Uniform Packaging and Labeling Regulation (UPLR): A Complete Guide

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Packaging Labeling

The Uniform Packaging and Labelling Regulation applies to product packaging in most US states. It requires importers and manufacturers to include specific information about the product, seller, and packaging contents. In this guide, we explain the basics of UPLR labeling requirements.


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What is the Uniform Packaging and Labeling Regulation (UPLR)?

The purpose of the Uniform Packaging and Labeling Regulation (UPLR) is to provide adequate information on product labels so that consumers and businesses can make price and quantity comparisons. The information on the product must include:

  • Product identity
  • Name and place of business of the manufacturer, packer, or distributor
  • Net quantity of contents (i.e. weight, numerical count)

According to the National Institute of Standards and Technology (NIST), the UPLR has been adopted into law in 45 of the 50 US states.

You can learn more about the requirements of the UPLR on the NIST website.

Which products does the UPLR apply to?

The ULPR applies to consumer packages of consumer commodities that are distributed through retail sales for individual use or consumption in the household. This includes products such as the following:

The regulation also applies to non-consumer packages of non-consumer commodities, including packages intended for industrial or institutional use, or for wholesale distribution.

Exemptions

Section 11 of the UPLR covers exemptions for several products. These exemptions might only concern some requirements and do not constitute a total exemption from the UPLR. We list some products and these exemptions below.

Pillows, Mattress Pads, Sleeping Bags, and similar products

Pillows, mattress pads, sleeping bags, and similar products that carry a permanent label as required by either the International Association of Bedding and Furniture Law Officials (IABFLO) or the California Bureau of Household Goods and Services (BHGS) are exempt from requirements such as the following:

  • Location
  • Size of letters or numbers
  • Free area
  • Declarations of identity and responsibility

These exemptions apply, provided that the statements of identity and responsibility appear on a permanent label, are clearly readable by the consumer, and conform to the other requirements of the UPLR.

Textile Packages

Textile packages needing to carry a declaration that states the quantity and the count of each individual unit are exempt from the following UPLR requirements:

  • Location
  • Free area
  • Minimum height of numbers and letters

Combination and Variety Packages

Combination and variety packages are exempt from the same requirements as those for textile packages. Note that Combination packages are retail packages containing two or more individual packages or units of different products. For example, a package of 3 sponges and 2 box cleaners.

Variety packages are retail packages containing two or more individual packages or units of similar, but not identical, products. For example, 5 sponges of different sizes.

Food Products

The UPLR exempts several food products from some of its requirements (e.g. location of the net quantity declaration). This includes the following products:

  • Eggs
  • Margarine
  • Corn meal
  • Bacon
  • Fluid dairy products (e.g., ice cream)
  • Butter
  • Small confections (e.g., “penny candy”)
  • Small packages of meat or meat products

Labeling Content Requirements

The UPLR requires packages to bear labels with accurate information regarding their identity and quantity of contents so that consumers and businesses may compare the price and quantity of such packages.

Declaration of Identity

The declaration of identity on a package’s label informs purchasers of the package’s contents.

Consumer products

A statement of identity on consumer products should conform to requirements such as the following:

a. It should specify the common or generic name of the product, including its function (e.g., “face towel”)

b. It should appear on the principal display panel of the package

c. It should not be deceptive or misleading

Non-consumer products

The requirements regarding the declaration of identity for non-consumer products are similar to those for consumer products.

The main difference lies in the location of the declaration. While the declaration of identity on consumer products must appear on the package’s principal display panel, the declaration of identity on non-consumer products must appear on the outside of the package.

Declaration of Responsibility

The requirements for the declaration of responsibility apply to packages of both consumer and non-consumer products. The declaration should include the name and address of the manufacturer, packer, and distributor.

The name should be that of the business selling the product, and the address should include the following information:

  • Street address (omit if publicly available)
  • City
  • State (or country, if outside the US)
  • ZIP code (or mailing code, if used outside the US)

The label may state the principal place of business if the commodity in question was manufactured, packed, or distributed in a location other than the principal place of business.

If the commodity is not produced by the company whose name is on the label, then the name should be qualified by a connecting phrase such as the following:

  • “Manufactured for and packed by __________”
  • “Distributed by __________”

Declaration of Quantity

The declaration of quantity on labels of consumer and non-consumer products should be stated in SI metric units, US customary units, or both where appropriate.

Consumer products

In general, consumer products and packages should bear the declaration of quantity in both SI metric units and US customary units.

However, the following products and packages are exempt from the SI metric unit requirements:

a. Packaged foods for retail sale

b. Random weight packages

c. Package labels printed before Feb 14, 1994

d. Beverages covered by the Federal Alcohol Administration Act

e. Products covered by the Federal Insecticide, Fungicide, and Rodenticide Act

f. Drugs and cosmetics covered by the Federal Food, Drug and Cosmetic Act

g. Meat and poultry products covered by the Federal Meat or Poultry Products Inspection Acts

h. Tobacco or tobacco products

Non-consumer products

Non-consumer products and packages might bear the declaration in SI units only unless federal laws require otherwise. The table below shows some examples.

In units of… In terms of…
Mass
  • Kilogram
  • Gram
  • Milligram
Liquid measure
  • Liter
  • Milliliter
Linear measure
  • Meter
  • Centimeter
  • Millimeter
Area measure
  • Square meter
  • Square decimeter
  • Square centimeter
  • Square millimeter

The SI units in the declaration of quantity must be properly expressed, in ways such as the following:

  • 200 g (instead of 0.2 kg)
  • 3.54 kg (instead of 3540 g)
  • 630 mL (instead of 0.63 L)
  • 820 mm or 82 cm (instead of 0.82 m)

Additionally, the declaration of quantity should not be expressed in mixed units, such as the following:

  • 5.3 kg (instead of 5 kg 300 g)

Prominence and Placement

In this section, we explain the UPLR requirements concerning the labeling placement and format. Generally speaking, all information appearing should be written in English and should be easy to read, and be conspicuous as to the size, style, and colors of letters.

Label Placement

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 the size of the principal display panel 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 styles, graphic material, or other elements displayed on the label.

Color Contrast

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.

Other Requirements

Section 8 of the UPLR has a few other requirements, such as the following:

a. The area above, below, and next to the quantity declaration should be free of printed information

b. The quantity declaration should be parallel to the declaration of identity and the base of the package

c. The minimum height of letters and numbers in the quantity declaration should not exceed given values; for instance, if the area of the principal display panel is more than 32 square centimeters, then the minimum height of the letters and numbers should be 1.6 mm, while if the panel’s area is less than 32 square centimeters, then the minimum height of the letters and numbers should be 3.2 mm.

Specific Requirements

Section 10 of the UPLR lists specific requirements regarding different types of products in various categories such as the following:

  • Multiunit packages
  • Combination packages
  • Variety packages
  • Wearing apparel
  • Threads and yarns

We provide a non-exhaustive list of some of those requirements below.

Multiunit Packages

Multiunit packages containing more than one individual packaged product of the same commodity should bear, on the outside of the package, a declaration of the following:

  • The number of individual packages
  • The quantity of units for each individual package; and
  • The total quantity of units of the multiunit package

For instance, 2 packages of 3 identical soap bars each (total: 6 soap bars).

Combination Packages

Combination packages containing two or more individual packages or units of different products should bear a declaration of quantity in terms of the following:

  • Weight
  • Volume
  • Measure
  • Count
  • Combination thereof (as appropriate)

Below we provide two examples.

Lighter fluid and flints

  • 4 cans lighter fluid, 300 mL (10.5 fl oz) each
  • 2 flint packages, 8 flints each

Sponges and cleaners

  • 4 sponges, each 8 cm x 10 cm x 2 cm (3 in x 4 in x 0.8 in)
  • 2 box cleaners, Net Mass 200 g (7 oz)

Variety Packages

Variety packages containing two or more individual packages or units of similar but not identical products should bear a net quantity declaration of the following:

a. Number of units of each identical commodity (followed by weight, volume, or measure)

b. Total quantity by weight, volume, measure, and count, as appropriate

Below we provide two examples.

Sponges

  • 5 sponges – 10 cm x 15 cm x 2 cm (3.9 in x 5.9 in x 0.78 in)
  • 3 sponges – 5 cm x 8 cm x 1.5 cm (2 in x 3.15 in x 0.6 in)
  • Total: 8 sponges

Soap

  • 3 soap bars – 75 g (2.6 oz) each
  • 2 soap bars 100 g (3.53 oz) each
  • Total: 5 soap bars – 425 g (14.86 oz)

Wearing Apparel

Wearing apparel sold as single-unit items, or normally sold as pairs (e.g., gloves) are exempt from the requirements for net quantity statement by count.

Sewing Threads, Handicraft Threads, and Yarns

Threads and yarns have specific requirements, such as the ones listed below.

Sewing and Handicraft Threads

Sewing and handicraft threads should bear the net quantity in terms of meters and yards.

Each unit of industrial thread should bear a mark identifying either of the following:

  • Net length, in terms of meters or yards
  • Net weight, in terms of kilograms or grams, and avoirdupois pounds or ounces

Thread products should provide an identification of the manufacturer, packer, or distributor by bearing marks such as the following (instead of the company name and address):

  • Trademark
  • Symbol
  • Brand

Yarns

Yarns should bear the net quantity statement in terms of mass or weight.

  • (USA & EU)

    We Help Brands & Importers With Product Compliance (US & EU)

    • Product Requirements Lists
    • Product Certification
    • Product & Packaging Labeling
    • Lab Testing

    BOOK A FREE CONSULTATION


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