portions of certain high-VI Group II+ base stocks may share molecular characteristics with Group III, which has contributed to their use in formulations marketed as synthetic blends.

In practice, relatively small amounts of Group III content have also been used to support “synthetic blend” positioning in some formulations. However, because Group II+ is not equivalent to Group III, extending that logic to “full synthetic” claims moves beyond how the term has been interpreted following the 1999 National Advertising Division (NAD) decision. The NAD, part of the Better Business Bureau’s advertising self-regulatory system, permitted the marketing of Group III base oils as synthetic.

Haffner further noted that the use of Group II+ in formulations marketed as synthetic blends has been widely accepted in practice, in part because the term itself is loosely defined and often shaped by marketing convention. However, extending that approach to products positioned as “full synthetic” goes beyond what has been accepted by industry formulators and marketers, and raises a different set of considerations.

“Based on long-standing industry practice and the 1999 National Advertising Division decision, full synthetic formulations have long been understood to rely on Group III or higher-quality base stocks. Using Group II+ as the primary base stock in a full synthetic formulation would represent a departure from that framework and may not deliver the same level of performance,” Haffner added.

As a result, “full synthetic” claims may reflect a combination of formulation approach and marketing positioning.

With Group III supplies tightening, some market participants are evaluating greater use of available base stocks, including Group II+. EPL may facilitate temporary formulation adjustments for API-licensed products when supported by appropriate data and performance testing. However, it does not address or alter how marketing claims are defined or evaluated, and, as Haffner noted, “from a technical standpoint, certain performance specifications are beyond the capabilities of Group II+ base stocks.”

For independent lubricant manufacturers and distributors, several practical considerations emerge:

• Competitive positioning: Variability in how “synthetic” products are formulated and marketed may continue to influence pricing and tier positioning.
• Customer communication: Questions around formulation and performance could increase as supply conditions evolve.
• Documentation and diligence: Records related to EPL-driven formulation changes may become relevant if product performance or labeling is later reviewed.

EPL is a temporary compliance mechanism. It requires technical support and does not override broader approval requirements. In practice, OEM specifications—such as those tied to General Motors’ dexos1™ program for widely used 0W-20 grades—may constrain formulation flexibility, limiting how much EPL can be used as an operational solution.

The current supply environment has brought greater visibility to a long-standing structural issue within the lubricants market—namely, the gap between technical formulation realities and how products are positioned and marketed. As base oil availability tightens and formulation flexibility becomes constrained, that gap becomes more difficult to manage, particularly in segments where the definition of “synthetic” is shaped as much by market convention as by chemistry.

This dynamic is occurring alongside broader structural shifts in the passenger car motor oil market, where full synthetic formulations are increasingly becoming the baseline, further narrowing the practical and commercial distinctions between product tiers.

In this context, distributors and independent blenders may benefit from confirming the composition and positioning of products marketed as “full synthetic,” and assessing whether formulation adjustments could affect performance or positioning.

Maintaining clarity and consistency in both formulation and communication remains essential for managing customer expectations in a dynamic market.

JobbersWorld will continue to monitor how EPL is applied across the industry and whether the discussion around synthetic labeling evolves in response to current conditions.

Editorial Note

This article is for informational purposes only and reflects industry analysis and expert opinion as of March 26, 2026. It does not constitute legal, technical, or regulatory advice. Readers should consult their own advisors and applicable guidelines, including API 1509, ILMA communications, OEM specifications, and FTC advertising standards, before making any decisions regarding formulations, EPL applications, or product labeling claims.