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nakedbakery

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Posted 12 May 2022 - 08:56 AM

Hiya

 

Were in the early process of getting SQF certification. Just started first production for products going into supermarkets and have a fair few rejects for being 5g underweight and 5g overweight (product weight is 65g E). The packaging has an e-mark - i was wondering if anyone has information on whether this is a non-conformance? Or should it still be dispatched as packaging states it is an e-mark? 

Our consultant is saying we need to set up a process to be able to use the e-mark?



SQFconsultant

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Posted 12 May 2022 - 11:50 AM

This is for the EU yes.

8% diviation (5g of 65) is a bit high and while in allowable range for the e-mark I'd be looking for an alternate solution.

Most consumers know what the emark stands for - so you risk potential loss of product sales if yoü use it... people do not like being shortchanged.


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Posted 12 May 2022 - 11:53 AM

See below---the allowable variance for your pack size is a MAX of 4.5 g

 

Better product control is also better for your companies bottom line-----you need to determine where the issue in the process is so that it can be corrected

https://eur-lex.euro...0190726#tocId14

 

https://europa.eu/yo...rk/index_en.htm

What are the requirements?

To ensure that the quantity displayed is correct, ℮-marked packages must fulfil the following requirements:

  • the average quantity of product in packages coming from the same batch must be equal to or greater than the quantity mentioned on the package.
  • the nominal quantity refers only to the product. It does not include packaging or any materials used to protect the product, handle it (example: the stick of a lollipop), preserve it (example: ice) or serve as an aid while using it (example: serving tray).
  • only a limited proportion of the prepackaged products from the same batch may have a smaller amount of product than indicated on the package. This is referred to as "tolerable negative error" and it is set in the annex 1 of the EU legislationico-external-link.png.

he tolerable negative error in the contents of a prepackage is fixed in accordance with the table below:

 

 

Nominal quantity Qn in grams or millilitres

Tolerable negative error

as % of Qn

g or ml

5 to 50

9

from 50 to 100

4.5

from 100 to 200

4.5

from 200 to 300

9

from 300 to 500

3

from 500 to 1 000

15

from 1 000 to 10 000

1.5


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Charles.C

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Posted 12 May 2022 - 03:33 PM

Hiya

 

Were in the early process of getting SQF certification. Just started first production for products going into supermarkets and have a fair few rejects for being 5g underweight and 5g overweight (product weight is 65g E). The packaging has an e-mark - i was wondering if anyone has information on whether this is a non-conformance? Or should it still be dispatched as packaging states it is an e-mark? 

Our consultant is saying we need to set up a process to be able to use the e-mark?

 

I doubt that there will be a (food) rejection for overweight.(!?) ([lack of]Profitability maybe Yes)

 

The detailed interpretation can depend on the specific type/presentation of product. What is it ?

 

IIRC Australia does not (internally) usually/legally implement the European system ??


Kind Regards,

 

Charles.C


pHruit

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Posted 12 May 2022 - 05:43 PM

I doubt that there will be a (food) rejection for overweight.(!?) ([lack of]Profitability maybe Yes)

 

Never had the misfortune of dealing with some of the retailers / brands in the UK, Charles? ;)

I while ago I dealt with a startup, and in getting used to their somewhat basic line they erred towards over- rather than under-filling, which seems sensible to normal humans, but alas it resulted in complaints and rejections for overfilled packs...

 

See below---the allowable variance for your pack size is a MAX of 4.5 g

 

(Text snipped for brevity)
 

 

If the OP is importing product to Europe then it's worth noting that the weights and measures at the EU level is a Directive, and is therefore implemented in local regulation in each member state. This means that regulations in specific countries can vary slightly.

Nonetheless the maximum allowable variance is actually twice the tolerable negative error (TNE), i.e. in the case of the OP's product the absolute minimum weight for a pack would be 65 - (4.5*2) = 56g. There are of course statistical constraints on the number of packs that fall into the TNE / 2TNE below the declared weight region, although no such constraint on being above this - the regulatory framework doesn't have any problem with food businesses giving away free product above the declared quantity.

 

Obviously this is a very UK-centric take (derived from the EU directive, before the "B word" happened) but if you are dealing with exports into this market then this guidance gives a reasonable overview: https://assets.publi...ons-2006-tp.pdf



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nakedbakery

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Posted 13 May 2022 - 04:51 AM

Hi guys. Thanks so much for your answers it helps a lot! We are processing in Australia - currently no importing to the EU but perhaps later on when we install our automated line. At the moment 2/3 of our process is quite hands on so that is where i see the discrepancies. 

100% overweight is bad for the bottom line - luckily we haven't had many overweight. But we have been getting a lot of underweight rejects that i am trying to fix. 

 

The average weight is about 62g



Charles.C

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Posted 13 May 2022 - 06:10 AM

Never had the misfortune of dealing with some of the retailers / brands in the UK, Charles? ;)

I while ago I dealt with a startup, and in getting used to their somewhat basic line they erred towards over- rather than under-filling, which seems sensible to normal humans, but alas it resulted in complaints and rejections for overfilled packs...

 

 

If the OP is importing product to Europe then it's worth noting that the weights and measures at the EU level is a Directive, and is therefore implemented in local regulation in each member state. This means that regulations in specific countries can vary slightly.

Nonetheless the maximum allowable variance is actually twice the tolerable negative error (TNE), i.e. in the case of the OP's product the absolute minimum weight for a pack would be 65 - (4.5*2) = 56g. There are of course statistical constraints on the number of packs that fall into the TNE / 2TNE below the declared weight region, although no such constraint on being above this - the regulatory framework doesn't have any problem with food businesses giving away free product above the declared quantity.

 

Obviously this is a very UK-centric take (derived from the EU directive, before the "B word" happened) but if you are dealing with exports into this market then this guidance gives a reasonable overview: https://assets.publi...ons-2006-tp.pdf

Hi pHruit,

 

As it happens, yes. Exported retail packs to various EC destinations including some to UK (when they could pay).

Always packed overweight to eliminate any problems with t1,t2 and items like zones of indecision.

Cannot recall any murmurs backwards about weight. (Obviously visibly bulging packs would be asking for trouble).

I always reckoned for a receiver it's like a never-ending Xmas.

 

The e-directive is mathematically related to applying a t-test hypothesis on the average weight and actually has some surprising flexibility if one is so inclined. ;)

 

@nakedbakery - a routine 5% shortweight on the average is simply guaranteed to get a complaint IMEX.


Kind Regards,

 

Charles.C




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