John (Steele),

The section titled "Uniform Unit Pricing Regulation" (UUPR) in Handbook 130 
(2013) is weak.

The bottom-line statement is "Finally, the NCWM does not want to include any 
requirement that may discourage retailers from voluntarily providing unit price 
information."

I recommend that the stronger statement: "Best Practice for Unit Pricing is 
'Price per Unit of measurement from the SI' i.e. price per gram, or price per 
kilogram or price per milliliter, or price per liter, or price per meter, etc.; 
as the consumer produce in question dictates."

Although I pay annual dues to the NCWM,  I do not have a vote in the NCWM, 
because I am not an appointed or elected *official* in the field of Legal 
Metrology.

Gene Mechtly
________________________________
From: John M. Steele [jmsteele9...@sbcglobal.net]
Sent: Thursday, February 20, 2014 3:50 PM
To: mechtly, eugene a; U.S. Metric Association
Cc: david.sef...@nist.gov; kenneth.butc...@nist.gov
Subject: Re: [USMA:53586] RE: Unit Pricing of Consumer Products in Retail 
Marketplaces

True, but the UPLR is not the only thing in H130.  There is also the UUPR, 
Uniform Unit Pricing Regulation, which, much like its title, is entirely about 
Unit Pricing.  There is a third Uniform Regulation in H130, which I would have 
to look up.

Here we go, from USMA site, the three Uniform Regulations in H130:

  *
NCWM Uniform Laws and Regulations in the Areas of Legal Metrology and Engine 
Fuel 
Quality<http://lamar.colostate.edu/%7Ehillger/laws/ncwm-uniform-laws.html>: The 
National Conference on Weights and Measures' model for state laws and 
regulations, consisting of several items, three of which we cover:
     *
Uniform Weights and Measures Law
     *
Uniform Packaging and Labeling Regulation (UPLR)
     *
Uniform Unit Pricing Regulation (UPR) (2009-02-26)


________________________________
From: "mechtly, eugene a" <mech...@illinois.edu>
To: John M. Steele <jmsteele9...@sbcglobal.net>; U.S. Metric Association 
<usma@colostate.edu>
Cc: "david.sef...@nist.gov" <david.sef...@nist.gov>; "kenneth.butc...@nist.gov" 
<kenneth.butc...@nist.gov>; "mechtly, eugene a" <mech...@illinois.edu>
Sent: Thursday, February 20, 2014 3:00 PM
Subject: RE: [USMA:53586] RE: Unit Pricing of Consumer Products in Retail 
Marketplaces

John (Steele),

Note that the Section on the UPLR in NIST Handbook 130 (2013) does not include 
*requirements*, or even any guidance whatsoever, on "Unit Pricing."  The entire 
focus of the UPLR (and the FPLA, for that matter) is on Retail Prices, not on 
Unit Prices.

There is *absolutely no requirement* in either the federal FPLA or in the UPLR 
(maintained by the NCWM) for inclusion of units from outside the SI in 
statements of "Unit Price" (Price per Unit of Measurement)!

This omission opens the door wide for new text in both the FPLA and the UPLR on 
Unit Pricing, expressed exclusively in Units from the SI!

Gene

From: owner-u...@colostate.edu [owner-u...@colostate.edu] on behalf of John M. 
Steele [jmsteele9...@sbcglobal.net]
Sent: Thursday, February 20, 2014 6:22 AM
To: U.S. Metric Association
Cc: david.sef...@nist.gov; kenneth.butc...@nist.gov
Subject: [USMA:53586] RE: Unit Pricing of Consumer Products in Retail 
Marketplaces

The existing Uniform Unit Pricing Regulation (from 2013 Handbook 130) already 
requires uniformity of the pricing unit for "like" products and ties the method 
of pricing to the method of declaring net contents.  I'm sure the working group 
is fully aware of the UUPR, but perhaps not all USMA readers are.

To quote from the document, the current units of measure for the unit pricing 
allow/require:

Section 2. Terms for Unit Pricing
The declaration of the unit price of a particular commodity in all package 
sizes offered for sale in a retail
establishment shall be uniformly and consistently expressed in terms of:
(a)Price per kilogram or 100 g, or price per pound or ounce, if the net 
quantity of contents of the commodity is in terms of weight.
(b) Price per liter or 100mL, or price per dry quart or dry pint, if the net 
quantity of contents of the commodity is in terms of dry measure or volume.
(c) Price per liter or 100mL, or price per gallon, quart, pint, or fluid ounce, 
if the net quantity of contents of the commodity is in terms of liquid volume.
(d) Price per individual unit or multiple units if the net quantity of contents 
of the commodity is in terms of count.
(e) Price per square meter, square decimeter, or square centimeter, or price 
per square yard, square foot, or square inch, if the net quantity of contents 
of the commodity is in terms of area.

On uniformity, it says:
Section 6. Uniformity
(a) If different brands or package sizes of the same consumer commodity are 
expressed in more than one unit
of measure (e.g., soft drinks are offered for sale in 2 L bottles and 12 fl oz 
cans), the retail establishment shall unit price the items consistently.
(b)
When metric units appear on the consumer commodity in addition to other units 
of measure, the retail
establishment may include both units of measure on any stamps, tags, labels, 
signs, or lists

I've seen minor misuse of section 2, eg., unit price by count for candy when it 
has a declared net weight, etc.  However, my grocery store chooses units so 
haphazardly as to imply that they are completely unaware of section 6, and 
think the purpose of unit pricing is to make sure you CAN'T compare sizes and 
brands.  I would certainly like to see more use of SI unit pricing, but I 
consider enforcement of the "uniformity" requirement to be far more important.  
It is widely misused and abused to confuse the customer.

Because each store can choose its own uniform units for each commodity, UUPR is 
completely useless between stores.  Perhaps section 2 needs to reduce choice 
and specify one and only one unit for each category of net content declaration. 
 Another area that should be considered is how broadly is a commodity defined.  
Coke and Pepsi are both cola-flavored soft drinks and I am pretty sure they are 
the same commodity.  How about other flavors such as ginger ale?  How about 
bottled waters?  They all quench thirst but if they are treated as different 
commodities, comparative pricing can be avoided, to the confusion of the 
customer.  Too much choice is either allowed or is utilized by the merchants 
without any enforcement.
________________________________
From: James <j...@metricmethods.com>
To: U.S. Metric Association <usma@colostate.edu>
Cc: "david.sef...@nist.gov" <david.sef...@nist.gov>; "kenneth.butc...@nist.gov" 
<kenneth.butc...@nist.gov>
Sent: Wednesday, February 19, 2014 8:34 PM
Subject: [USMA:53584] RE: Unit Pricing of Consumer Products in Retail 
Marketplaces

I'm glad that you were able to take part in that, Gene. You've got some
good background knowledge for a foundation for your views on that topic.

I'm sure that you, as I do, find it frustrating to see one can of a
product unit priced in cents per fluid ounce and another can unit priced
in cents per pint.

Jim
On 2014-02-19 19:24, mechtly, eugene a wrote:
> Please note the correction of the second word in my email.
>
> Eugene Mechtly
>
> ________________________________________
> From: mechtly, eugene a
> Sent: Wednesday, February 19, 2014 7:15 PM
> To: U.S. Metric Accociation
> Cc: david.sef...@nist.gov<mailto:david.sef...@nist.gov>; 
> kenneth.butc...@nist.gov<mailto:kenneth.butc...@nist.gov>; mechtly, eugene a
> Subject: Unit Pricing of Consumer Products in Retail Marketplaces
>
> Unit Pricing may be defined as Price per Unit of Measurement in retail 
> markets.
>
> Some examples are: dollars per liter for bottled water, cents per milliliter 
> for eye drops, cents per gram for nuts, seeds, or berries, dollars per 
> kilogram for flour, cents per meter for dental floss, etc.
>
> A Guiding Principal is that a sIngle expression for the Unit Price (price per 
> measurement unit) must be applied to all items of a given category, from all 
> packers, in all package sizes, or from random size packages, or from bulk 
> distribution, in each particular retail establishment, to enable consumers to 
> compare cost and value of each and every brands of that category offered for 
> sale in each particular retail store.
>
> A Web Meeting of a NIST Working Group on Unit Pricing was conducted earlier 
> today.
>
> David Sefcik of NIST is the leader of this Working Group.
>
> About twenty members of the Group, including several from Australia, 
> participated today.
>
> A Unit Pricing Guide is being drafter by the Group.  The Guide is presently 
> in the form of "Draft Version 6."
>
> Version 6 is not confidential, although the Final Version has not yet been 
> written or approved by the Working Group.
>
> By participating in this Group, i hope to advance the use of SI in Unit 
> Pricing, just  as grams and milliliters are presently found on Labels of 
> Nutrition Facts.
>
> The existing FPLA *does not* require that Unit Prices be expressed in units 
> outside the SI.  The existing FPLA requires only that units outside the SI be 
> *included* in declarations on labels of the net amounts offered for sale.
>
> Eugene Mechtly
>
>
>
>





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