19 replies to this topic

[Ron Gardner]

I have an inspector who is requiring me to calculate my packaged product from ounces to grams @ 1:28 ratio. saying that a 4 oz package is 112 grams. can anyone help me with evidence that this is insane?

[Brothbro]

From an FDA source, but it's true that for labeling purposes 1oz = 28g even though this is not the scientific measurement. Maybe others have some insight into USDA-specific rules.

 

(5) For labeling purposes, the term common household measure or common household unit means cup, tablespoon, teaspoon, piece, slice, fraction (e.g., 1⁄4 pizza), ounce (oz), fluid ounce (fl oz), or other common household equipment used to package food products (e.g., jar, tray). In expressing serving size in household measures, except as specified in paragraphs (b)(5)(iv), (b)(5)(v), (b)(5)(vi), and (b)(5)(vii) of this section, the following rules shall be used:

 

(viii) For nutrition labeling purposes, a teaspoon means 5 milliliters (mL), a tablespoon means 15 mL, a cup means 240 mL, 1 fl oz means 30 mL, and 1 oz in weight means 28 g.

 

https://www.ecfr.gov...1.9(b)(5)(viii)

[Scampi]

4 ounces IS ~28 grams             why is that insane?

 

How much does 1 oz weigh in grams?

 

 

approximately 28.3495 grams

 

There are 28 grams in an ounce. This unit conversion can be expressed as 28 grams = 1 ounce or 28 g = 1 oz. However you write it, there are 28 grams in one avoirdupois ounce. In a more precise conversion, 1 ounce is equal to approximately 28.3495 grams (or 28.35 g).

[G M]

I have an inspector who is requiring me to calculate my packaged product from ounces to grams @ 1:28 ratio. saying that a 4 oz package is 112 grams. can anyone help me with evidence that this is insane?

 

 

Considering that the relevant tables in the NIST handbook list both English standard and metric values this just seems like an odd/lazy request.  What does the inspector want these converted values for?  

[SerenityNow!]

Not sure if you referencing the Net Wt. or the Serving size.  If you are in the US, the Net Wt needs to show metric weight as well.  I have attached the FDA's Food Labeling Guide.  Page 14, question 3 is where you will find info about this topic.

 

 

[Ron Gardner]

so, I guess my issue is this.

I see 1 oz is 28 grams after rounding. no problem I get that.

But to round 28 prior to multiplying is just not making any sense.

 

if you have 80 ounces it would be 2240g instead of (actual math) 2268g. If you are saying that your product is 1oz (28g) per serving. then according to grams, you have 81 servings, yet according to oz. you would have 80 servings.

 

Why don't we just use simple math?

Does the general public understand the difference between real math and government math?

 

Or am I just missing something?

[Scampi]

you're missing rounding the grams DOWN to 28 so your # of servings in a package remains the same

 

There are rounding rules for measurements in all countries.... In Canada we also have to follow the weights and measures regulations which tell you when to round up or down and that varies depending on the starting size/weight etc

 

so yes, if you do the math WITHOUT rounding, you'd get ~2600 g but you MUST round down as it's less than 28.5 g/ounce in actual math

[Scampi]

For your reference

 

https://labelcalc.co...our-food-label/

 

https://www.accessda...nutrition label

 

https://www.fda.gov/...Guide-(PDF).pdf

[Ron Gardner]

you're missing rounding the grams DOWN to 28 so your # of servings in a package remains the same

 

There are rounding rules for measurements in all countries.... In Canada we also have to follow the weights and measures regulations which tell you when to round up or down and that varies depending on the starting size/weight etc

 

so yes, if you do the math WITHOUT rounding, you'd get ~2600 g but you MUST round down as it's less than 28.5 g/ounce in actual math

 

 

 

 

sorry but that doesn't make any sense to me how is 80 oz 2600 grams?   80*28.350 = 2268 or if you do the math by rounding the grams first it is 80*28=2240.

either way, If I was on a 112g diet of meat per day. and I do this for 365 days, but eat a 4oz steak for everyday for a year would I have eaten 40,228 grams of meat or 39,872 grams of meat?

[Scampi]

Sorry---  I meant 2240g  

 

28*80 = 2240

[G M]

What did the USDA inspector want the metric measurements for? Is it total primary package net wt, serving size, etc.?

 

 

The initial post would indicate that the total net weight for the package: 4oz = 113g  No rounding would be involved until you get to the last step and drop the decimal from 113.398.  

 

In their own example, an 8oz net weight is 226g (8*28.3495), not 224 (8*28).

https://www.fsis.usd..._Net_Weight.pdf

 

 

I'm still confused because the metric units aren't required for labeling, and this would be small enough that you don't need a second unit listed either.  Part III.B of this notice is calling out the optional nature of metric units for net wt., unless this is some oddball class of product following different special rules:

https://www.fsis.usd...is-notice/61-22

 

Some detail around the request itself and what triggered it seems to be missing.

Edited by G M, 05 October 2023 - 04:43 PM.

[SerenityNow!]

What is the product?  All FDA regulated products require metric units along with customary units.  Meats and poultry, which are regulated by the USDA are not required to include metric.

 

Also, rounding should be done at the end of calculation, not all the way throughout.  Calculate at true gram weight, then round your net grams.

 

My opinion is that the inspector is incorrect by stating calculations are to be done at 1:28 ratio. Granted, In a 4 oz package, its not off by much which is probably why it's being suggested this way. When you get to larger packages it starts to throw off your serving declarations. I would say it's a case of learning a method that is "close enough" and believing its the correct process.

 

I'd stick to the proper practice throughout my labeling processes.  Creating actual calculations then rounding.  Imagine someone rounding down your money because it's "close enough"

Edited by SerenityNow!, 05 October 2023 - 05:26 PM.

[Scampi]

2. Determine the serving size for your multi-serving product using the RACC for the product (21 CFR 101.9(b)(2),(3), and (4)). The serving size is expressed as a common household measure followed by the equivalent metric quantity in parenthesis (e.g., “1/2 cup (112 g)”). Acceptable household measures are listed in order of appropriate use in 21 CFR 101.9(b)(5). Rounding rules for metric quantities and a few additional format options are included in 21 CFR 101.9(b)(7). 3. Use the information in 21 CFR 101.9(b)(8) to determine the number of servings and the appropriate rounding rules for numbers of servings

 

https://www.fda.gov/...Guide-(PDF).pdf

[beautiophile]

It's surprising me a lot that the industries almost have no idea about significant figures.

[DeadPresident]

It's surprising me a lot that the industries almost have no idea about significant figures.

First time even hearing the phrase.

[PrplomSolved]

It's surprising me a lot that the industries almost have no idea about significant figures.

Out here in Georgia we call those our good ol' Sig Figs

[Ron Gardner]

So... I have searched the internet and found so many variants on this issue.  

Let's say you have a bag of random meat. 

Net weight says 4oz. (113g) 1oz/28.35g x 4 = 113.4 (rounded to 113)

But the serving size has to say 4 oz. (112g) 1oz/28g x 4 =112 

Some companies use 113g on both the serving size and net weight. some use 112g. 

I can't find an answer as to why it would be 112, other than because we say so.

math is easy and the nutritional facts panel is hard enough for consumers to understand, why do we have to confuse the general public even further?

 

by using the rounding rule prior to multiplying, at some point you are out of regulation with the RACC and weights and measures.

 

Anyone has an answer as to why we use two different conversions on the same product?

[G M]

...

But the serving size has to say 4 oz. (112g) 1oz/28g x 4 =112 

...

 

 

 

Where is this part coming from?  

 

You are choosing what a "serving" is for your label.  If you want it to be mathematically accurate "4oz (113g)" then go ahead. 

 

Plenty of companies out there make the realistic assumption that people just eat the entire content of a package even though it contains 400% of the DV for Vitamin_delicious, and others decide that for marketing purposes a "serving" is some goofy amount of product that contains 90 calories or whatever sounds good in their commercials.

[Ron Gardner]

Where is this part coming from?  

 

You are choosing what a "serving" is for your label.  If you want it to be mathematically accurate "4oz (113g)" then go ahead. 

 

Plenty of companies out there make the realistic assumption that people just eat the entire content of a package even though it contains 400% of the DV for Vitamin_delicious, and others decide that for marketing purposes a "serving" is some goofy amount of product that contains 90 calories or whatever sounds good in their commercials.

 

This is coming from the USDA, they are making us change all our labels to say 4oz(112g) on serving size, but still allows 4oz(113g) on net weight. The fact that they say 1oz/28g so 4oz must read 112g.  The math is ridiculous, but I don't write the laws.  

 

I am just trying to figure out why the government isn't just not doing proper math.  I am not opposed to following the rules but would like to understand why it is a rule.

[Scampi]

This may help explain the logic

Serving Size

Some products have a RACC of 30 grams, which needs to be converted to a household measure for the serving size. A RACC of 30 grams is approximately equal to a household measure of 1 ounce, but 1 ounce technically weighs 28.35 grams. If the household serving size is 1 ounce, should the gram weight equivalent of the label serving size be 30 grams or rounded to 28 grams?

For nutrition labeling purposes, if the household serving size is 1 ounce, manufacturers should use 28 grams as the rounded metric weight equivalent, as explained in 21 CFR 101.9(b)(5)(viii).

 

(5) For labeling purposes, the term common household measure or common household unit means cup, tablespoon, teaspoon, piece, slice, fraction (e.g., 1⁄4 pizza), ounce (oz), fluid ounce (fl oz), or other common household equipment used to package food products (e.g., jar, tray). In expressing serving size in household measures, except as specified in paragraphs (b)(5)(iv), (b)(5)(v), (b)(5)(vi), and (b)(5)(vii) of this section, the following rules shall be used:

(i) Cups, tablespoons, or teaspoons shall be used wherever possible and appropriate except for beverages. For beverages, a manufacturer may use fluid ounces. Cups shall be expressed in 1/4- or 1/3-cup increments. Tablespoons shall be expressed as 1, 1 1/3, 1 1/2, 1 2/3, 2, or 3 tablespoons. Teaspoons shall be expressed as 1/8, 1/4, 1/2, 3/4, 1, or 2 teaspoons.

(ii) If cups, tablespoons or teaspoons are not applicable, units such as piece, slice, tray, jar, and fraction shall be used.

(iii) If paragraphs (b)(5)(i) and (b)(5)(ii) of this section are not applicable, ounces may be used with an appropriate visual unit of measure such as a dimension of a piece, e.g., 1 oz (28 g/about 1⁄2 pickle). Ounce measurements shall be expressed in 0.5 oz increments most closely approximating the reference amount.

(iv) A description of the individual container or package shall be used for single serving containers and for individually packaged products within multiserving containers (e.g., can, box, package). A description of the individual unit shall be used for other products in discrete units (e.g., piece, slice, cracker, bar).

(v) For unprepared products where the entire contents of the package is used to prepare large discrete units that are usually divided for consumption (e.g., cake mix, pizza kit), the fraction or portion of the package may be used.

(vi) Ounces with an appropriate visual unit of measure, as described in paragraph (b)(5)(iii) of this section, may be used for products that naturally vary in size as provided for in paragraph (b)(2)(i)(F) of this section.

(vii) As provided for in § 101.9(h)(1), for products that consist of two or more distinct ingredients or components packaged and presented to be consumed together (e.g. dry macaroni and cheese mix, cake and muffin mixes with separate ingredient packages, pancakes and syrup), nutrition information may be declared for each component or as a composite. The serving size may be provided in accordance with the provisions of paragraphs (b)(2)(i), (b)(2)(ii), and (b)(2)(iii) of this section, or alternatively in ounces with an appropriate visual unit of measure, as described in paragraph (b)(5)(iii) of this section (e.g., declared as separate components: “3 oz dry macaroni (84 g/about 2⁄3 cup)” and “1 oz dry cheese mix (28 g/about 2 tbsp);” declared as a composite value: “4 oz (112 g/about 2⁄3 cup macaroni and 2 tbsp dry cheese mix)”).

(viii) For nutrition labeling purposes, a teaspoon means 5 milliliters (mL), a tablespoon means 15 mL, a cup means 240 mL, 1 fl oz means 30 mL, and 1 oz in weight means 28 g.

(ix) When a serving size, determined from the reference amount in § 101.12(b) and the procedures described in this section, falls exactly half way between two serving sizes, e.g., 2.5 tbsp, manufacturers shall round the serving size up to the next incremental size.

 

https://www.fda.gov/...bel#ServingSize