FSIS Proposes Elimination of Dual Net Content Labeling
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EmailNeal Fortin, Director of MSU's Institute for Food Laws and Regulations, explains implications of the USDA FSIS' proposal to eliminate dual net content labeling.
The USDA Food Safety & Inspection Service (FSIS) proposed amending its labeling regulations to remove the requirement for dual declaration of net contents on packages that contain more than one pound or one pint but less than four pounds or one gallon. Under the proposal, meat and poultry packages in these ranges would be allowed to express contents in one of the avoirdupois units of measure instead of both. For example, the net weight could read, “56 oz.” or “3.5 lbs.” rather than “56 oz. (3.5 lbs.)”
In its preamble to its proposal FSIS states, “If the proposed changes are finalized, FSIS expects the net weight and content requirements will be clearer and there will be fewer . . . questions and less misunderstanding of the net weight and content requirements.”
What do you think? Will clarity be achieved by eliminating the dual listing? If clarity is the goal, wouldn’t it be simpler to list just in the largest whole unit? That is, wouldn’t it be simpler to always label three pounds as “3 lbs.” As proposed, three pounds would sometimes be “3 lbs.” but sometimes “48 oz.” other times “3 lbs. (48 oz.)” and still other times “48 oz. (3 lbs.)”
You can let FSIS know what you think of their proposal. FSIS is asking for comments by June 17, 2019. Comment here:
https://www.fsis.usda.gov/wps/portal/fsis/topics/regulations/federal-register/proposed-rules
