I have noticed a few products in my home that should be covered under the FPLA or UPLR and don't appear to meet the labelling requirements. Given FMI's opposition to permissive metric only, I wonder if we do any good pushing manufacturers who presently have compliance issues, pushing them to comply, and making them aware of our preference for the the much simpler SI only labelling. It is a little difficult in some cases to determine whether FPLA or UPLR apply, and exactly which section of the law is not complied with, or whether an exemption complies. However, the laws are pretty well summarized on the USMA site, I will start the Rogue's Gallery with three noncompliant products and invite others to contribute: No SI declaration at all (does not comply with the FPLA, 15 CFR 1453(a)(2)) *Williams Mug Shaving Soap, Net Wt 4 oz. SI declaration uses more than three digits (does not comply with FTC rule supporting FPLA, 16 CFR 500.19(b), same requirement in UPLR if that is what actually applies) *Aquafresh Fluoride Toothpaste (Triple Protection Advanced), Net Wt. 5.6 oz / 158.8 g *Red Star Active Dry Yeast, 4 oz / 113.4 g I wrote the first two some time ago and did not get a response. I just noticed the Red Star, and the body of my e-mail to them follows:
I recently bought a 4 oz bottle of Red Star Active Dry Yeast for use with my bread machine. First, let me say that it works just fine. I am writing to comment on the product labelling. The Net Contents of the bottle are labelled as 4 oz. / 113.4 g. The United States has required dual labelling of consumer goods in both Customary units and metric (SI) units since 1994 under the Fair Packaging and Labelling Act (FPLA). Your label meets the basic intent of labelling in both unit systems. However, the Federal Trade Commission has a set of detailed regulations applying to FPLA under 16 CFR 500. In particular, section 500.19(b) requires the SI value to be expressed in no more than 3 digits. Your 4 digit declaration, 113.4 g, would appear noncompliant, and the logical choices would be to claim 113 g at the present fill, or claim 114 g and fill accordingly. (Either declaration may be rounded down, the larger claim must be true.) Please note that I am neither a lawyer nor involved in FPLA compliance. I am an educated consumer who believes the US should go metric. I would prefer to see the FPLA amended to permit (not require) SI-only net content labels. In the meantime, I would prefer to see manufacturers comply with the existing requirements, particularly the metric requirements. Sections of the relevant laws are linked at the US Metric Association site, although you may prefer to get them from other sources. http://lamar.colostate.edu/~hillger/laws/
