Threats to product-labelling we take for granted?

QCA encourages consumers and consumer organisations to comment on quantity statements

The Queensland Consumers Association (QCA)has made a submissions to the Consultation on Labelling etc of Pre-packaged Products.

The consultation is being undertaken by the National Measurement Institute on draft new international recommendations (R79 and R87) on labelling and other requirements for pre-packaged products (including food) issued by the International Organisation of Legal Metrology (OIML).

The recommendations deal with some very important consumer issues often taken for granted for example:

  •  location and display of quantity statements on packages
  •  drained weight
  •  misleading package shape
  •  slack fill.

The key points in QCA’s submissions are:

  • Strongly support retaining the current requirement that the quantity information be displayed on the principal display panel. (The reasons why it should be retained are provided below).
  • Support continuing to require that all quantity information on packages be very easy for consumers to notice, read, and understand.
  • Support expanding the recommendations to include products in random quantity packages.
  • Support continuing that it be optional to provide drained weight information for products packed in a liquid medium not intended for use, but suggesting that if this is provided any words used to describe drained weight be unable to be confused with words used for other quantity information, for example “net weight.
  • Emphasise that regulatory agencies must monitor and enforce requirements that packages not mislead regarding product quantity, identity, and fill level.

Why consumers need the quantity information on the principal display panel

Consumers need this information in this location so that they can quickly and easily:

  • assess whether the quantity is what they want
  • compare the quantity in alternative packages (including packages that are the same size but contain different amounts of product)
  • calculate and compare the unit price when, as is common in many countries and stores, the unit price is not provided and must be calculated by the consumer.

Having the quantity information in this location also helps to keep consumers aware of, and using, quantity information and to notice when quantities change.

Even though some retailers put the quantity information on shelf labels this is not an acceptable substitute for it being on the front of packages because

  • often retailers are not required to put quantity info on the shelf label and some do not.
  • the quantity info on shelf labels can be inaccurate.
  • many retailers do not use shelf labels
  • consumers need the quantity info in front of them on packages when packages are displayed for sale in a store.
  • at home consumers need to be able to easily and quickly see how much is in a  packaged product.

Provide your views to the consultation process

QCA urges consumers and consumer organisations to support their submission. This can be done by sending an email to

QCA is very concerned that consumer interests in clear labelling will be overridden.  For example, partly due to consumer inertia, the wine industry no longer has to show the volume on the front label of most wine bottles, and the Australian food industry is likely to want this exemption extended to other industries.

CFA has contacted the National Measurement Institute to express its support for the submission made by QCA.