16 CFR Parts 500-503: Rules, Regulations, Statements of General Policy or Interpretation and Exemptions Under the Fair Packaging and Labeling Act ("FPLA" or "Act") #00004

Submission Number:
00004
Commenter:
Martin Vlietstra
Organization:
private
State:
Outside the United States
Initiative Name:
16 CFR Parts 500-503: Rules, Regulations, Statements of General Policy or Interpretation and Exemptions Under the Fair Packaging and Labeling Act ("FPLA" or "Act")
Matter Number:

R411015

In response to "Section III Request for Comment, item 13" of your document, may I draw to attention that under British law (SI 2006:659, para 8.3 f&g), the only units permitted as supplementary indicators that may be used alongside metric units on pre-packaged goods marked in terms of weight or volume are the [Imperial] gallon, quart, pint, fluid ounce, pound and ounce. Since the imperial gallon is 4.54 litres and the US gallon 3.75 litres, any goods that are destined for the British market should avoid the use of US gallons, quarts or pints as this will breach UK law. The US fluid ounce does not present a problem as it is 4% larger than the imperial fluid ounce, there being 16 US fluid ounces in a US pint, but 20 imperial fluid ounces in an imperial pint. You might find it helpful if US companies that wish to export their goods to the United Kingdom be permitted to use metric units only in such cases as this will permit them to print the same label for both marketplaces. British law cited: Statutory Instrument 2006:659 - The Weights and Measures (Packaged Goods) Regulations 2006 - see attachment for full text.