Dear John,
I suspect that the three digit requirement is a hangover from the
'Rule of 1000'. As such it might not always be appropriate. Consider
the case of the quart (milk) bottle. If you need a metric indication
then 1136 millilitres would be relatively accurate but what would be
the legal value?
My view is that preference should be given to whole number indications
without fractions (vulgar or decimal) and that four digits should be
allowed to provide for whole numbers. See http://www.metricationmatters.com/docs/WholeNumberRule.pdf
This is how we did it in Australia. 1136 millilitres of milk was sold
for a year or two during the upgrade to the metric system and then
this size quietly disappeared in favor of 1 litre, 2 litre, and 3
litre milk containers.
Cheers,
Pat Naughtin
Geelong, Australia
On 2009/05/07, at 11:55 PM, John M. Steele wrote:
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/
Cheers,
Pat Naughtin
PO Box 305 Belmont 3216,
Geelong, Australia
Phone: 61 3 5241 2008
Metric system consultant, writer, and speaker, Pat Naughtin, has
helped thousands of people and hundreds of companies upgrade to the
modern metric system smoothly, quickly, and so economically that they
now save thousands each year when buying, processing, or selling for
their businesses. Pat provides services and resources for many
different trades, crafts, and professions for commercial, industrial
and government metrication leaders in Asia, Europe, and in the USA.
Pat's clients include the Australian Government, Google, NASA, NIST,
and the metric associations of Canada, the UK, and the USA. See http://www.metricationmatters.com
for more metrication information, contact Pat at [email protected]
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