US EPA's Vessel General Permit (VGP) and similar regulations require the use of EALs in oil-to-sea interfaces on US-flagged vessels unless technically infeasible. Products classified under 59774 — particularly those meeting OECD biodegradability and aquatic toxicity standards — are often the preferred choice for marine compliance, making EAL certification a key commercial differentiator for importers supplying the marine sector.

Yes, particularly for blended formulations that contain both bio-based and mineral oil components. The classification turns on whether the oil or grease is sourced from petroleum or non-petroleum origins, and a blend with even moderate mineral oil content may shift classification to 59772. Importers should obtain detailed composition data and consider a binding ruling for any formulation that combines petroleum and non-petroleum lubricating components.