I reposted the list of reasons below. My comments are listed under each of the points in RED color. θ consumers are not demanding that their food products be packaged and labeled using the metric system. In my opinion a voluntary option to metric only labeling would not conflict with this statement. If a product was metric only labeled and consumers were turned off to it, then the product won't sell and the manufacturer would be forced to put the English units back on.. This comment is confusing voluntary with forced metric only and forced repackaging in rounded metric sizes, which voluntary does not mean. θ Value-comparison between similar products of various sizes may be difficult to determine for consumers if some manufacturers use the metric-only option and others use inch/pound. If the industry was interested in value comparison, then they would support universal unit prices labels that were clear and consistent. I have noticed many products alreay that are rounded metric with inch/pound equivalents such that they can not be easily compared to rounded inch/pound. The FMI seems to be ignoring this point. θ Retailers will be faced with consumer complaints when value-comparison cannot be determined. As already noted, value comparison is difficult as is with the present labels and sizes. The way to assure value comparison is via clear and consistent unit price labels. θ International interpretations of metric requirements would likely result in package size changes. It is already that way. I have seen some foreign products on the shelves in both metric and English units where the metric is round and the English is not. Forcing the addition of English units on the packages does not automatically mean the product sizes will be rounded English. Metric only doesn't mean a product will change to metric only. A product labeled as 1 lb 454 g would just become 454 g. θ Changes in package sizes will make certain display cases, such as the dairy case and push-in display racks obsolete. Again, voluntary metric only labeling does not mean change in package sizes. Why is this being made an issue? Anyway, don't producers often change package sizes without metrics being an issue? θ Metric will also impact other types of equipment in the grocery store, including bakery pans, scales, scanners, computers, and other types of measurement equipment, requiring costly conversion or replacement. All of this will occur simply by not listing an english unit on a label? Wow! Does anyone at the FMI know what the word voluntary means as in reference to labels? Why would dropping English units from labels require a change in all of the items listed? θ Shipping cases will even have to be replaced if metric-only is an option. Why would they have to be if all that was being allowed was to drop English units from a label? θ A metric-only option may conflict with domestic feeding programs. What? How? You mean Americans won't be able to eat any food from packages without English units on the label? θ Packagers may change display-only in metric units and that will require changes in unit pricing labels. So? As long as the unit pricing was in the same unit what would it matter? You can also have a metric only label, and a dual unit price label or metric only unit price label. Where is the problem here? θ There is a cost for the retailer associated with label changes, including design cost and plate changes (plates can cost in the neighborhood of $1,000). But the label change would be voluntary, which means if the producer or reatiler finds it too costly, then they can decide not to change. θ Retailers typically keep a label inventory of about 50 weeks. So? And if they decide not to change they can keep dual labels forever. What does this comment have to do with voluntarily dropping English units from labels? θ Retailer’s operating companies forecast what business might be like in the future (ex: tomatoes) and make future labels accordingly (thus, more label inventory).. Don't companies change labels from time to time anyway? So when they naturally lan a label change for other reasons they can decide to drop english units if they wish, so again, where is the problem. θ In addition to unit pricing, a metric-only option will also impact UPC codes and price advertising as well as nutrition information and recipe programs. How? The product UPC code shouldn't change and nutrition is already given in metric only. How would it affect the way it is advertised? I often see price adds for 2 liter soda bottles with no mention of ounces. This does not seem to affect the advertizing as they claim. As outlined above, converting to metric is more than simply changing labels to make metric the primary method for declaring net contents on a package. Compliance costs necessary to convert to metric are significant, exceeding $1 billion for the food industry. These costs will be passed on to consumers, including food stamp, WIC recipients and the elderly, who will see their purchasing power dramatically reduced when buying groceries, with no added value. The FMI seems to be very ignorant and can't seem to differentiate the difference between "converting a product to metric" and simply allowing a producer to label in metric only if they want to. How will simply dropping English units affect all of these areas? Has anyone challenged any of these points? As you know, the federal government attempted to convert to metric in the mid-1970's, and the metric experiment was a dismal failure. There is no competitive advantage to be gained by mandating or allowing for a metric-only option for consumer products that are bought, used or consumed in the United States, especially food products. If a manufacturer needs to label a product metrically to be globally competitive, the company will do so. The conversion to the metric system failed due to the way it was handled. That should not be an issue now. Again, the amendment would allow voluntary change and the FMI is making it out to be like it is mandatory. Someone needs to set them straight. Thank you again for your consideration of our views. If Ken Butcher fell for their arguments and did not challenge them then shame on you Ken. If the USMA members really feel strongly about the right for a producer to have metric only labels if they so desire, then they should have no problem bringing to the attention of those who will listen that the points the FMI has brought up are completely without merit. Has anyone done so as of yet or does anyone plan to? Jerry The majority of consumers do not understand metric measurements. Moreover,
________________________________ From: Paul Trusten <[email protected]> To: U.S. Metric Association <[email protected]> Sent: Thursday, February 19, 2009 10:32:44 AM Subject: [USMA:43080] discussion of Food Marketing Institute objections to metric-only labeling option To the USMA Listserver: Attached is a 2002 letter from the Food Marketing Institute (FMI) to the NIST Laws and Metric Group, outlining the Institute's objections to amending the federal Fair Packaging and Labeling Act (FPLA) to allow optional metric-only labeling on U.S. consumer products. The letter is posted on the NIST Web site at http://ts.nist.gov/WeightsAndMeasures/Metric/upload/fmicomments.pdf. I have been informed that FMI has restated these 2002 objections at a recent meeting. FMI is a U.S.. trade association of about 1500 food retailers and wholesalers (for a member list, see http://www.fmi.org/forms/MemberDirectory/viewMemberDirectory?reportType=domesticrw#S) . Apparently, tt has considerable sway over laws pertaining to U.S. packaging and labeling, and is supposed to be the principal opponent to labeling metrication. For more information about the organization, see www.fmi.org. I am asking our Listserver subscribers to study this letter carefully and post their solutions to FMI's objections to the proposed amendment. I am also asking that you please do not forward your suggestions to FMI. FMI has made its positions clear, and I don't think we want to bombard it with ours. However, I feel we should have a focused discussion of the issues it continues to raise. Please take time to think. I shall be collecting and saving your ideas. Thanks very much! Paul Paul Trusten, R.Ph. Public Relations Director U.S. Metric Association, Inc. www.metric.org 3609 Caldera Blvd. Apt. 122 Midland TX 79707-2872 US +1(432)528-7724 [email protected]
