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November 7, 2002

Mr. Ken Butcher

Office of Weights and Measures

National Institute of Standards and Technology

100 Bureau Drive, Stop 2000

Gaithersburg, MD 20899-2350

Dear Mr. Butcher:

**Re: Metric-Only Option for U.S. Food Manufacturers**

On behalf of the Food Marketing Institute (FMI)[^1], I am pleased to
provide the following comments on a metric-only option for U.S. food
manufacturers of consumer goods. As you know, any change to the Fair
Packaging and Labeling Act must be made by an act of Congress.

FMI does not support the use of metric-only. Metric-only would not be of
any value to the U.S. retailer community or to most consumers in
America. Below is an outline of numerous points of concern that FMI has
regarding the metric-only option:

> Mr. Ken Butcher
>
> November 7, 2002
>
> Page two

-   The majority of consumers do not understand metric measurements.
    Moreover, consumers are not demanding that their food products be
    packaged and labeled using the metric system.

-   Value-comparison between similar products of various sizes may be
    difficult to determine for consumers if some manufacturers use the
    metric-only option and others use inch/pound.

-   

-   Retailers will be faced with consumer complaints when
    value-comparison cannot be determined.

-   International interpretations of metric requirements would likely
    result in package size changes.

-   Changes in package sizes will make certain display cases, such as
    the dairy case and push-in display racks obsolete.

-   Metric will also impact other types of equipment in the grocery
    store, including bakery pans, scales, scanners, computers, and other
    types of measurement equipment, requiring costly conversion or
    replacement.

-   Shipping cases will even have to be replaced if metric-only is an
    option.

-   

-   A metric-only option may conflict with domestic feeding programs.

-   

-   

-   

-   Packagers may change display-only in metric units and that will
    require changes in unit pricing labels.

-   There is a cost for the retailer associated with label changes,
    including design cost and plate changes (plates can cost in the
    neighborhood of \$1,000).

-   Retailers typically keep a label inventory of about 50 weeks.

-   Retailer's operating companies forecast what business might be like
    in the future (ex: tomatoes) and make future labels accordingly
    (thus, more label inventory).

-   In addition to unit pricing, a metric-only option will also impact
    UPC codes and price advertising as well as nutrition information and
    recipe programs.

Mr. Ken Butcher

November 7, 2002

Page three

As outlined above, converting to metric is more than simply changing
labels to make metric the primary method for declaring net contents on a
package. Compliance costs necessary to convert to metric are
significant, exceeding \$1 billion for the food industry. These costs
will be passed on to consumers, including food stamp, WIC recipients and
the elderly, who will see their purchasing power dramatically reduced
when buying groceries, with no added value.

As you know, the federal government attempted to convert to metric in
the mid-1970\'s, and the metric experiment was a dismal failure. There
is no competitive advantage to be gained by mandating or allowing for a
metric-only option for consumer products that are bought, used or
consumed in the United States, especially food products. If a
manufacturer needs to label a product metrically to be globally
competitive, the company will do so.

Thank you again for your consideration of our views.

Sincerely,

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John J. Motley III

Senior Vice President

Government and Public Affairs

[^1]: Food Marketing Institute (FMI) conducts programs in research,
    education, industry relations and public affairs on behalf of its
    2,300 member companies --- food retailers and wholesalers --- in the
    United States and around the world. FMI's U.S. members operate
    approximately 26,000 retail food stores with a combined annual sales
    volume of \$340 billion --- three-quarters of all food retail store
    sales in the United States. FMI's retail membership is composed of
    large multi-store chains, regional firms and independent
    supermarkets. Its international membership includes 200 companies
    from 60 countries.