PowerPointPrsentation

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Workshop on harmonisation of requirements for
pre-packed goods In Mediterranean
Region Welcome Ladies and Gentlemen of the
Mediterranean Sea neighbouring
states Valletta, 24 - 25 June 2004
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Another title could read as followsConsumer
protectionorHow to control pre-packages
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Introduction
I would like to divide my lecture into several
parts A) Historical review B) Regulations
of package labelling C) Sampling plan of the
EEC and terms used in package checking D)
Requirements for the unit price for
pre-packages E) General unit price declaration
and the advantage for the consumer F)
Experiences with the supervision in Germany
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Historical review
At first a review - an introduction into the
history Until the year 1969 we used the
preventive system in Germany to protect the
consumer that meant, all balances of the filling
industry had to be calibrated and verified. So,
the industry was forced by legal metrology to use
only verified filling machines to produce the
packages.
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Historical review
But the great mistake in this system was nobody
knew what the real net content of the packages
was and nobody could rely on the content.
Up to this time the word pre-package was unknown.
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Historical review
With the new act of the Law of Weights and
Measures in 1969 we changed from the preventive
to the repressive system.   From then on the
balances did not need to be calibrated any more.
But the authority controls since that time the
net content and labelling of the produced
packages using statistical quality control.
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Historical review
But there is a little restriction the producer
has to use verified and suitable measuring
instruments. And he is forced to make notes of
his quality control.   Nowadays, if it is not
okay, the producer will get a punishment. This
fine can amount up to 10 000 Euros.
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Historical review
You see, the act is from 1969 and the ordinance
about pre-packages was published one year later
in 1970.   So we have been controlling
pre-packages in Germany since more than thirty
years. Years later we came to a full
harmonisation with Europe and now we are speaking
about the
EUROPEAN Pre-package Directives
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Regulations of labelling
Regulations of labelling Today, nearly the
whole world prefers this principle.   The idea of
the legislator is Each of the consumers should
buy and get on average the indicated promised
quantity, filled in packages of the daily
use. We are speaking about the average or mean
value principle. And it is very simple, that is
to say
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Regulations of labelling
It should be marked what is inside, and it
should be inside what is marked. on average
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Regulations of labelling
At this point it is important to find out the
very exact definition of a pre-package. How to
describe? In Germany we defined it in
1970, and nine years later the Europeans gave
the definition
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Regulations of labelling
In 1979 the EEC gave the following
definition   Article 2 (2) of Directive
75/106/EEC shall be replaced by the
following '2. A product is prepacked when it is
placed in a package of whatever nature without
the purchaser being present and the quantity of
product contained in the package has a
predetermined value and cannot be altered without
the package either being opened or undergoing a
perceptible modification.
Any more question what a pre-package is??
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Regulations of labelling
Furthermore we say weight declaration for solid
products and volume declaration for liquid
products, in general but there are some
exceptions like ice cream, aerosols and some
others. By the way my opinion is the less
exceptions, the better. In most cases weight is
easier to control.
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Regulations of labelling
Then the producer has to mark the quantity well
visibly on the pre-packages - the European
prescriptions depend on the package weight or
volume. The Europeans say minimum 2, 3, 4, and
6 mm - for up to 50, 200, 1000 g or ml and more
than 1000 g or ml. These only for the numbers and
not for the letter size. Example 500 ml, 375 g
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Regulations of labelling
      Number size
 
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Regulations of labelling
For a good consumer protection I advise the
producer to make it better - to go up to minimum
4 mm that should work for the industry. There
is a lot of space on the package for the list
of ingredients and of course for the EAN Code to
scan the price so, why not for well information
big letter sizes?   Some producers take big
numbers of there own free will.   E. g. look at
Kelloggs - our producer of detergents. Other
specialities in labelling is by count, length and
area.  
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Regulations of labelling
It cannot be that the consumer has to take a
magnifying glass when going shopping!!
I think, in some cases it is an impudence against
the consumer.
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Regulations of labelling
Another idea could be, to define the letter size
in dependence on the volume size of the package.
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Regulations of labelling
Drained weight A very special case for weight
indication is the drained weight. For some
pre-packages which contain an infusion liquid, it
is prescribed to declare beside the total weight
also the drained weight. Such
pre-packages are sausages in tins or glasses,
all vegetables and fruits in containers etc. An
infusion liquid is a liquid which is unimportant
in contrast to the product. Therefore, it is
not relevant for the buyer. Those liquids are
water, salt water, sugar water ...
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Regulations of labelling
Specifying
In contrary to the essential parts of the
pre-package the infusion liquid has only a
secondary role and is therefore not interesting
for buying e.g. water, aqueous solutions of
salts, brine, aqueous solutions of food acids,
vinegar, aqueous solutions of sugars, aqueous
solutions of other sweetening substances, fruit
or vegetable juices in the case of fruit or
vegetables.
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Regulations of labelling
Here are some examples for drained weight
products
Peeled tomatoes
For vegetables
Products in water or salt water
Mushrooms
(Sausages)
Cucumbers
Peas
Beans
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Regulations of labelling
Fruits
Strawberries
Products in sugar water
Apricots
Pears
Cherries
Gooseberries
Pineapples
Plumps
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Sampling plan / Statistical facts
Sampling plan and statistical facts   At first
sight the net content is very simple -
once more
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Sampling plan / Statistical facts
It should be marked what is inside, and it
should be inside on average what is marked.
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Sampling plan / Statistical facts
First the LEGAL REQUIREMENTS   1) the average
weight or volume must be equal to, or more than
nominal quantity.   2) only 2 of the produced
packages below the first tolerance limit TL1
3) not a single pre-package under the second
limit TL2   That means, no consumer should
get such an underweight pre-package.

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Sampling plan / Statistical facts
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Sampling plan / Statistical facts
So, the expectation of the consumer is to get the
promised quantity on average. In former times and
up to now there is always some doubt about this
medium principle.   At a pre-package conference
in 1979 in Canada, 25 countries voted for the
mean value. (only 3 countries were against it,
they wanted to see the minimum filling
principle) And that is also my opinion the
principle is well-tried.
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Sampling plan / Statistical facts
The mean value principle differs from statistical
safety, it is between 95 to 99.5   The
statistical certainty is in Canada 95 USA
Handbook 67 99 EEC and Germany 99.5   So, let
us see the requirements of the EEC and the
official testing plan of Germany.
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Sampling plan / Statistical facts
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Sampling plan / Statistical facts
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Sampling plan / Statistical facts
   
Overfilling                 net content
QN _________________________________________
_____________________

production time
h       TL1 _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ for whole
production
for sample sizes

n 50 c 3 k 0,379
max 2 are allowed
n 80 c 5 k 0,295


n
125 c 7 k 0,234 TL2
_________________________________________________
_______________    
 
nominal
not a single pre-package is allowed below the
TL2-limit
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Sampling plan / Statistical facts
Controlling procedure   First, it is important
that the plant manager realizes that we are an
official authority. So we have to identify us by
identity card.   Our law also says that we can
get help for work if we need. And in the most
cases we need help! Otherwise there is no chance
to take a correct sample size in huge
storehouses. Very often we will need a forklift
there. Thus it is very important to include the
help in your rules.
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Sampling plan / Statistical facts
On principle we never make appointments with the
plant manager. That means, if we are there, we
are there and we begin with the sampling.
Between three and seven samples for each
factory. Our ordinance also says that we have to
supervise the plants at least once a year.
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Sampling plan / Statistical facts
Controlling At first, let us have a look at the
total number of pre-packages - we call it
lot. The sample size depends on the lot
size.   Important is that it is a production with
a output of minimum one hour, or more. - The
more, the better - That means, if the lot
at store is less than 1 hour, it is not possible
to take a representative sample size.
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Sampling plan / Statistical facts
for lots smaller than 100 we do a 100 inspection
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Sampling plan / Statistical facts
To find a representative sample size, we have
internal instructions to give us help by finding.
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Sampling plan / Statistical facts
gather packages/ transport packages
You have to choose minimum n gather packages
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Sampling plan / Statistical facts
The regulated range amounts from 5 g or ml up to
10 kg or l. Only for this area you will find
minus deviations and the other regulations
regarding pre-packages. - This is mostly the
range for pre-packages of the daily use - The
minus deviation depends on the nominal net
content, they are changing from g/ml to
percentage this is to avoid jumps at the
borders.  
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Sampling plan / Statistical facts
You see, the greater the quantity the less the
percentage of the minus deviation.   This is
useful, because it is easier to fill big
quantities than to fill small packages with high
accuracy.
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Sampling plan / Statistical facts
minus deviation
tolerable minus deviation
QN
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Sampling plan / Statistical facts
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Sampling plan / Statistical facts
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Sampling plan / Statistical facts
Table 2 Tolerable deficiencies in actual content
for prepackages
R87
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Sampling plan / Statistical facts
Although we use a notebook for our supervision, I
will give you finally a very useful form to write
down any important information of the check.
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Unit price
Requirements for the unit price for
pre-packages This is very new for Germany in
force since September 2000. But in the EEC they
used it already years before and only German
industry was not willing to agree. Finally, the
legislator had to enforce it.
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Unit price
Here the definition in the Official Journal of
the European Communities from 18.03.98. DIRECT
IVE 98/6/EC Article 2 For the purpose of
this directive is
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Unit price
a) Selling price shall mean the final price for
a unit of the product , or a given quantity of
the product, including VAT and all other
taxes b) unit price shall mean the final
price, including VAT and all other taxes, for one
kilogram, one litre, one metre, one square
metre, or one cubic metre of the product or a
different single unit of quantity which is widely
and customarily used in the Member State
concerned in the marketing of specific products
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Unit price
c) products sold in bulk shall mean products
which are not pre- packed and are measured in
the presence of the consumer d) trader shall
mean any natural or legal person who sells or
offers for sale products which fall within his
commercial or professional activity
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Unit price
e) consumer shall mean any natural or legal
person who buys a product for purpose that do
not fall within the sphere of his commercial or
professional activity.
Once more The unit price declaration is only
(exclusive ) for the last step in trade, i.e.
when selling to the consumer.
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Unit price
back to the drained weight the unit price for
these products belongs to the drained weight
Example Cucumbers in a glass Unit Price is 2.68
/kg That is 0.51 for 190 g drained weight
But 51 Cent for total net of 330 g would show an
unit price of only 1.68 /kg
So, the consumer should compare only the drained
weight and not the total weight!
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Unit price
One example  e.g. cereals from Kelloggs
 Acting for your currency I calculate with
Euros   375 g Frosties cost 1.98 Euro 250 g
Frosties cost 1.28 Euro   Is there anybody
able to compare the prices? Which package is
cheaper, which one is more expensive?
Unit price 5.28 Euro/kg
Unit price 5.12 Euro/kg
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General unit price

• The great advantage is
• to improve the transparency of the
• market
• (standardisation) list 1 of the ordinance
• to improve consumer information - (clearly
• identification and quantity indication)
• the consumer has the right for indicated weight
  or
• volume, and the packer can avoid overfilling
• to come to a fair competition

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General unit price
None of us is aware of the power we (the
consumer) have. I started with the words It
should be marked, what is inside, and it should
be inside, what is marked.
Of course it is important for the plant to have a
good quality control. Why?? Let me ask a
question.
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General unit price
What is quality?????
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General unit price
Quality is, when the consumer comes back, and not
the product.
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Experiences
Experiences in Germany with the
supervision Finally, I will give you some
information about results and costs of our
inspections, about the experiences we made in
Germany.
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Experiences
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Experiences

• Right from the beginning we took a fee for each
  sample size.
• it is from 75,6 EUROS for a sample size of n50
• to 127 EUROS for a sample size of n125 pre-
  packages.
• A normal density test will cost 43,90 EUROS.
• Special tests are paid for working hours
• one hour will cost 64 EUROS for an engineer.

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Experiences

• It is okay, because the government has to pay for
  its officials
• and for the industry the supervision fee is only
  
• a per mil of the produced output.
• Also the law court agreed in many judgements,
  because in the beginning there was a great
  opposition against this fee.

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Thank you for listening!!