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The packer is the person who places goods into packages.  However, the packer may not necessarily be the person named on the package or the person whose brand or trademark appears on the label. A person who packs under contract for a chain of supermarkets is the packer and is thus responsible for compliance with the legislation.

What are the packer's duties?

The packer has four important duties:

  • To ensure that the packages will pass a reference test to determine if the packages comply with the first two of the three rules of the average system. The reference test is a special statistical test carried out by an inspector.The packer must also ensure compliance with the third rule by either:

1) making up each and every package on equipment prescribed by the regulations
2) testing samples of the packages using prescribed equipment and keeping a record of the tests for one year.

  • To ensure that the declaration of the nominal quantity on the label is in the prescribed units of measurement and that figures of the prescribed size are used.
Nominal quantity Minimum height of figures
200 g/ml or less 3mm
above 200 g/ml
but not more than 1000 g/ml
above 1000 g/ml 6mm
  • To show on the label the name and address of the packer or the person arranging for the packing to be done or, in the case of non-food products only, a mark which will enable an inspector to identify that person.
  • To provide an inspector with any assistance that he or she may reasonably require.

No. There is no requirement to pack to the average quantity system; it is permissible to pack to the minimum system provided each packaged contains at least the declared quantity.

However, packers who choose to pack on a minimum basis must follow the same rules as for the average system as regards the making up or checking of packages; in general, less checking is needed when more product is put into a package. This can be an advantage where the goods are relatively inexpensive.