The Uniform Packaging and Labelling Regulation applies to product packaging in most US states and requires importers and manufacturers to include certain information about the seller and the packaging contents. In this guide, we explain the basics of UPLR labeling requirements.
What is the Uniform Packaging and Labeling Regulation (UPLR)?
The Uniform Packaging and Labeling Regulation (UPLR) has been adopted into law in 45 of the 50 US states.
According to the National Institute of Standards and Technology (NIST) it has been adopted by all states excluding the following:
- North Dakota
- Rhode Island
See the “Summary of State Laws and Regulations in Weights and Measures” in this document to learn more.
The purpose of the UPLR is to provide adequate information on product labels so that consumers can make price and quantity comparisons. The information on the product must include:
- Product identity
- Net quantity of contents (i.e. weight, numerical count)
- Name and place of business of the manufacturer, packer, or distributor
You can learn more about the requirements of the UPLR on the NIST website.
Which products does the UPLR apply to?
The UPLR applies to consumer products packaging, such as packaging for the following product categories:
For many products, however, only a subset of the UPLR labeling requirements apply. The reason is that UPLR doesn’t cover labeling requirements that are already set by other regulations and agencies, such as the CPSIA (e.g. tracking labeling requirements) or the various FDA regulations. Hence, you don’t need to add duplicate labels to the product.
Take pillows and cushions as an example. The UPLR exempts these products to comply with the declaration of identity, declaration of responsibility, and several layout requirements (e.g. letters size) because such information is already covered by the US Law Label.
Also, the UPLR exempts the following type of packages:
a. Inner wrappings not intended to be sold individually
b. Shipping containers or wrapping used solely for the transportation of any commodities in bulk to non-consumers
c. Auxiliary containers or outer wrappings
UPLR Labeling Content Requirements
In this section, we introduce the UPLR labeling content requirements. As explained in this document, some requirements might be different for products that are sold in either:
- Consumer packages aimed at end consumers (B2C)
- Packaging for industrial use or wholesale distribution (B2B)
In this guide, we mainly focus on explaining the UPLR requirements for consumer packages. Additionally, we briefly outline the requirements for B2B packaging.
Declaration of Identity
The UPLR requires that a separate declaration of identity should be displayed on the main panel of the product packaging. The information must not be misleading or deceptive to consumers. The identity information means the name or other appropriate description for a product. For example, the label for a detergent should be indicated as “Detergent”.
For non-consumer packaging, the declaration of identity should appear on the outside of a package and also contain the product description, which is the product name and the function statement of the products such as “Cooking oil”.
Declaration of Responsibility
The UPLR requires that packages for consumer products should contain the following information:
- Manufacturer/Importer’s company name
- Address (street name, city, state, or country name)
- Zip Code
The UPLR also requires that – in case the product is not manufactured by the company whose name appears on the label – that the label should include wording such as “Manufactured for and packed by ________,” “Distributed by ________,” or other relevant wordings.
The declaration of identity and responsibility requirements for non-consumer packaging is the same as the consumer packaging.
Declaration of Quantity
The UPLR requires that products that are intended to be sold to end-users must include label information that indicates the product quantity expressed in the International System of Units (SI) and the US Customary Units.
Here, we provide examples of units required under the SI system.
|Commodity type||SI Units||US Customary Units||Product Examples|
|Solid, semisolid, or a mixture of solid and liquid||Kilogram, gram, milligram||Pound or ounce||Food|
|Liquid products||Liter, millilitere||Gallon||Beverage|
|Products that are labeled by linear measure||Meter, centimeter, or millimeter||Yard, foot, or inch||Bookshelves, desks, couches|
|Products that labeled by area measure||Square cm, or other measures such as square mm||Square yard, square foot, or square inch||Mattresses, fish tanks, table|
|Products that are labeled by numerical units (count)||The number should be between 1-1000, such as 2 pairs of xx, 3 pieces of xx, etc.||Same as SI units||Razors, blades|
The UPLR requires that non-consumer packages should bear a declaration of quantity expressed in either the International System of Units (SI) or the US Customary Units. The declaration should indicate the net quantity of contents in terms of the largest whole unit.
UPLR Label Prominence and Placement
In this section, we explain the UPLR requirements on labeling placement and format. Generally speaking, all information appearing should be written in English and should be outstanding, easy to read, and conspicuous as to size, style, and colors of letters.
The UPLR requires that the quantity declaration label on consumer packages should appear in the bottom 30% of the principal display panel or panels. For cylindrical containers, it should be 40%.
Display Panel Size
The calculation of principal display panel size is relatively straightforward. If a package is a 30 cm (height) x 15 cm (depth) rectangular solid, then the display panel size has an area of 30 cm x 15 cm = 450 square cm.
The size of the quantity declaration should occupy 30% of the display panel’s area which is 450 square cm x 0.3 = 135 square cm.
The calculation principle for quantity declaration area is the same for the cylindrical containers. If a cylindrical container has a height of 10 cm and a circumference of 20 cm, then the quantity declaration area should be 10 cm x 20 cm x 0.4 = 80 square cm.
Type of Lettering
The label letters should be conspicuous and correspond to the holistic styles, graphic material, or other elements displayed on the label.
The information displayed on the labeling should be in a color that contrasts with its background, except in cases when the product quantity information is blown, formed, or molded on a glass or plastic surface.
The UPLR provides a list of exempt products which cover food, cosmetics, medical devices or other types of products. Note that UPLR often does not fully exempt these products from complying with its labeling requirements.
Instead, it only partially exempts those products from complying with certain proportions of the regulations, such as location, net quantity of contents identity, or responsibility. This is because those products are either already covered by other regulations, such as FDA and EPA, or certain labeling requirements of the UPLR are not compatible with these products.
Below, we provide some examples.
Pillows, Mattress Pads, Sleeping Bags, and similar products
The UPLR exempts pillows, mattress pads, sleeping bags, or cushions that must comply with the labeling requirements of the US Law Label or the Department of Consumer Affairs, Bureau of Household Goods and Services (BHGS), from complying with the following labeling requirements specified in the UPLR:
- Label location on the product
- Size of letters or numbers
- Free area
- Declarations of identity and responsibility
Containers of cosmetic products are partially exempted by the UPLR because such products are covered by FDA’s cosmetic labeling requirements. Examples of cosmetics include:
- Facial products
- Hair care products
- Manicure and pedicure
- Oral hygiene products
You can find the label requirements for cosmetics in the FDA’s website.
Certain Food Products
The UPLR partially exempted certain food products from complying with its labeling requirements. For example, the following products are exempted from certain sections of the UPLR:
- Meat and meat products
- Poultry products
- Distilled spirits
The following are labeling sections that do not apply to the above product list:
- Label location on the product
- Minimum type size of the net quantity declaration
- Net quantity of contents identity