The NSF has released a new Registration Guidelines for Proprietary Substances and Nonfood Compound in January 2021.
Among other things it acknowledges the need to issue a new classification category for lubricants used to manufacture articles that contact food.

Previously, such products were classified as miscellaneous and given the category code P1. Now, lubricants complying with the provisions of 21 CFR 178.3910 (Surface lubricants used in the manufacture of metallic articles) are now exclusively under the category of U1, Metal Working Fluids.

As this corrects the previous classification of P1 it also puts a distinction between, H1 and U1, where H1 is now confined to 21CFR 178.3570(b), for use on food processing equipment, lubricants for machine parts and equipment in locations in which there is exposure of the lubricated part to food, or incidental food contact.
Lubricants for use in the manufacture of metallic articles that contact food are exclusively classified under category code U1.

The category code P1 still remain for miscellaneous products.

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