List of Products Covered by the UPLR: An Overview

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The Uniform Packaging and Labeling Regulation (UPLR) aims at providing consumers with accurate information regarding the product name, seller identity, and content quantity of packages so that the purchasers can compare quantity and price with other products.

The Uniform Packaging and Labeling Regulation (UPLR) covers products ranging from apparel and textiles to food and beverage. In this guide, we list some of the categories covered by the UPLR and the various ways that the regulation impacts the packaging labeling requirements.

Product List Creation Methodology

Though the UPLR may apply to many different categories of products, in this guide we only list products that are mentioned in the regulation itself. This article also lists some products that are covered by the UPLR, but which may be exempt from some requirements – under certain conditions.


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General UPLR Requirements

The UPLR generally requires labels on consumer packaging to clearly specify the following:

a. The product’s name

b. Who manufactured, packed, or distributed the package, and their place of business

c. The net quantity of the package’s contents (e.g. weight, mass measure, or numerical count), servings, or uses

Address format

The manufacturer’s, packer’s, or distributor’s address should include the following information:

  • Street address
  • City
  • State (or country, for non-US locations)
  • ZIP Code (mailing code, if any, for non-US countries)

Unit measures

Packages and their contents must be measured in metric units (SI) and US customary units unless exceptions apply. The required information about the products’ sizes might vary (e.g. bedsheets are to be measured in centimeters and inches, and food to be measured in grams and ounces).

Other requirements

Here are some additional requirements (although exceptions might apply):

a. The quantity declaration of a package’s contents should appear in the bottom 30% of the label

b. Letters should have a minimum height of 1.6 mm (1/16 in)

c. Exponents and other characters should be presented in the same type style as the letters, and be proportionate to the type size used

d. The height of letters and numbers should not exceed that of three times their width

Products Covered by UPLR

Wearing Apparel

The UPLR specifies that wearing apparel includes non-textile apparel, leather apparel, and footwear. It also sets exemptions to the net quantities requirements.

Labeling Requirements

Wearing apparel is exempt from the requirements for net quantity statement by count if it is normally sold in pairs, like shoes, or if it is sold as single unit items, like leather goods.

Examples

Wearing apparel includes textile apparel and non-textile apparel items, such as leather goods. Here are some examples of covered products:

  • Footwear
  • Hosiery
  • Gloves
  • Shoes

Textiles

The regulation specifies that textile products include items ranging from bed sheets and comforters to flags and potholders. It also gives examples of products exempted from net quantities requirements set out in Section 6.9 “Bi-dimensional Commodities”.

Labeling Requirements

Section 6.9 requires that labels should state the product’s dimensions (with regards to the quantity declaration) in both SI and US customary units (eg., in cm and inches). For example:


20.3 cm x 25.4 cm (8 in x 10 in)


Textile products are exempt from the above requirements covering bi-dimensional commodities when the quantity statement is specified by count (e.g. 3 items) and the products are of “irregular dimensions”.

Examples

Here are some examples of products mentioned by the UPLR:

  • Blankets
  • Bedspreads
  • Dishtowels
  • Flags

Sewing Threads, Handicraft Threads, and Yarns

The regulation specifies labeling requirements for sewing threads, handicraft threads, and yarns, including requirements concerning unit measures.

Labeling Requirements

The net quantity for handicraft threads and sewing threads should be expressed in terms of meters and yards. On the other hand, the net quantity of yarns should be expressed in terms of weight or mass.

Labels on thread products should identify who manufactured, packed, or distributed said products. Instead of stating a name and address (as is usually required), you may provide the following information:

  • Trademark
  • Symbol
  • Brand
  • Other mark that identifies the manufacturer

Examples

Here are some examples of covered products:

  • Sewing threads
  • Handicraft threads
  • Yarns

Pillows, Cushions, Comforters, Mattress Pads, Sleeping Bags, and Similar Products

The regulation specifies labeling requirements for the products such as pillows, mattress pads, and sleeping bags.

Labeling Requirements

According to Section 11.25, products mentioned above are exempt from several labeling requirements, provided said products fulfill the following conditions:

a. They bear a permanently-attached label

b. They satisfy other requirements in the UPLR

c. Purchasers can clearly read the information on the product’s permanently-attached label

Specifically, covered products bearing a permanent label as designated by the International Association of Bedding and Furniture Law Officials (IABFLO) or the Department of Consumer Affairs, Bureau of Household Goods and Services (BHGS) are exempt from certain labeling requirements, such as:

  • Location
  • Size of letters or numbers
  • Declaration of identity

Examples

Here are some examples of covered products:

  • Pillows
  • Cushions
  • Comforters
  • Mattress Pads
  • Sleeping Bags

Audio Recording Media

The regulation provides the labeling requirements for audio recording media. It also specifies the conditions under which audio recording media packaged and labeled for retail sale are exempt from the net quantity statement requirements.

Labeling Requirements

The labeling requirements for the net quantity of audio recording media are outlined below. Note that audio recording media is exempt from net quantity content requirements if the length of time for the following is not available.

Unrecorded audio media

The label should bear the following information with regards to unrecorded audio media:

a. Length of time available for recording

b. Recording, playing speed, or other machine settings

c. Supplementary information concerning the length of the media

Prerecorded audio media

The length of time for prerecorded audio media that is of entertainment value should be provided on the label.

“Entertainment value” is defined here as the portion of audio media that starts with the first frame of sound and finishes with the end of the sound.

Examples

Examples of audio recording media include:

  • Camera film
  • Video recording tape
  • Audio recording tape

Food

The UPLR covers labeling requirements and exemptions for different types of food products.

Labeling Requirements

The UPLR has several labeling requirements for food products, including:


a. Parallel Identity Declaration: Consumer Package, which states that the declaration of the identity should generally be placed parallel to the base of the package.

b. Location, which states that the declaration of quantity of a package’s contents should appear in the bottom 30% of the display panel(s).

c. Parallel Quantity Declaration, which states that the quantity declaration should generally be placed parallel to the base of the product’s package


The following food products are exempt from the location requirement of the net quantity declaration:

  • Fluid dairy products, ice cream, and similar frozen desserts
  • Butter
  • Eggs
  • Flour
  • Margarine
  • Corn flour and corn meal

We outline some additional exemptions for specific food products below.

Frozen desserts

Fluid dairy products, ice cream, and similar frozen desserts are exempt from location requirements when the net contents of containers are:

a. 8 fluid ounces (fl oz) but are packaged in half liquid pint (liq pt) containers

b. 64 fl oz but are packaged in half-gallon containers

Butter

Butter is exempt from requirements regarding the parallel declaration of identity and quantity when it is packaged in 8 oz and 1 pound (lb) packages with continuous label copy wrapping.

Butter is also exempt from the location requirements when it is packaged in 8 oz and 1 lb units.

Eggs

Each half of 12-egg cartons designed for division in half is exempt from location requirements if the undivided carton conforms to its requirements.

Wheat flour

Packages of wheat flour in the following conventional packages are exempt from location requirements:

  • 2 lb packages
  • 5 lb packages
  • 10 lb packages
  • 25 lb packages
  • 50 lb packages
  • 100 lb packages

Margarine

Margarine in 1 lb rectangular packages is exempt from location requirements.

Corn flour

Corn flour and corn meal packaged in the following conventional bags are exempt from location requirements:

  • 5 lb bags
  • 10 lb bags
  • 25 lb bags
  • 50 lb bags
  • 100 lb bags

Examples

Here are a few examples of covered products:

  • Butter
  • Margarine
  • Corn flour
  • Eggs

Beverage

The regulation also covers beverages. In particular, the measurement units of certain liquid beverages have to be stated in the declaration of quantity. Also, Section 11 of the UPLR covers exemptions for beverages.

Labeling Requirements

According to the labeling requirements regarding the declaration of quantity for consumer packages, the declaration of quantity can express a beverage’s measurement in either SI Units or in US Customary Units.

SI units

Where beverages are concerned, if the declaration of quantity is expressed in SI units, the units should be in liters or milliliters. The units should express the volume at a temperature of 20 °C, except for the following beverages:


a. Distilled spirits – the volume should be expressed at a temperature of 15.6 °C

b. Malt (beer) beverages – the volume should be expressed at a temperature of 4 °C

c. Wine – the volume should be expressed at a temperature of 20 °C


US customary units

If the declaration of the quantity of beverages is expressed in US customary units of liquid measure, the units should be in the following:

  • US gallons
  • Liquid quart
  • Liquid pint
  • Fluid-ounce subdivisions of the gallon

The units should also express the beverage’s volume at a temperature of 68 °F, except for the following beverages:


a. Distilled spirits – the volume should be expressed at a temperature of 60 °F

b. Malt (beer) beverages – the volume should be expressed at a temperature of 39.1 °F

c. Refrigerated food (e.g., milk) – the volume should be expressed at a temperature of 40 °F


Exemptions

Section 11.8 specifies that packages of alcoholic beverages like beer, distilled spirits, and wine are exempt from requirements regarding location and calculation of area of principal panel for purposes of type size, provided other labeling requirements are fulfilled.

Section 11.10 specifies two things regarding single-strength and less than single-strength fruit beverages.

Firstly, they are exempt from bearing liquid measurements in either SI units or US customary units when they are packaged in the following containers of 8 fl oz and 64 fl oz capacity:

  • Glass containers
  • Plastic containers
  • Fluid milk type paper containers

Secondly, they are exempt from requirements regarding the location of the declaration of quantity on a label when the beverage is packaged in glass or plastic containers of the following capacities:

  • Half pint
  • 1 pint
  • 1 quart
  • Half gallon
  • 1 gallon

Examples

Here we list a few examples of beverages:

  • Distilled spirits
  • Malt (beer) beverages
  • Wine
  • Milk

Packaged Seed

The UPLR covers labeling requirements for packaged seeds.

Labeling Requirements

Packages of seeds meant for planting that have net contents of less than 225 g or 8 oz should be labeled in compliance with this regulation.

The quantity statement should appear in the upper 30% of the label. Also, it should be in terms of:


a. The largest whole SI unit for packages weighing up to 7 g

b. In grams and ounces for all other packages weighing less than 225 g or 8 oz


The quantity statement should be in terms of count for some types of seed including:

  • Coated seed
  • Encapsulated seed
  • Pelletized seed
  • Pre-planters
  • Seed tapes

Examples

We list a few examples of covered packaged seeds below:

  • Coated seed
  • Encapsulated seed
  • Pelletized seed
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    • Request a free 30-minute call with Ivan Malloci to learn how we can help you with:
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    • Lab testing

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    Sources: Our articles are written in part based on publicly available information, and our own practical experience relating to product compliance. These are some of the primary sources we use:

    • ec.europa.eu
    • echa.europa.eu
    • ecfr.gov
    • cpsc.gov
    • ftc.gov
    • fcc.gov
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