Outstanding work, Gene! :-) 

So, if I understand this correctly, the FTC will let companies know that they 
will be checking only that the net contents as stated using SI units will be 
checked. 

In other words, as a matter of their new selective enforcement policy, the FTC 
will not come down on anyone who puts stuff in a package that is labeled only 
in metric units (even though that technically violates the FPLA) provided that 
the stated quantity in SI units is correct. 

Does that sum it up correctly? 

thanks, 
Ezra 

----- Original Message -----

From: "eugene a mechtly" <mech...@illinois.edu> 
To: "USMA" <usma@colostate.edu> 
Cc: "USMA" <usma@colostate.edu> 
Sent: Wednesday, September 17, 2014 9:55:00 AM 
Subject: [USMA:54373] NIST Training Course for Checking the Net Amouts inside 
Packages 

First, I want to thank Ken Butcher for sending me various files in electronic 
format concerning the NIST Training Course for Officials who have the duty of 
verifying the net amounts inside packages intended for consumers in retail 
markets. 

My conclusion is that Metric-Only Enforcement of labeling declarations is 
completely compliant with requirements of both the current FPLA, and the 
current UPLR (as defined in the 2014 Editions of NIST Handbooks 130 and 133). 

Although "duality" of units of measurement (units from the SI and units from 
outside the SI) continues to be required on the labels of consumer commodities 
by the current FPLA, there is absolutely no exclusion of metric-only 
verification of net amounts inside packages by the current FPLA. The only 
limitation is that net amounts not be overstated, after rounding to three 
significant digits, by the part of the label stated in units from outside the 
SI. 

My hope is that the new revised FTC rules will be consistent with this 
interpretation. 

Eugene Mechtly 


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