Here’s a refutation of the FMI comments against allowing metric-only labeling:

The comments can be found at: http://ts.nist.gov/WeightsAndMeasures/Metric/upload/fmicomments.pdf

Summary: A version of the FPLA which allows metric-only labels (and disallows US Customary-only labels) will not directly have an impact on packages sizes or prices. The arguments used to inflate the cost to the Food Marketing industry are mostly invalid.

Furthermore, nothing in the proposed FPLA changes deny retailers the option of placing supplementary size information on the shelf. Thus if a metric-only labelled product seems to be causing an issue with customers at a particular store, that store may print and place a shelf label stating “255 g (9 oz).”

- “The majority of consumers do not understand metric measurements. Moreover, consumers are not demanding that their food products be packaged and labeled using the metric system.”
= A large majority of customers don’t _care_ how things are labeled when it comes to comparison. Customers do care when it comes to including products in a recipe.
= Food packaged with metric units with an allowed optional alternative US Customary unit (no more prominent than the metric unit) would still allow customers to purchase enough flour, as an example, for a recipe. But I don’t typically buy sugar and flower by the amount on the label, I eyeball the size.
= People aren’t demanding it because they don’t care and usually don’t use the labels on the package. I, for example, use the Nutrition Information chart far more often than I use the package size label.

- “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.”
= True … if an either/or/both scenario is allowed. Requiring metric and optionally allowing US Customary solves this issue since everything will have (at least) metric units.
= Metric will make it _easier_ to compare sizes. Customers will just look for the metric label on the dual-labeled product. Two differently sized cans of beans labeled in grams can easily be punched into a calculator for the price

per gram. With US Customary conversion factors (lb, oz … but don’t confuse that conversion factor with gallons/pints/quarts/cups/_fluid_ ounces), the process of converting one unit to another becomes much more difficult.

- “International interpretations of metric requirements would likely result in package size changes.”
= This argument makes no sense. How would international interpretations of how to _label_ cause a company to think that the _size_ must be changed?
= Since all international companies use metric at home, why would using metric in the US suddenly cause them confusion?

- “Changes in package sizes will make certain display cases, such as the dairy case and push-in display racks obsolete.”
= These racks become obsolete or rusted all the time. It’s a cost of doing business.
= My retailers all use flat shelves with modular product spacing because products already come in many sizes. Thus retailers would only have to adjust the shelves and displays they already have … IF a product actually changes in size.

- “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.”
= The FPLA does not apply to loose goods such as goods cooked on bakery pans, measured on scales, calculated by weight at the register.
= Scanners will still read the same bar codes.
= When (not if) metric measures are applied to loose goods and goods packaged in the store, scales will have to be reprogrammed or replaced (if metric units were required for loose goods .., computers and cash registers will have to be reprogrammed.
= Computers are easily reprogrammed all the time to reflect price changes.
= When (not if) metric measures are applied to loose goods, Muffins won’t change in size. Bread won’t change in size. Baking pans will still be flat.
= Replacement/new scales and software purchased before the inevitable metric switch should include the ability to display in metric as a contingency - it doesn’t cost that much extra when you design it right from the start.

- “Shipping cases will even have to be replaced if metric-only is an option.”
= Shipping cases are already designed for the product shipped in them.
= Products are already a great variety of shapes and sizes thus already necessitating a variety of shipping case sizes.
= Shipping case sizes are the manufacturers’ problem, not the retailers’ problem.
= When manufacturers decide that their product should be internationally salable, they’ll switch to metric sizes anyway and the retailers will just have to deal with it, anyway.
= Where the retailer is the manufacturer, the manufacturing branch of the company will make the packing decisions.

- “A metric-only option may conflict with domestic feeding programs.”
- “In particular, the WIC program would be affected. The WIC program specifies certain package sizes that may not be compatible with metric requirements.

For example, under the WIC program, the following items are specified container sizes and there can be no substitutions: milk, gallon or half-gallon; canned milk, 12 ounces; non-fat dry milk, 1 pound box; canned juice, 46 fluid ounce can; infant juice, 4 fluid ounces. This will vary slightly by state. Because of this, each state would have to change or convert their package size specifications.”
= Products intended by the manufacturer to be sold to WIC may continue to be labeled and sized according to WIC rules. Retailers may continue to work with manufacturers to specify which products fall under this category.

- “Packagers may change display-only in metric units and that will require changes in unit pricing labels.”
- “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).”
- “Retailers typically keep a label inventory of about 50 weeks.”
- “Retailer’s operating companies forecast what business might be like in the future (ex: tomatoes) and make future labels accordingly (thus, more label inventory).”
= These arguments don’t make sense. Are unit pricing labels the label on the shelf? If so, those get changed every at least every two weeks and as often as daily at the (computer) store I used to work for. I assume that food retailers have similar practices so that the sale price remains flexible and competitive.
= My former retail employers already had inexpensive ways of changing prices such as price sticker guns (for the toy store) and laser-printer-based shelf labels (for the computer store). Kroger appears to use laser-printed shelf labels. Publix, too. Ditto for Whole Foods and Ingles. Ditto for QuikTrip (gas station).
= Laser printed shelf labels are fast to deploy and cost only-fractions of a cent per product changed. Price sticker guns cost a little more in time and a whole lot less in materials.
= Once the metric-only OPTION is law, retailers and manufacturers will have plenty of time to change their advertising papers before any given sale.
= Once the metric-only OPTION is passed, retailers will have plenty of time (thus price change cycles) to change store labels to reflect metric-units.
= The FPLA metric-only OPTION can be passed with plenty of lead time and/or a grace period for changes necessary to software and scales.

- “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.”
= Unless a product size is changed by the manufacturer on the manufacturer’s terms, there will be no impact on the product size and thus no impact on the UPC.
= Retailers already deal with inventory changes daily. Since no mandated change will occur in package sizing, no impact will occur.
= The only impact on the Nutrition Information panel should be a change in what unit the serving size is displayed in. It would make the entire Nutrition Label metric instead of everything except the serving size. Manufacturers could take the opportunity to make serving sizes reasonable (rather than, for example, 1/5 of a pizza when 1/8 or 1/6 is more likely).
= Recipes will only be affected occasionally. Retailers can assist customers through a transition by printing inexpensive but attractive conversion cheat sheets thus attract customers to their stores versus stores that don’t provide cheat sheets.
= Customers will quickly adapt their recipe(s) by making a note on the recipe card(s).

This is the same in the UK. As for a pound of something and you get a metric amount. Too bad the UK doesn’t let the pound become 500 g and the pint 500 mL. It may perpetuate the use of the terms for a long time, but it should reduce the negative effects of the muddle.

It is also sort of funny that the FFU-ists love to point out the remnant use of old units. Pints of beer in pubs, some milk containers, miles on roads, etc. Everything else is metric. The goal of the UK must be to remove any obstacles to these last areas metricating.

There doesn’t have to be a compulsion to sell beer and milk in litres, but it shouldn’t be outlawed either. Even if the UK doesn’t plan to metricate road signs, there is no reason to ban the use of metric signage.

What is being done now to remove these anti-metric restrictions?

But If you should ever be in Weybridge it would be fun to meet - and maybe share a pint (or even a half litre) and put the world to rights. Cheers

Robin replies: It is not a question of being stupid. Without a reason or incentive to adapt to a different system, people will quite naturally stick with what they know. This inertia is reinforced by the wholly misleading populist campaigns to portray metrication as a foreign imposition. There is nothing authoritarian about defining the units of measurement which must be used for all “official, legal, contractual and trade purposes”. That is what the 1824 Weights and Measures Act did in defining the standard imperial system.

Steve Jones clearly thinks it is alright for everybody to use whatever measurement units they like - whatever the consequences for consumer protection, public safety, children’s education and general incomprehension. However, if you believe that one system is better than two (or more), then it is necessary to find ways of phasing out the obsolete system. If you advocate voluntary change, in the knowledge that it will never happen, you are implicitly condemning the UK to permanent muddle. Maybe that’s what he wants.

This contrasts with the efficient way in which Australia, New Zealand, South Africa and indeed most Commonwealth countries made the change within about 10 years.

Without an element of compulsion (as far as official, legal and trade uses are concerned), completion of metrication will never happen. Anyway, weights and measures law has always been compulsory.

For a fuller explanation see http://www.ukma.org.uk/Campaign/index.htm
and the links from that webpage.

We must be just waiting for further laws and prosecutions until that day when enlightenment dawns and we will stumble gratefully from the murky depths whispering ‘Thank You, Bless You’ to you - our rescuers.

Sadly it ain’t like that. By your own arguments, the imperial system should have withered and died years ago in favour of the intellectually superior metric. Much like Marx’s theoretical prediction about the death of capitalism in the 1850s. Well, Karl, we’re still waiting.

But imperial survives - because it as a convenient, practical and familiar system. Traders would not sell in pounds and ounces if there was an overwhelming demand for kilograms. (BTW - I think your implicit assumptions that anyone selling in imperial is a rogue, vagabond or cheat very offensive)

I was talking to a very intelligent young man yesterday. He is 18 and has been educated completely in metric. But he still describes hs height in feet and inches and his weight in stones and pounds. And he has no idea what the metric equivalents are.

Maybe, just maybe - when his grandchildren are growing up - there may be a case for converting completely to metric - as imperial will be extinct anyway. But until that day comes I suggest that you continue to stress the benefits that you perceive for the metric system, while removing the elements of compulsion, coercion and prosecution that you seem so keen on.

There is no more surefire way to annoy the general public than to adopt the ‘De Haut en Bas’ approach of intellectual superiority that is all-pervasive in your site. A great way to start a campaign to ‘Save the Pint’ is to threaten to ban it. Neil Herron and Steve Thoburn understood this to great effect and with great public support - even among some TSOs that I know.

Arrogant intellectual complacency will not win you the argument.

The FMI (Food Marketing Institute) is an American lobbying group that has a big influence when it comes to metric only packaging. They are opposed to amending the FPLA to permit metric only labelling. The PDF file explains their views.

Personally I feel that if they keep the FPLA from being amended, then the EU metric only directive must also not be amended.

Robin, in your Letter to Paul, I never made such an assumption that adopting the UPLR made the use of metric only in New Jersey a signed deal. I may not have been clear, but I thought those who post here understood the difference between the FPLA and the UPLR.

I agree completely with what Paul said. I hope everything is clear now.

Robin, you also wrote:

“This is of vital importance to the UK since US insistence on dual
marking is prejudicing our attempts to phase out imperial and
US-customary marking within the EU.”

I would think this is the intent of the US. This is exactly what they don’t want to happen, that is to have FFU (Fred Flintstone Units) phased out. They want the EU to amend their directive to allow FFU forever but are resisting amending the FPLA to allow metric only labelling fearing that just allowing it will spell the demise of FFU that much faster.

Dear Robin,

Thanks for writing. Yes, the FPLA’s dual-labeling requirement still holds for
products subject to it.Products subject to the FPLA must still be dual-labeled
in New Jersey. The “excitement” we feel over here now has to do
with the steady success of the Uniform Packaging and Labeling Regulation
(UPLR), a model regulation authored by the National Council of Weights and
Measures in 1952, and amended in 1999 to include a provision for the optional
use of metric units only, on products not regulated by the FPLA, and thus
subject only to state regulation. Since that amendment was added to UPLR, 48 of
the 50 state governments have adopted it, New Jersey being the latest. New York
and Alabama are the only states left that have apparently not yet approved the
UPLR option. The NIST Laws and Metric Group tells me that all of the non-state
U.S. territories (the District of Columbia, Guam, the U.S. Virgin Islands,
Puerto Rico, and American Samoa) have also adopted the metric-only UPLR option,
so once New York and Alabama decide in favor of it, then every location in the
U.S. will allow it on that basis.

The U.S. Constitution empowers only the Congress to establish the standard of
measurement for the country. It is not a state function. The UPLR is not going
to be “the thing” that will make this country go metric. However, unanimity
among the states with regard to this particular labeling practice via the UPLR
will strengthen the argument for supporters of U.S. metrication to press the
case for the really important move: amending the FPLA to allow the metric-only
labeling option for the vast majority of products sold in the U.S. Once metric
units are able to stand alone legally on U.S. products, industry and public use
of SI will be accelerated considerably, and, I also believe (as you say),
progress on continued UK metrication will be given a major boost.

Please write back with more questions if any of this is unclear.

SI-incerely,

Paul Trusten, R.Ph.
Public Relations Director
U.S. Metric Association, Inc.

Quoting Robin Paice

>> Dear Mr Trusten
>>
>> Can you please clarify this statement?
>>
>> http://www.mail-archive.com/usma@colostate.edu/msg28726.html
>>
>> The announcement suggests that the state of NJ will permit metric-only
>> labelling for all packaged products sold within the state. However, our
>> understanding is that the FPLA takes precedence over state law, and
>> therefore products that are regulated at the federal level (including
>> most foodstuffs and some household goods) must still be dual marked -
>> whatever the NJ authorities may have said. Have we got this right?
>>
>> This is of vital importance to the UK since US insistence on dual
>> marking is prejudicing our attempts to phase out imperial and
>> US-customary marking within the EU.
>>
>> Can you help?
>>
>> Best wishes
>>
>> Robin Paice
>> Chairman UK Metric Association