Review of the National Trade Measurement Regulations 2009, Part 4: Packaging

Use of simpler language - plain English. Keeping all exemptions, variances etc. in one place rather than in:

- The 'Secretary's list for items approved for sale by number or linear measurement';
- Various different Regulations;
- Schedule 4;
- Schedule 5;
- Schedule 6.

Clarification of terms partly-solid and partly-liquid and semi-solid.

Regulation 4.18 should say or similar products packed in sheets.

Remove Regulation 4.20 and 4.21 - sizes of bedsheets and tarpaulins etc. are descriptive markings - such items are not priced by quantity/area and so should not be included in trade measurement legislation.

Subdivision 3 could be made much simpler - it is not easy for businesses to follow.

4.26 - this would be simpler if it applied to all products packed to random weight. It could be replaced by a regulation saying that any product packed in random quantities should include unit price and total price. In practice, this will mainly be for such products as currently listed. It would mean a number of definitions could be removed.

Why should cake and haberdashery items be singled out in Regulation 4.12(5) ? Remove these items.

Enable anyone to mark measurement by hand that marks products to be sold at premises owned by the packer - to enable e.g. market holders, and similar, who may mark the packs at home/at a warehouse before bringing the product to the market stall to be able to hand-write the measurement marking.

There is no harm in permitting people to mark 'Minimum measurement' on any product - particularly as there is no specification as to what is meant by a measurement marking. Many packers must take account possible reduction in quantity during the shelf-life of the packaged article in determining what value to apply to a measurement marking. Similarly, the use of the word 'net' should be permitted, not excluded as a qualifying term: the measurement marking has to be made by reference to the net measurement; the inclusion of the word net, is not confusing for purchasers; this will prevent issues where packs are packed overseas where the word 'net' may be required.

Clarify and simplify egg marking - the consumer wants to know the weight of the pack and the number of eggs. The home-baking population might like to know the size of the eggs in a pack - a cake can be ruined if eggs used are too small or too large!! - but I imagine there would be too much opposition to making the minimum size of each egg a requirement.

4.27 - mass when packed - why the specific rules for soap and mushrooms? Many other (particularly fresh produce) products lose weight after packing and have to be packed to make allowance for any possible weight loss - there should be no special provisions and the use of the words 'mass/weight when packed' should not be permitted in ANY case (this will have a knock-on effect on Regulations 4.31 and 4.32 which could then be removed - if this provision IS retained then better definitions for bar soap, medicinal soap etc. should be included).

The regulations must make clear that the quantity marked must make allowance for any loss of quantity during the expected shelf-life of the product (loss of weight or volume).

It is easier for business to follow prescriptive, black and white regulations, rather than principles-based regulations that are open to interpretation.

Making marking requirements (particularly regarding name and address marking) tie in with requirements for other legislative requirements - particularly food labelling requirements would make sense, so there is one simple rule for packers to follow.