I have commented on section 13 (Foreign regulation), drawing to attention the incompatibility of the US and the Imperial pint, quart and gallon. I also cited UK legislation that can be found at http://www.legislation.gov.uk/uksi/2006/659/pdfs/uksi_20060659_en.pdf (in particular section 8.3 f&g). My argument was that labels that need to comply with both UK and US regulations should not mention gallons, quarts or pints.
Others might find this useful to add to their own submissions. -----Original Message----- From: owner-u...@colostate.edu [mailto:owner-u...@colostate.edu] On Behalf Of James Sent: 02 April 2014 17:55 To: U.S. Metric Association Subject: [USMA:53670] Re: Fwd: FTC Solicits Comments on Rules, Regulations, Policy, Interpretation of FPLA (Deadline: May 21, 2014) This is an excellent opportunity for us to speak on behalf of permissive metric-only labeling. The odds of FTC agreeing to mandatory metric-only labeling are extremely low and comments pushing for that will be swamped by industry (FMI) lobbyists. But permissive metric-only stands a chance, I think. The usual guidance applies. Keep the tone temperate. Ensure there are no spelling errors, nor any factual errors. Be succinct, yet complete enough to show the logic behind the comment. Jim -- James R. Frysinger 632 Stoney Point Mountain Road Doyle TN 38559-3030 (C) 931.212.0267 (H) 931.657.3107 (F) 931.657.3108 On 2014-04-02 11:40, Metric Rules Info wrote: > Any thoughts?? > >> *Subject:* *FTC Solicits Comments on Rules, Regulations, Policy, >> Interpretation of FPLA (Deadline: May 21, 2014)* >> >> PLEASE DIRECT YOUR QUESTIONS AND SEND COMMENTS DIRECTLY TO THE >> FEDERAL TRADE COMMISSION - PLEASE DO NOT REPLY TO NIST. >> >> The Federal Trade Commission has issued the attached request for >> public comments on its rules, regulations and policy interpretations >> of the Federal Fair Packaging and Labeling Act (FPLA). >> >> We are providing a copy of this notice because you have indicated >> that you are interested in FPLA issues on the Office of Weights and >> Measures Client Database. >> >> *__* >> >> *_The FTC deadline for comments is May 21, 2014._**__* >> >> Hereis the FRN (see attachment) and the notice link >> (https://www.federalregister.gov/articles/2014/03/19/2014-06066/rules-regula tions-statements-of-general-policy-or-interpretation-and-exemptions-under-th e-fair). >> >> *__* >> >> *_FTC Q_**_UESTIONS:_* >> >> *__* >> >> Specifically, the Commission solicits comments on the following >> questions related to its current ruleswhich are available here: >> http://www.ecfr.gov/cgi-bin/text-idx?SID=8c87da7af86468db2374f6cfda5e >> a4e1&node=16:1.0.1.5.62&rgn=div5 >> >> >> (1) Is there a continuing need for the Rules as currently promulgated? >> Why or why not? >> >> (2) What benefits have the Rules provided to, or what significant >> costs have the Rules imposed on, consumers? Provide any evidence >> supporting your position. >> >> (3) What modifications, if any, should the Commission make to the >> Rules to increase their benefits or reduce their costs to consumers? >> >> (a) Provide any evidence supporting your proposed modifications. >> >> (b) How would these modifications affect the costs and benefits of >> the Rules for consumers and businesses, including small businesses? >> >> (4) What impact have the Rules had in promoting the flow of truthful >> information to consumers or preventing the flow of deceptive >> information to consumers? Provide any evidence supporting your position. >> >> (5) What benefits, if any, have the Rules provided to, or what >> significant costs, including costs of compliance, have the Rules >> imposed on businesses, including small businesses? Provide any >> >> evidence supporting your position. >> >> (6) What modifications, if any, should be made to the Rules to >> increase their benefits or reduce their costs to businesses, >> including small businesses? >> >> (a) Provide any evidence supporting your proposed modifications. >> >> (b) How would these modifications affect the costs and benefits of >> the Rules for consumers and businesses, including small businesses? >> >> (7) Provide any evidence concerning the degree of industry compliance >> with the Rules. Does this evidence indicate that the Rules should be >> modified? If so, why and how? If not, why not? >> >> (8) Provide any evidence concerning whether any of the Rules' >> provisions are no longer necessary. Explain why these provisions are >> unnecessary. >> >> (9) What potentially unfair or deceptive practices concerning product >> packaging and labeling, falling within the FTC's purview under the >> Act, are occurring in the marketplace? >> >> (a) Provide any evidence, such as empirical data, consumer perception >> studies, or consumer complaints, demonstrating the extent of such >> practices. >> >> (b) Provide any evidence demonstrating whether such practices cause >> consumer injury. >> >> (c) With reference to such practices, should the Rules be modified? >> If so, why and how? If not, why not? >> >> (10) What modifications, if any, should be made to the Rules to >> account for current or impending changes in technology or economic >> conditions? >> >> (a) Provide any evidence supporting the proposed modifications. >> >> (b) How would these modifications affect the costs and benefits of >> the Rules for consumers and businesses, including small businesses? >> >> (11) Do the Rules duplicate or conflict with other federal, state, or >> local laws or rules, such as those enforced by U.S. Food and Drug >> Administration? If so, how? >> >> (a) Provide any evidence supporting your position. >> >> (b) With reference to the asserted conflicts, should the Rules be >> modified? If so, why and how? If not, why not? >> >> (12) Provide any evidence concerning whether the Rules have assisted >> in promoting national consistency with respect to product packaging >> and labeling. >> >> (13) Are there foreign or international laws, regulations, or >> standards with respect to product packaging and labeling that the >> Commission should consider as it reviews the Rules? If so, what are they? >> >> (a) Should the Rules be modified in order to harmonize with these >> international laws, regulations, or standards? If so, why and how? If >> not, why not? >> >> (b) How would such harmonization affect the costs and benefits of the >> Rules for consumers and businesses, including small businesses? >> >> (c) Provide any evidence supporting your position. >> > >
