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Should the amount of product in a package have to be displayed on the front of the package?

Currently, for most packaged products, the quantity in the package must be displayed on the front.

But, if some of the options in a consultation Regulatory Impact Statement (RIS) issued recently by the federal government were adopted, it would NOT be mandatory to display the quantity information on the front of any packaged products . (However, the quantity information would still have to displayed somewhere on the package and it would still have to be prominent and legible.)

I think that that the quantity information needs to be on the front of ALL packages for many reasons including to:

  • Ensure that it is easy for all consumers to locate.

  • Ensure that the location is consistent across all packages.

  • Facilitate consumer use of the information to make a variety of decisions at the time of purchase, including easily informed choices about the quantity needed and to compare the price per unit of quantity (the unit price). (Note: For constant quantity packages the unit price only has to be provided by very large grocery retailers.)

  • Facilitate consumer use of the quantity information after purchase.

  • Help consumers notice package “shrinkflation” (reduced quantity but unchanged or increased selling price).

  • Help consumers notice when packages contain large amounts of empty space (slack fill).

  • Meet the needs of the many consumers with disabilities, including impaired vision, mobility, and cognition.

Comments/views on the above are welcome. Also, on a consultation question that asks whether, and if so why, there are any particular types of packaged products where retaining front of pack quantity information is important.

The 213 page consultation RIS, which covers much more than this issue, is available here

https://consult.industry.gov.au/measurement-law-review/mlr-consultation-regulation-impact-statement/

The closing date for responses is Friday 14 May.

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I think that the most important factor is on the supermarket/retailer shelf, the front of the packaging faces forward to catch the eye/attention of the consumer. This means that if the weight is on another side other than the front, the consumer has to pick up each individual package to compare weights between products if weight is a deciding factor in the purchase decision.

If the packaging/manufacturing industry succeeds in having net weights placed elsewhere on the packaging, maybe supermarkets should be mandated to include packaging weights clearly and in large font on their shelf labels (this has a disadvantage if a product is wrongly position by the retailer or a consumer as the weight label would be wrong for the shelved product). I am sure that the supermarkets would resist this and may therefore support the status quo.

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Thanks for the input. The RIS assumes that the extra time spent finding the quantity information is the only cost to consumers. I disagree and argue that moving the information off the front of the pack will significantly reduce the number of consumers who look at and use the information. This will result in additional costs for consumers arising from less informed choices, etc.

I have thought about saying this in the past but have not, mainly because it might prejudice achieving having the info provided on the front of packages. Also, it would have to apply to all retailers not just supermarkets. However, I agree that retailers are likely to strongly resist such a requirement and this could strengthen the case for the info to be on the front of the pack.

BTW on this aspect of the topic, all the options in the RIS would require internet selling sites to provide quantity info. I think this is a welcome and long overdue change.

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Yes. Front. Yes. Consistent e.g. front, bottom, right.

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I agree it should remain at the front.

Perhaps we could look at it the other way, and say that if the manufacturers have nothing to hide it should be proudly displayed on the front. Surely the only possible reason manufacturers would want to remove the quantum from the front is to gain some advantage. This correlates very closely to disadvantage to consumers.

In these days of COVID you do NOT want everyone handling items unecessarily to be able to see the backs or sides of labels. How would they ever contact trace sources if people caught COVID from touching food items that they didn’t even buy and take home?

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Good point that I had not thought of. Will add it to the list in my original post…

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That’s definitely right. The lifetime of COVID on a surface is such that the donor of the virus may not have been in the store at even close to the same time as the recipient of the virus.

All assuming that people check in at the supermarket. I’ve never seen someone check in at the supermarket. I’ve never checked in at the supermarket.

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Pretty interesting when the only thing most people are short of is…TIME! IMHO having to pick up every item I buy to search for the weight (ok sure, some packaging will be familiar) is just an annoying farnarkle.

@ijarratt is it mandatory now? Why do they want to change it? IIRC a RIS needs to state why.

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weight and unit pricing.

If a company shrinks product (and still sells original sizing) making it look the same I am more than likely not going to be purchasing their products if it can be helped.

1kg vs 750g cheese blocks seems a consistent culprit! I buy a locally source block now that only comes in 750g and it priced to be competitive on unit price (Coon/Bega regularly price both 1kg and 750 at same price and they’re right next to each other too). Used to notice it a lot with boxed cereal but I don’t really buy that stuff any more.

Pandemic aside, companies will be spending money to make this change and I’ve yet to encounter any that do anything packaging related out of the good of their hearts to benefit consumers.

What benefit do consumers get by not having product weight’s/qty on front of products?
What benefit is there to companies that doesn’t lead to exploiting consumers? (again changing labelling is going to cost them $$, companies don’t usually spend without expecting a return or savings somewhere)

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It seems with many cereals the box front is the same size, but the boxes have become thinner…with reducing weights. Possibly marketing psychology in play where one thinks they are getting the same amount, when the box is actually less.

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I think the packaging should be similar size to the contents not a box of air plus the product

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RE Not a box of air plus the product

This is known as “slack fill” and I included it in the list of reasons why the quantity info should be on the front of the pack. But as far as i know, it is not referred to specifically in the measurement law or the Australian Consumer Law. So to force a packer to change it would be necessary to prove that it was “misleading or deceptive conduct” and that is not easy, especially of the quantity information is provided on the front of the pack and is easy to notice and read.

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To provide greater flexibility to industry and reduce the need for some imported products to be relabelled or repackaged.

Re imported products I argue that the producer should ensure that the quantity info is on the front of the pack before exporting the product.

Also, since many other countries, including the USA also have this requirement, putting the info on the front should be normal practice for an efficient exporter, especially since I know of no country that does not accept the quantity info being provided on the front of the pack.

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Haven’t they heard of stickers, which is used often for nutritional panels to meet Australian labelling requirements (often stuck over other nutritional information prescribed elsewhere). A small weight label to cover say an imperical weight is cheap compared to ‘relabelling or repackaging’. The precedence has been established.

This reason sounds like fishing to justify the change.

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Understood, thanks.

So much effort goes into constantly making things easier for ‘industry’ while the consumer has to fight battles on all fronts to stop from being exploited and just get value for money…product safety, warranties, collusion, dodgy packaging…

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Stickers are included in the term “relabelling”. Some industries e.g. cosmetics may also not want to put the quantity info (and even worse a sticker showing it) on the front for aesthetic reasons…

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Cosmetics are sold on the packaging and marketing. Possibly the most expensive part of the product. The industry has made an art form turning $10 of stinking water into a $200 retail product. If ever there was a product line that needs to reliably and clearly declare the true volume or weight of contents on the packaging.

Apologies to all those who appreciate the scent of a million roses. By my olfactory senses success is the aroma of slow cooking roast lamb. :heart_eyes::yum::yum:

Edit - P.S.
No need for anyone to diverge into explaining why or how we are socially conditioned into worshipping some scents over others. I’ll just note products marketed mostly to male purchasers are often attributed to other than flowers. Animal organs and rotting timber’s of sailing ships might be two thoughts. It’s highly unlikely the associated products contents include either. Contents nil quantity?

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The tobacco industry was not exactly in favour of generic packaging with photos of cancer sufferers, but when there is enough will…

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I totally agree. But consumers need to let the federal govt know that there is enough will on this issue.

Anyone interested doing so can support requiring that the quantity information be provided on the front of all packaged products by participating in the online consultation that closes on Friday 14 May.

The easiest way to do that is to go to this page and make a short written submission (not respond to the survey questions)
https://consult.industry.gov.au/measurement-law-review/mlr-consultation-regulation-impact-statement/consultation/subpage.2021-03-30.1326246018/

The conversation here indicates to me that the main justifications for consumers asking that the quantity information be on the front of ALL packages are to:
• Ensure that it is easy for all consumers to locate and that the location is consistent across all packages.
• Meet the needs of the many consumers with disabilities, including impaired vision, mobility, and cognition.
• Reduce the amount of the time consumers need to spend locating the quantity information.
• Facilitate consumer use of the quantity information to make a variety of decisions at the time of purchase, including easily informed choices about the quantity needed and to compare the price per unit of quantity - the unit price. (Note: Only very large grocery retailers have to provide the unit price for products in constant measure packages… Elsewhere e.g. in many small supermarkets and in chemists, hardware stores, etc. you have to calculate it yourself using the price and the quantity info and to facilitatethis the quantity information needs to be easy to locate.)
• Facilitate consumer use of the quantity information after purchase e.g. when using the product.
• Help consumers notice package “shrinkflation” (reduced quantity but unchanged or increased selling price).
• Help consumers focus on the quantity in the pack, not its dimensions and awareness that some packages may contain large amounts of empty space (slack fill).
• Reduce disease transfer by reducing the amount of unnecessary handling of packaged products in shops.

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Submission written and submitted :slight_smile:

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