NIST OWM Executive Summary

2023 NCWM Annual L&R Agenda Items 

July 10, 2023 

1 

Executive Summaries from the NIST OWM Analysis of the

2023 NCWM Laws and Regulations (L&R) 

Annual Meeting Agenda 

The NIST OWM Executive Summary is extracted from the NIST OWM Analysis. This provides the 

NIST OWM community with high level points that summarize the technical aspects and 

recommendations for the Item Under Consideration. The full NIST OWM Analysis can be viewed at 

https://www.nist.gov/pml/owm/publications/owm-technical-analysis. NIST OWM offers these 

comments and recommendations based upon information and input available as of the date of this report. 

Language shown in bold face print by striking out information to be deleted and underlining information 

to be added. Requirements that are proposed to be nonretroactive are printed in bold faced italics. 

For additional information or assistance please contact a NIST OWM Technical Advisor:

Lisa Warfield, L&R Committee, lisa.warfield@nist.gov or (301) 975-3308 

John McGuire, L&R Committee, john.t.mcguire@nist.gov or (202) 981-1750 
NIST OWM Executive Summary

2023 NCWM Annual L&R Agenda Items

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Subject Series List - Laws and Regulations Committee

Handbook 130 – General .............................................................................................................GEN Series

Uniform Laws

Uniform Weights and Measures Law..................................................................................WAM Series

Uniform Weighmaster Law................................................................................................. WMR Series

Uniform Fuels and Automotive Lubricants Inspection Law.................................................. FLL Series

Uniform Regulations

Uniform Packaging and Labeling Regulation ........................................................................PAL Series

Uniform Regulation for the Method of Sale of Commodities...............................................MOS Series

Uniform Unit Pricing Regulation .......................................................................................... UPR Series

Uniform Regulation for the Voluntary Registration of Servicepersons and Service Agencies 

for Commercial Weighing and Measuring Devices.............................................................. RSA Series

Uniform Regulation for National Type Evaluation................................................................NTP Series

Uniform Fuels and Automotive Lubricants Regulation .........................................................FLR Series

Examination Procedure for Price Verification...........................................................................PPV Series

NCWM Policy, Interpretations, and Guidelines........................................................................POL Series

Handbook 133.............................................................................................................................. NET Series

Other Items...................................................................................................................................OTH Series
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Table of Contents

WML - Uniform Weights and Measures Law ...........................................................................4

MOS – Uniform Regulation for the Method of Sale of Commodities .....................................4

UPR – Uniform Unit Pricing Regulation...................................................................................6

FLR – Uniform Fuels and Automotive Lubricants Regulation ...............................................7

NET – Handbook 133: Checking the Net Content of Packaged Goods .................................8

Item Block 2 (B2)Gasoline........................................................................................................9

Item Block 3 (B3)Cannabis.......................................................................................................9

Item Block 4 (B4)E-commerce ...............................................................................................12

Item Block 6 (B6)Transmission Fluid ....................................................................................22
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WML - Uniform Weights and Measures Law 

NIST OWM Executive for WML-23.1 – Section 10. Certificate: Required Entries

NIST OWM Recommendation: OWM believes this item is fully developed and ready for Voting 

status.

• This adds a “Note” to Section 10 to inform the user that electronic signatures are acceptable if 

a State has a digital signature statute

• OWM has learned that 49 states, the District of Columbia, U.S. Virgin Islands have adopted 

the UETA most states adopt the Uniform Electronic Transactions Act (UETA 

https://www.uniformlaws.org/home) which promotes the use of electronic signatures. New 

York has not adopted UETA but has enacted a similar statue. 

MOS – Uniform Regulation for the Method of Sale of Commodities

NIST OWM Executive for MOS-23.1 Section 1.12. Ready-to-Eat Food, 1.12.2. Methods of Sale.

NIST OWM Recommendation: OWM does concur with the latest Item under consideration and 

believes the striking the words “packed or” adds clarity to the submitters original issue. OWM 

believes this item is fully developed and ready for Voting

NIST OWM Executive for MOS-20.5 – Section 2.21. Liquefied Petroleum Gas

NIST OWM Recommendation: OWM recommends this as a Voting Item with the following changes.

• Since 1986, the method of sale requires selling LPG based on 60 °F (15.6 °C) and applies to all 

sales. Although the existing language references a value of “15.6 °C” for temperature 

determinations in metric units, according to the current industry practice for sales of petroleum 

products, the reference temperature for sales in metric are based on 15 °C rather than the exact 

conversion from 60 °F (which is 15.6 °C). Thus, the temperature reference in metric should be 

15 °C.

• LPG has an inherently high thermal expansion of up to 0.4 % per 1 °C (2 °F). This means it 

changes by about 1 % in volume for every 3 °C or 5 °F change in temperature. The volume and 

density of the product varies significantly with temperature and pressure. 

• There are several formatting issues and missing terms that had appeared in past reports but are not 

reflected in 2023 Publication 16. (See the OWM Detailed Analysis for specifics). 

 In 2.21.1. The title “Method of Sale” requires a bold/underscore

 Within Section 2.21.1. Method of Sale. OWM recommends striking the last line that states –“If 

kept, offered, exposed for sale, or sold by:” This same language appears within the first line of 

the regulation.
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NIST OWM Executive for MOS-20.5 – Section 2.21. Liquefied Petroleum Gas

 In 2.21.1.(a) the following words should be reflected in bold/underscore “(a) Weight by the 

kilogram or” and “; or by” 

 In 2.21.1.(b). the following words should be reflected in bold/underscore “(b) Gas” and in 

front of the words “meter cubic” the word “or” should be shown as “; or”. 

 In 2.21.1.(b). the first “see Section 2.21. Note” does not appear in the NCWM report as 

bold/strikethrough. The “Note” was placed at the end of the sentence and should be noted with 

a bold/underscore. 

 In 2.21.1.(b) the word “or” in front of the words “meter cubic” needs to be bold/underscore. 

 In 2.21.1.(c) the words “Liquid Volume” needs to be reflected in bold/underscore. 

 In 2.21.1.(c) liquid volume in the first sentence the word “or” should not be bold/underscore 

 The words “Section 21.1 Note” should be bold. 

 In Section 21.1 Note ANSI B109.1 (2000) needs to be bold/underscore. A “(“ needs to appear 

before the word “For” in the title. 

 In Section Note 21.1. The handbook language reflects “First Edition 1974” this should be 

added into the proposal with a bold/strikethrough. 

 In Section Note 21.1. the word fore should be bold/strikethrough. 

 In Section Note 21.1. the bracket before the word “Under” should be reflected in bold 

underscore, not a strikethrough. 

• As the Committee considers the next steps for this item, OWM would ask that the Committee

consider the new format (layout) as shown under the OWM Detailed Analysis of the existing 

language. This will provide clarity and is easier to read. If this item is not adopted, OWM does 

considers a format change to the existing language to be considered editorial and would move 

forth to apply the format to the next edition of HB130.

NIST OWM Executive for MOS-23.4 – Retail Sales of Electricity Sold as a Vehicle Fuel

NIST OWM Recommendation: OWM believes this item is fully developed and ready for Voting status.

• The Joule unit of measurement is not in use for this commercial application. This will align 

with the USNWG recommendation to delete all references in NIST HB44 to the megajoule, as 

well as align NIST HB130. 
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NIST OWM Executive for MOS-23.4 – Retail Sales of Electricity Sold as a Vehicle Fuel

• The proposal aligns the unit of measurement recognized for electrical energy vehicle fueling 

equipment in corresponding legal metrology requirements in NIST Handbooks 44 and 130 by 

removing all reference to “joule.” 

• The “joule” unit of measurement is not recognized for electrical energy in corresponding 

OIML R 46 Active electrical energy meters and the recently published OIML Guide 22 

Electrical vehicle supply equipment standard.

• NIST OWM acknowledges that removing the “megajoule (MJ)” unit of measurement from the 

handbook does not conform to the practice in place for applying the concept of primary use of 

SI (metric) measurements. However, it appears that the trade practice is limited to use of the 

kilowatt-hour unit of measurement. Should the delivery, displayed quantity, and advertised 

price of electrical energy move to expressions of quantity by the joule the handbook could be 

modified at that time to recognize that unit of measurement.

UPR – Uniform Unit Pricing Regulation

NIST OWM Executive for UPR-23.1 – Section 2. Terms for Unit Pricing.

NIST OWM Recommendation: OWM supports the recommended proposal with the following 

editorial change and then believes it is ready for Voting. 

• The word “the” should be added before the word “net.” “Price per meter, decimeter, 

centimeter or price per yard, foot, or 100 feet, or inch, if the net quantity of contents of the 

commodity is in terms of length.”

• OWM supports the proposed change and recommends adding “100 feet” be added to the 

proposed language. The modified language would read, “Price per meter, decimeter, 

centimeter or price per yard, foot or 100 feet, or inch, if net quantity of contents of the 

commodity is in terms of length.”

• The Uniform Unit Pricing Regulation does not provide guidance for commodities sold by 

length. The terms recommended in the proposal have been in use in the marketplace for many 

years. Adding the proposed language will add clear guidance to the regulation and assist 

retailers with providing accurate and uniform unit pricing information to consumers. 

• Making this change would be consistent with NIST SP 1181 Unit Pricing Guide, A Best 

Practice Approach to Unit Pricing.
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FLR – Uniform Fuels and Automotive Lubricants Regulation

NIST OWM Executive for FLR-23.3 Section 2.20. Hydrogen Fuel

NIST OWM Recommendation: OWM recommends that this item either be returned to the Submitter 

or FALS for additional development.

• The weights and measures community recognizes for more than two decades a concerted effort 

in the hydrogen community to globally align related standards. 

• Address the concerns raised about the proposal resulting in dual fuel quality standards in effect 

should there be a delay in the alignment process. What are the mechanisms in place for rapid 

alignment of the standards and the technical committee with oversight having the ability to 

recognize emerging test methods for the verification of constituent values? 

• There should be clarification on whether specific portions of the ISO standard applicable to 

fueling road vehicles must be cited in the fuel specification requirement. What guidance is 

offered for that interim period when the SAE and ISO standards differ or what would occur if 

as a result of the standard review cycle if the hydrogen community is left with differing 

contaminant specifications where the standards cannot be aligned? 

NIST OWM Executive for FLR-23.4. – Section 4.3. Dispenser Filters

NIST OWM Recommendation: OWM recommends that this item be assigned either back to the 

submitter or to FALS for additional development. 

• The entire proposed new Section 4.3.3. Delivery of Hydrogen Gas should be in bold and 

underscored print and include an annotation at the end of the section to reflect the year the 

section was added to the handbook. (Added 202X). (See Item under Consideration below) 

• It appears that other properties should be considered in selecting a coalescing filter, such as, 

but not limited to the filter’s material compatibility, pressure ratings and type of dispenser. 

• There are various methods of suppling hydrogen depending on whether the source was natural 

gas reformation, electrolysis of water, or whether it was shipped onsite in a liquid state, which 

all seem to determine the level of contamination of various liquids. In addition to those, there is 

the possibility that the equipment used to compress the gas might also be a source of liquid 

contaminants. 

• OWM has concerns with what is size appropriate to the dispensing systems. This information 

should be clarified. The proposal specifies the selection of a “size appropriate” coalescing 

filter and does not specify any other properties or conditions for establishing the suitability of 

this type of filter in hydrogen gas dispensing systems. 

• What is the current input on the proposal from hydrogen dispenser manufacturers, hydrogen 

car manufacturers, and owner/operators of dispensers produced and installed prior to 2022?
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NET – Handbook 133: Checking the Net Content of Packaged Goods

NIST OWM Executive for NET-22.1 – HB133, Section 1.2.6. Deviations Caused by Moisture Loss 

or Gain and Section 2.3.8. Table 2-3 Moisture Allowances.

NIST OWM Recommendation1: OWM recognizes the importance of this work and the progress the 

TG has made thus far. However, there are some significant issues that need to be addressed before this 

item is ready for adoption. OWM recommends the item remain Assigned to the Cannabis Task Group.

• The L&R Committee requested that the NCWM Cannabis TG follow NIST Handbook 130, 

NCWM, Interpretations and Guidelines Section 2.5.6. “Guidelines for NCWM Resolution of 

Requests for Recognition of Moisture Loss in Other Packaged Products” to establish the 

moisture allowances (loss and gain). 

• OWM does not concur with adding a 3 % weight variance without study, documentation, and 

verification of results.

• The 3 % was assigned by the Cannabis TG; the TG based this value on other known 

commodities stated within NIST HB 133 Table 2-3 Moisture Allowance and to align with 

California regulations. The Cannabis Moisture Loss WG has not shared any moisture 

allowance data with the Cannabis TG or L&R Committee. 

• OWM recognizes that there was only one member of the Cannabis TG Moisture Loss WG. 

We encourage other members to join this group, submit data, and reach consensus on bringing 

language forward to the L&R Committee. In 1988, NCWM Task Force developed the 

Guidelines for NCWM Resolution of Requests for the Recognition of Moisture Loss in Other 

Packaged Foods in NIST Handbook 130 NCWM Policy, Interpretations and Guidelines 

Section 2.5.6. we encourage the Cannabis Moisture Allowance TG to follow this guidance.

• They would need to conduct a nationwide scientifically valid study that reflects regional 

environment and seasonal changes in humidity. Any studies should also consider the different 

types of packaging into consideration. This needs to be for both moisture loss and moisture 

gain (as being proposed). 

• Two key components, among others, for any industry in determining moisture loss include: 

1. having “real world” data on product as found in the retail marketing chain (not just 

laboratory moisture loss data) and 

2. collect data on industry-wide basis (rather than from only one or two companies). 

• A modification to NIST Handbook 133 procedures will need to be submitted for consideration. 

Current procedures are written to guide inspectors only on applying a moisture allowance 

when a sample has a negative average error. 

• OWM recommends that the state directors be surveyed (see OWM general comments on Block 

3) to determine if they intend to have their inspectors take enforcement action on overweight 

packages of cannabis. If they do not implement this type of enforcement action for the reason,

they doubt that the public or courts would find those cases justify prosecution, then the 

approach should probably not be added to NIST Handbook 133 and remain as guidance. 
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NIST OWM Executive for NET-22.1 – HB133, Section 1.2.6. Deviations Caused by Moisture Loss 

or Gain and Section 2.3.8. Table 2-3 Moisture Allowances.

____________________

1 In contrast to hemp, marijuana remains a Schedule I substance under the Controlled Substances Act. NIST does 

not have a policy role related to the production, sale, distribution, or use of cannabis (including hemp and 

marijuana). NIST participates in the National Conference of Weights and Measures (NCWM) as part of NIST’s 

statutory mission to promote uniformity in state laws, regulations, and testing procedures. 

Item Block 2 (B2) Gasoline 

NIST OWM Executive for Item Block 2 (B2) – Gasoline

NIST OWM Recommendation: OWM believes that clarification is needed 3.2.5.(b) that offers 

clarification as to what the submitter is recommending (appears below). OWM does concur with the 

recent June 28, 2023 submission to FALS for modifications to the language in the MOS 23.2 and FALS 

FLR-23.2. with the exception of Section 3.2.5.(b). 

3.2.5. Product Transfer Document (PTD) Requirements 

..... 

(cb) Gasoline For fuels containing more than 0.3 % by volume methanol a declaration shall 

be identified as “with” or “containing” methanol.

(Added 2014) (Amended 2018 and 20XX) 

Item Block 3 (B3) Cannabis

NIST OWM Executive for Block 3. (B3) – Cannabis

NIST OWM Recommendation1: OWM recognizes the importance of this work and the progress the

TG has made thus far. However, there are some significant issues that need to be addressed before this 

block of items is ready for adoption. 

• NIST OWM is aware there is concern with the Effective date that the Committee modified to 

the Item Under Consideration. The Committee will need to determine whether this is a 

technical or editorial change. With due process applying we hope the Committee ensures that 

stakeholder feedback was received. We also note that the 2023 Spring Regional Reports for 

CWMA and NEWMA both supported the language moving forward as a vote with no 

modification to the date.

• OWM continues to encourage the Cannabis TG reach out to State Cannabis Commissions, 

Medicinal Programs, Health Departments, and other State Cannabis Regulatory authorities to 
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NIST OWM Executive for Block 3. (B3) – Cannabis

work collaboratively to develop language that is acceptable to all stakeholders. There are 

approximately 22 states that have labeling laws or regulations. 

• Inform stakeholders of any developments by the TG, OWM recommends the TG provide a 

summary to appear in the NCWM Publications. It should be clarified if this TG reports to the 

NCWM L&R Committee or NCWM Board of Directors.

Form 15’s submitted by the Cannabis TG include the following statements. OWM comments are 

included with each point.

• “W&M does not regulate quality. To the extent establishing an acceptable water activity range 

is monitoring quality, this is a positive by-product of monitoring equitable transactions, 

promoting health and safety and preventing diversion.”

OWM Comment: Weights and measures strives for equity in the marketplaces but has not 

been involved with the health and safety side of commodities.

• “Equipment cost. The additional cost of water activity meter(s) should not be prohibitive. It 

could be easily offset by the revenue that would be saved by preventing over drying and 

diversion and/or by fees collected. This could be accomplished by random testing of Cannabis 

flower throughout the manufacturing and distributions processes. It should also be noted that 

setting a water activity standard in the MOS does not establish testing requirements nor 

frequency of testing requirements.” 

OWM Comment: Many states’ package inspection activities are not fee-supported and would 

not be generating income by charging fees for services. 

B3: PAL-22.2. – Section 10. Requirements, 10.XX. Cannabis and Cannabis-Containing Products

• OWM had previously noted our concerns with “Cannabis” being italicized. Is it a requirement 

that this term “Cannabis” appear an italics style for packaging and labeling requirements? If 

so, OWM recommends the Committee add the statement to (a)(2); “the term Cannabis shall 

appear in capitalization and italics style.” If it is not a requirement the capitalization and italics 

format must be removed to avoid confusion in labeling requirements. If the Committee 

believes that a change is required, they should provide an acceptable time for industry to redo 

their labeling. We do not concur that these labels are printed “on demand”. 

• “Cannabis” has a known standard of identity; it is not necessary to add a definition to the 

handbook.

• OWM commends the NCWM Cannabis Task Group for its outstanding work on developing 

these proposals. If these proposals move forward and the NCWM Cannabis Packaging and 

Labeling Subcommittee is disbanded, OWM recommends that Committee task PALS with the 

development of Cannabis labeling.

B3: MOS-22.2 Section 1.XX Cannabis and Cannabis-Containing Products and 2.XX Cannabis 

and Cannabis-Containing Products
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July 10, 2023

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NIST OWM Executive for Block 3. (B3) – Cannabis

OWM does not concur that a method of sale is necessary for this commodity. The Weights and 

Measures Law, Section 16. Method of Sale which specifies:

Section 16. Method of Sale 

Except as otherwise provided by the Director or by firmly established trade custom and practice, 

(a) commodities in liquid form shall be sold by liquid measure or by weight; and

(b) commodities not in liquid form shall be sold by weight, by measure, or by count. 

The method of sale shall provide accurate and adequate quantity information that permits the 

buyer to make price and quantity comparisons. 

• Section 2.XX.X. Water Activity speaks about “unprocessed” Cannabis but does not define 

what this means and there is no reference within ASTM D8197. 

• Water Activity is not related to Moisture Allowance. Water Activity should not be placed into 

the Moisture Allowance Table 2-3 within NIST HB 133. Doing so will only cause confusion. 

• Water Activity is used to measure the growth of microbes using ASTM D8196-20, Standard 

Practice for Determination of Water activity (aw) in Cannabis, helping to ensure its safety. It 

is also used to identify the potency (THC level). In many states water activity testing would be 

conducted by an agency, other than weights and measures. Outside of fuel quality most 

weights and measures programs do not inspect and enforce quality and safety of most 

consumer commodities. 

• To assist the officials, the Committee request that the Cannabis TG develop procedures for 

incorporation into NIST HB133 – in the following areas:

 procedure for determining moisture allowance if the MOS is adopted with criteria for 

Water Activity. 

 Search and seizure (including transportation)

 Safety procedures

 Proper equipment

 Testing for THC (if involved with the testing aspect) (i.e., potency, THC, contaminates). 

____________________

1 In contrast to hemp, marijuana remains a Schedule I substance under the Controlled Substances Act. NIST does 

not have a policy role related to the production, sale, distribution, or use of cannabis (including hemp and 

marijuana). NIST participates in the National Conference of Weights and Measures (NCWM) as part of NIST’s 

statutory mission to promote uniformity in state laws, regulations, and testing procedures. 
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Item Block 4 (B4) E-commerce 

NIST OWM Executive for Item Block 4 (B4) E-commerce

NIST OWM Recommendation: OWM believes that Item WAM-23.1.is fully developed and should 

proceed if OTH-21.1 moves forward as a Vote. On OTH-21.1 NIST is recommending the changes 

noted in the Crosswalk (see below). 

• For OTH-21.1 NIST OWM offers up recommended changes to the Item Under Consideration in the 

Crosswalk (see below). In addition, the NCWM L&R Supporting Documents provides for a clean 

version of the E-commerce Regulation reflecting all the changes specified in the crosswalk.

• NIST OWM believes WAM-23.1 and OTH-21.1 must remain as a “block” through the 

adoption process. 

• PALS member’s, Chair Guay, David Sefcik, and John McGuire met with FTC on January 26, 

2023, and provided an overview of the e-commerce regulation. On May 3, 2023, PALS met to 

review FTC’s letter (dtd. 4/10/2023) which contained FTC staff comments on the draft 

language. 

• Item WAM-23.1. – Section 11. Powers and Duties of the Director products subject to unit 

pricing on E-commerce sites, the states should consult with their legal counsel to determine if 

their state has authority to enforce the e-commerce regulation (if adopted) or whether having a 

(model) weights and measures law is needed. 

Crosswalk of language as it appears in OTH-21.1 and NIST Recommended Changes

Language as it appears in NCWM Pub. 16 (2023) NIST OWM Recommended changes

Section 1. 

This regulation shall apply to products and transactions 

which occur when purchasers are not present to 

purchase a consumer or non-consumer product in 

person. 

This regulation specifically establishes requirements 

for web-based sales (including smartphone and 

computer applications) and other sites/programs which 

offer products for sale and permit customers to make 

purchases without being physically present to inspect 

and select individual products and commodities inperson. This regulation also applies to any product 

information which shall accompany the transactions 

including labeling and receipts. 

Section 1. Application

This regulation shall apply to products and transactions 

which occur when purchasers are not present to 

purchase a consumer or non-consumer product in 

person. 

This regulation specifically establishes requirements 

for web-based sales (including smartphone and 

computer applications) and other sites/programs which 

offer products for sale and permit customers to make 

purchases without being physically present to inspect 

and select individual products and commodities inperson. This regulation also applies to any product 

information that which shall accompany the 

transaction(s) including but not limited to labeling 

and receipts. 

For Section 2. Definitions: 

• NIST OWM Recommends that “Section 2. Definitions” be placed into the NIST HB in alphabetical order. 

As in past situations similar to this, NIST has been authorized editorial rights for this change.
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• Clarifying the definitions in 2.1. Product, 2.2. Consumer Product, and 2.3. Non-Consumer Product to 

align with the following Definitions, 15 C.F.R. § 16.3, Definitions, 15 U.S.C. § 2052, and Terms Defined 

16 C.F.R. § 500. 

• Sections 2.19. SI or SI Units and 2.20. U.S. Customary Units definitions are already defined within NIST 

Handbook 130. 

Section 2. Section 2. Definitions

2.1. Product – An article, commodity or substance 

that is manufactured, grown, harvested, mined, or 

refined for sale. 

2.1. Product – An article, commodity, or substance 

either packaged or unpackaged that is

manufactured, grown, harvested, mined, refined, or 

a package introduced into commerce. 

2.2. Consumer Product – A product sold or 

offered for sale in packaged or bulk form which is 

intended for personal use in a home or residence.

2.2. Consumer Product – A product sold or offered 

for sale in either packaged, unpackaged, or in bulk 

form which is intended for personal use in a home or 

residence consumption or use or enjoyment, by an 

individual or individuals.

2.3. Non-Consumer Product – A product sold or 

offered for sale which is intended for use by a 

business or institution customer for industrial use 

or wholesale distribution. 

2.3. Non-Consumer Product – A product other 

than a consumer product sold or offered for sale 

which is intended for use by a business or 

institution customer and a product intended solely

for industrial or institutional use or for wholesale 

distribution. 

2.4. Online Marketplace – Any person or entity 

who operates an electronically accessed platform 

that includes features that allow for, facilitate, or 

enable sellers to engage in the sale, purchase, 

payment, storage, shipping, or delivery of a product 

within the U.S., is used by sellers for such purposes, 

and has a contractual or similar relationship with 

its users governing their use of that platform to sell 

and purchase products. 

2.4. Online Marketplace – A Any person or entity 

who operates an electronically accessed accessible

platform that includes features that allow for, 

facilitates or enables sellers to engage in the sale, 

purchase, payment, storage, shipping, or delivery of a 

product(s) within the U.S. This is used by sellers for 

such purposes and has a contractual or similar 

relationship with its users governing their use of that 

platform to sell and purchase products. 

2.7. E-commerce Site – The site, program or 

interface through which customers make product 

purchases by means of e-commerce. An ecommerce site may be a manufacturer website, a 

retail website, an online marketplace, a delivery 

service site, a phone application, or other interface 

in which the customer is physically not present to 

inspect and select products. 

2.7. E-commerce Site – An The online site, 

program, or interface through which a customer makes 

product purchases by means of e-commerce. An ecommerce site may be a manufacturer website, a or 

retail website, an online marketplace, a delivery 

service site, phone application, or other interfaces in 

which the customer is physically not present to inspect 

and select products.

2.10. Package. – Except as excluded by Section 1, 

the term “package,” whether standard package or 

random package, means any consumer product or 

non-consumer product which is:

2.10. Package. – Except as excluded by Section 1. 

Application, the term “package,” whether standard 

package or random package, means any consumer 

product or non-consumer product which is:

2.19. SI or SI Units – SI or SI Units means the 

International System of Units as established in 1960 

by the General Conference on Weights and 

2.19. SI or SI Units – SI or SI Units means the 

International System of Units as established in 1960 by 

the General Conference on Weights and Measures 
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Measures (CGPM) and interpreted or modified for 

the United States by the Secretary of Commerce.

(CGPM) and interpreted or modified for the United 

States by the Secretary of Commerce. See the 

“Interpretation of the International System of Units 

for the United States” in the “Federal Register” 

(Volume 73, No. 96, pages 28432 to 28433) for May 

16, 2008, and 15 United States Code, Section 205a - 

2051 “Metric Conversion.” See also NIST Special 

Publication 330, The International System of Units 

(SI), 2019 edition and NIST Special Publication 811, 

Guide for the Use of the International System of 

Units (SI), 2008 edition that are available at 

https://www.nist.gov/pml/owm/owm-products-andservices/publications-and-documentary-standards

or by contacting TheSI@nist.gov. 

2.20. U.S. Customary Units – Units based upon 

the inch, foot, gallon, and the pound commonly used 

in the United States of America. U.S. customary 

units include units for weight, liquid measure, 

linear measure, area measure, volume measure and 

dry measure (see NIST Handbook 130, UPLR 

Section 6. Declaration of Quantity: Consumer 

Packages for additional information). 

2.20. U.S. Customary Units – The U.S. 

customary system of weights and measures is 

recognized as a proper system to be used in the 

declaration of quantity. The declaration of quantity 

is based on weight, measure, or count. (See NIST 

Handbook 130, UPLR Section 6. Declaration of 

Quantity: Consumer Packages for additional 

information).

Section 3. Required Declarations for E-commerce Sites Offering Products for Sale 

NIST OWM recommendation:

• As reflected in NCWM Pub. 16, Section 3.3. does not reflect the subsection letters (a) through 

(e). This is reflected properly in the NIST OWM submitted language.

Section 4. Required Information for E-commerce Products Upon Delivery.

NIST recommends 

• The word change from “cost” to “price” in 4.2.(d) 

• Defining the individual costs to the consumer on the receipt or invoice

• As reflected in NCWM Publication 16, Section 4.3. does not reflect the subsection letters (a) through 

(d). This is reflected properly in the NIST OWM submitted language.

4.2. Random Package E-commerce Delivery 

Requirements. – The following shall apply to the 

information provided within, upon, or together with 

each random package delivered to/received by a 

customer in an e-commerce transaction:

(d) Product Price. – The price charged for the 

product shall be prominently marked upon 

the product or be recorded and displayed 

on documentation within the package. 

Where multiple products are delivered 

4.2. Random Package E-commerce Delivery 

Requirements. – The following shall apply to the 

information provided within, upon, or together with 

each random package delivered to/received by a 

customer in an e-commerce transaction:

(d) Product Price. – The price charged for the 

product shall be prominently marked upon the 

product or be recorded and displayed on 

documentation within the package. Where 

multiple products are delivered concurrently, 
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15

concurrently, it shall be clear which 

information applies to each product. The 

product receipt shall provide the purchaser 

with cost information including the cost of 

the product and any applicable additional 

charges. Although the price information 

may also appear on a receipt or invoice, it 

shall also be provided as specified above 

with the product package. 

it shall be clear which information applies to 

each product. The product receipt shall 

provide the purchaser with cost price

information including the cost of the product 

and any applicable additional charges. 

Although the price information may also 

appear on a receipt or invoice, it shall also be 

provided as specified above with the product 

package. In addition, cost information (if any) 

for shipping, delivery, taxes, and other 

services shall be provided to the customer in 

the manner prescribed as above.

4.3. Bulk Product E-commerce Delivery 

Requirements – The following shall apply to the 

information provided on or with bulk products 

delivered to / received by a customer in an ecommerce sale:

... 

(d) Product Price. – The total price charged for 

the product shall be provided to the 

customer on the transaction receipt.

4.3. Bulk Product E-commerce Delivery 

Requirements – The following shall apply to the 

information provided on or with bulk products 

delivered to / received by a customer in an e-commerce 

sale:

... 

(d) Product Price. – The total product price 

charged for shall include the cost of the 

item, shipping (if any), delivery, taxes, and 

other services. These costs shall be 

individually listed and provided to the 

customer on either the transaction receipt or 

invoice.

Section 5. Unit Pricing Requirements on E-Commerce Sites for Products Offered for Sale

NIST OWM recommends the following: 

• Section 5.1. Products Subject to Unit Pricing on E-commerce Sites, lowercase wording for “price 

information” to be formatted correctly.

• NIST OWM has incorporated subsection (a) and (d) into Section 5..2 Required Unit Price Information. 

Formatted fixed uppercase letters to lowercase.

• The change in the word “presented” to “displayed in NCWM Pub. 16, Section 5.2. (f) 

• Sections will be re-lettered as they fall within the regulation. 

5.1. Products Subject to Unit Pricing on Ecommerce Sites 

(a) Unit Price Information is required for bulk 

products and random packages offered for 

sale on an e-commerce site. 

5.1. Products Subject to Unit Pricing on Ecommerce Sites 

(a) Unit Pprice Iinformation is required for bulk 

products and random packages offered for 

sale on an e-commerce site. 
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2023 NCWM Annual L&R Agenda Items 

16

(b) Unit Price Information is optional for 

standard packages offered for sale on ecommerce sites. 

(b) Unit Pprice Iinformation is optional for 

standard packages offered for sale on ecommerce sites. 

5.2. Required Unit Price Information 

The Unit Price shall be consistent with the 

required method of sale for the product. 

(b) Units of Measure. – The declaration of the 

unit price of a particular commodity in all 

package sizes offered for sale on an ecommerce site shall be uniformly and 

consistently expressed in terms of: 

(c) Exemptions – The following exemptions 

from unit pricing requirements above are 

permitted:

(d) E-commerce sites shall determine the most 

effective units for ensuring value 

comparison of similar products with 

varying product sizes. However, unit 

prices (e.g., price per ounce, price per inch, 

etc.) shall employ consistent units of 

measure for similar or competing products 

posted on the same e-commerce site.

(e) Unit Pricing Expressions shall be listed in 

the nearest cent when a dollar or more. If 

the unit price is under a dollar, it shall be 

listed to the tenth of a cent or the whole 

cent, but both methods cannot be used 

simultaneously. The e-commerce site shall 

accurately and consistently use the same 

method of rounding up or down to compute 

the unit price to the whole cent.

(f) The unit price information shall be 

presented adjacent to the product price 

information. When present, unit price 

information is to be provided in a manner 

so that it is adjacent to all other product 

pricing information.

5.2. Required Unit Price Information –The unit 

price shall be consistent with the required method 

of sale for the product. An e-commerce site shall 

determine the most effective units for ensuring 

value comparison of similar products with varying 

product sizes. Unit prices shall employ consistent 

units of measure for similar or competing products 

posted on the same e-commerce site (e.g., price per 

ounce, price per inch, etc.) 

The Unit Price shall be consistent with the 

required method of sale for the product 

(b) Unit of Measure (a) The declaration of the unit 

price of a particular category of product in all 

package sizes offered for sale on an e-commerce 

site shall be uniformly and consistently 

expressed in the same unit of measure in terms 

of:

.... 

(b)(c) Exemptions The following exemptions from 

unit pricing requirements above are permitted:

(c) E-commerce sites shall determine the most 

effective units for ensuring value 

comparison of similar products with 

varying product sizes. However, unit 

prices (e.g., price per ounce, price per inch, 

etc.) shall employ consistent units of 

measure for similar or competing products 

posted on the same e-commerce site.

(e) (c) Unit Ppricing Eexpressions shall be listed 

in to the nearest cent when it is a dollar or 

more. If the unit price is under a dollar, it 

shall be listed to the tenth of a cent or the 

whole cent, but both methods cannot be used 

simultaneously. The e-commerce site shall be

accurately and consistently use the same 

method of rounding up or down to compute 

the unit price to the whole cent.

(f) (d) The unit price information shall be 

displayed presented adjacent to the product 

priceing information. When present, unit 

price information is to be provided in a 
NIST OWM Executive Summary

2023 NCWM Annual L&R Agenda Items 

July 10, 2023 

17

manner so that it is adjacent to all other 

product pricing information.

Section 6. Declaration of Quantity – E-commerce Products

NIST OWM recommends the following:

• Section 6.1 be separated into two subsections (a) & (b). 

• The information shown in the NCWM 2023 PUB 16 has been separated to be user-friendly. 

6.1. E-commerce Site Requirements – Any ecommerce package offered for sale on an ecommerce site shall be displayed or represented on 

the e-commerce site with a separate Declaration of 

Quantity statement which details the quantity of 

product that the package contains in SI and U.S. 

customary units of measure and/or in count 

consistent with the requirements for packages 

intended for retail sale prescribed in the UPLR (see 

Section 6. NOTE 1) Section 6. Declaration of Quantity: 

Consumer Packages and Section 7. Declaration of 

Quantity: Non-Consumer Packages, as applicable 

or other existing Federal regulations for nonconsumer products. The Declaration of Quantity 

shall be accurately displayed in relevant units to 

facilitate value comparison. The declaration shall 

not be misleading or deceptive. 

6.1. E-commerce Site Requirements – Any ecommerce package offered for sale on an e-commerce 

site shall be displayed or represented on the ecommerce site with a separate Ddeclaration of 

Qquantity statement which details the quantity of 

product that the package contains in. 

(a) the declaration of quantity statement shall 

be recognized SI and U.S. customary units of 

measure and/or in count consistent with the 

requirements for packages intended for retail 

sale prescribed in the as specified in NIST 

Handbook 130, UPLR, Section 6. 

Declaration of Quantity: Consumer 

Packages and Section 7. Declaration of 

Quantity: Non-Consumer Packages, (see 

Section 6. NOTE 1)

, as applicable or other existing 

Federal regulations for non-consumer 

products and; 

(b) the Ddeclaration of Qquantity shall be 

accurately displayed in relevant units to 

facilitate value comparison. shall not 

misrepresent the quantity in any manner 

that can be misleading or deceptive. Any 

declaration of quantity statement that does 

not permit price or quantity comparison is 

forbidden. 

6.2. E-commerce Package Requirements – Ecommerce standard and random consumer 

packages and pre-packaged non-consumer 

packages upon delivery to customers shall have an 

accurate Declaration of Net Quantity on the 

package label. 

6.2. E-commerce Package Requirements – Ecommerce standard and random consumer packages 

and pre-packaged non-consumer packages upon 

delivery to customers shall have an accurate 

Ddeclaration of Nnet Qquantity on the package label. 

6.3. E-commerce Bulk or Unpackaged Product 

Requirements – E-commerce bulk and nonconsumer products which are not packaged prior to 

6.3. E-commerce Bulk or Unpackaged Product 

Requirements – E-commerce bulk and unpackaged 

non-consumer products which are not packaged prior 
NIST OWM Executive Summary

2023 NCWM Annual L&R Agenda Items 

18

purchase, at the time of delivery to the customer, 

shall be accompanied by an accurate Declaration of 

Net Quantity on a printed transaction receipt. This 

printed receipt shall include the product identity, 

unit price, net quantity, and actual charged price in 

a clear and non-misleading manner for all bulk or 

non-packaged products. Electronic receipts may be 

used in place of paper receipts if the information 

required for a paper receipt is printed upon or 

contained in each individual bulk and/or nonpackaged product. Electronic receipts may be 

provided in place of printed receipts if the customer 

specifies an electronic receipt is preferred. 

to purchase, at the time of delivery to the customer, 

shall be accompanied by an accurate Ddeclaration of 

Nnet Qquantity on a the printed or electronic 

transaction receipt to the customer or person. This 

printed receipt shall include the product identity, 

unit price, net quantity, and actual charged price in 

a clear and non-misleading manner for all bulk or 

non-packaged products. Electronic receipts may be 

used in place of paper receipts if the information 

required for a paper receipt is printed upon or 

contained in each individual bulk and/or nonpackaged product. Electronic receipts may be 

provided in place of printed receipts if the customer 

specifies an electronic receipt is preferred. The 

printed or electronic receipt shall include the 

product identity, unit price, net quantity, and actual 

charged price in a clear and non-misleading 

manner for all bulk or unpackaged products. 

6.7. SI Units: Mass, Measure. – A declaration of 

quantity for an e-commerce product or package 

shall be expressed in units according to the 

provisions of the UPLR (add appropriate 

reference), the applicable Method of Sale 

Regulation (add appropriate reference) or the 

applicable regulation(s) of another regulatory 

agency. Generally, declarations are to follow the 

requirements detailed below:

(Formatting issues on lettering)

6.7. SI Units: Mass and Measure. – A declaration 

of quantity for an e-commerce product or package shall 

be expressed in units according to the UPLR (add 

appropriate reference) the applicable Method of 

Sale Regulation (add appropriate reference) or the 

applicable regulation(s) of another regulatory 

agency. Generally, declarations are to follow the 

requirements detailed below: as specified in 

Handbook 130, Sections 6.5 through 6.6.2. and 7.4 (see

Section 6. Note 1) or the applicable regulation(s) of a federal 

or state regulatory agency. 

6.8. U.S. Customary Units: Weight and Measure. 

– A declaration of quantity for an e-commerce 

product or package shall be expressed in units 

according to the provisions of the Uniform 

Packaging and Labeling Regulation ((see Section 6. Note 1)

Sections 6.7. through 6.8.2., the applicable Method 

of Sale Regulation ((see Section 6. Note 2) as applicable, or 

the applicable regulation(s) of a regulatory agency. 

Generally, declarations are to follow the 

requirements detailed below.

6.8. U.S. Customary Units: Weight and Measure.

– A declaration of quantity for an e-commerce product 

or package shall be expressed in units according to the 

provisions of the Uniform Packaging and Labeling

Regulation UPLR as specified in Handbook 130 (see 

Section 6. Note 1) Sections 6.7. through 6.8.2. and 7.5. (see 

Section 6. Note 1)

, the applicable Method of Sale 

Regulation ((see Section 6. Note 2) as applicable, or the 

applicable regulation(s) of a federal or state 

regulatory agency. Generally, declarations are to 

follow the requirements detailed below.

Section 6. NOTE 1: See NIST Handbook 130, 

Uniform Packaging and Labeling Regulation 

(UPLR).

Section 6. NOTE 2: See NIST Handbook 130, 

Uniform Regulation for the Method of Sale of 

Commodities.

Section 6. NOTE 1: See NIST Handbook 130, 

Uniform Regulations, Uniform Packaging and 

Labeling Regulation.

Section 6. NOTE 2: See NIST Handbook 130, 

Uniform Regulation for the Method of Sale of 

Commodities.
NIST OWM Executive Summary

2023 NCWM Annual L&R Agenda Items 

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19

Section 7. Declaration of Identity: E-commerce Products 

NIST recommends retitling Section 7.2. to read “Identity Declaration – The identity declaration shall be in 

terms of:”

7.2. The identity declaration shall be in terms of: 7.2. Identity Declaration – The identity declaration 

shall be in terms of:

Section 8. Declaration of Responsible Person: E-commerce Products

NIST OWM recommends adding the word “; or” after each subsection within Section 8.3. E-commerce 

Site Requirements. 

8.3. E-commerce Site Requirements. – The 

operator of an e-commerce site offering products 

for sale shall comply with at least one of the 

following requirements regarding each product 

offered for sale:

(a) The e-commerce site shall provide the 

name and address of the product 

manufacturer, packer, or distributor. 

(b) The e-commerce site shall provide the 

name and website address of the product 

manufacturer, packer, or distributor. 

(c) The e-commerce site shall provide the 

product brand name or the name of the 

product manufacturer, distributor, or 

packer, when product manufacturer, 

distributor or packer address information 

is displayed on the package label at the 

time the product is delivered to the 

purchaser. 

(d) When the e-commerce site owner or 

operator is the also the product 

manufacturer, packer or distributor, the ecommerce site shall clearly and 

conspicuously display its name, address, 

and contact information on both the ecommerce site and on the transaction 

receipt. 

8.3. E-commerce Site Requirements. – The 

operator of an e-commerce site offering products for 

sale shall comply with at least one of the following 

requirements regarding each product offered for sale:

(a) The e-commerce site shall provide the name 

and address of the product manufacturer, 

packer, or distributor; or 

(b) The e-commerce site shall provide the name 

and website address of the product 

manufacturer, packer, or distributor; or 

(c) The e-commerce site shall provide the product 

brand name or the name of the product 

manufacturer, distributor, or packer, when 

product manufacturer, distributor or packer 

address information is displayed on the 

package label at the time the product is 

delivered to the purchaser; or

(d) When the e-commerce site owner or operator 

is the also the product manufacturer, packer or 

distributor, the e-commerce site shall clearly 

and conspicuously display its name, address, 

and contact information on both the ecommerce site and on the transaction receipt.

Section 9. Product Photograph or Accurate Product Graphic Representation/Image: E-commerce Site 

Requirements 

NIST OWM recommends changing some words for sentence structure and clarity within Section 9.1. through 

9.5.
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2023 NCWM Annual L&R Agenda Items 

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9.1. E-commerce Standard Packages. – Any ecommerce package offered for sale on an ecommerce site shall be represented on the site with 

a current photograph of the package offered for 

sale. As an alternative, a detailed and accurate 

photographic depiction or representation of the 

package may be displayed. This picture or 

graphical representation shall be sufficiently sized, 

detailed, and clear to enable the customer to 

distinguish this package or product from similar 

packages including varying sizes, varieties, and 

product functions. When a consumer can customize 

an e-commerce package, a photographic 

representation of the customized product can be 

provided in addition to the required pre-customized 

product. 

9.1. E-commerce Standard Packages. – Any eEcommerce packages offered for sale on an ecommerce site shall be represented on the ecommerce site with a current photograph of the 

package offered for sale. As an alternative, a detailed 

and accurate photographic depiction or representation 

of the package may be displayed. This picture or 

graphical representation shall be sufficiently sized, 

detailed, and clear to enable the customer to distinguish 

this package or product from similar packages 

including varying sizes, varieties, and product 

functions. When a consumer can customize an ecommerce package, a photographic representation of 

the customized product can be provided in addition to 

the required pre-customized product. 

9.2. E-commerce Random Packages. – Ecommerce random products offered for sale on an 

e-commerce site shall be accompanied on the site by 

a representative picture or photographic depiction 

of product (packaged or unpackaged) which is 

being offered for sale. This picture or photographic 

depiction shall be sufficiently sized, detailed, and 

clear to enable the customer to see the product and 

the pictured item shall be representative of the 

product being offered for sale. When a consumer 

can customize an e-commerce random package, a 

photographic representation of the customized 

product can be provided in addition to the required 

pre-customized product.

9.2. E-commerce Random Packages. – Ecommerce random products offered for sale on an ecommerce site shall be accompanied on the ecommerce site by a representative picture or 

photographic depiction of representing the product 

(packaged or unpackaged) which is being offered for 

sale. This picture(s) or photographic(s) depiction shall 

be sufficiently sized, detailed, and clear to enable the 

customer to see the product and the pictured item 

shall be representative of the product being offered 

for sale. When a consumer customer can customizes

an e-commerce random package, a photographic 

representation of the customized product can be 

provided in addition to the required pre-customized 

product.

9.3. E-commerce Bulk Products and Select 

Random Packages. – Bulk products offered for sale 

on an E-commerce site shall be accompanied on the 

site by a representative picture or photographic 

depiction of the unpackaged product which is being 

offered for sale. Products packaged in random 

packages shall be displayed on the site with a 

representative depiction of a representative 

package, a clear and conspicuous statement 

explaining that packaged products are of random 

quantity, and instructions to customers regarding 

the means to specify a maximum or minimum 

package quantity in ordering and purchasing the 

product. The picture(s) or photographic 

depiction(s) shall be sufficiently sized, detailed, and 

clear to enable the customer to see the product and 

the pictured item shall be representative of the 

product being offered for sale. When a consumer 

can customize bulk or random package, a 

photographic representation of the customized 

9.3. E-commerce Bulk Products and Select 

Random Packages. – Bulk products and select 

random packages offered for sale on an Ecommerce site shall be accompanied on the ecommerce site by a representative picture or 

photographic depiction of the unpackaged product 

which is being offered for sale. Products packaged 

in random packages shall be displayed on the site 

with a representative depiction of a representative 

package, a A clear and conspicuous statement 

explaining that the packaged products are of random 

quantity, and instructions to customers regarding the 

means to specify a minimum or maximum or 

minimum package quantity in when ordering and/or

purchasing the product. The picture(s) or photographic 

depiction(s) shall be sufficiently sized, detailed, and 

clear to enable the customer to see the product and the 

pictured item shall be representative of the product 

being offered for sale. When a consumer customer 

can customizes a bulk or random package, a 

photographic representation of the customized product 
NIST OWM Executive Summary

2023 NCWM Annual L&R Agenda Items 

July 10, 2023 

21

product can be provided in addition to the required 

pre-customized product.

can be provided in addition to the required precustomized product.

9.4. E-commerce Non-Consumer Packages. –

Non-consumer products offered for sale on an ecommerce site shall be accompanied on the site by a 

representative picture or photographic depiction of 

the product which is being offered for sale. This 

picture or photographic depictions shall be 

sufficiently sized, detailed, and clear to enable the 

customer to see the product and the pictured item 

shall be representative of the product being offered 

for sale. When a consumer can customize an nonconsumer package, a photographic representation 

of the customized product can be provided in 

addition to the required pre-customized product. 

9.4. E-commerce Non-Consumer Packages. –

Non-consumer products offered for sale on an ecommerce site shall be accompanied on the ecommerce site by with a representative current 

picture or photographic depiction of the product which 

is being offered for sale. This picture or photographic 

depiction(s) shall be sufficiently sized, detailed, and 

clear to enable the customer to see the product and the 

pictured item shall be representative of the product 

being offered for sale. When a consumer can

customizes a non-consumer package, a photographic 

representation of the customized product can be 

provided in addition to the required pre-customized 

product.

9.5. Pictures on Receipts: Transaction receipts 

are not required to provide pictures or 

photographic depictions

9.5. Pictures on Receipts – Transaction Ecommerce receipts are not required to provide pictures 

or photographic depictions.
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Item Block 6 (B6) Transmission Fluid 

NIST OWM Executive for Section Item Block 6 (B6) – Transmission Fluid

NIST OWM Recommendation: OWM recommends this be withdrawn for the following reasons:

IFG Chair Johnson reported to FALS that designating transmission fluid “obsolete” is impractical for a 

variety of reasons, including lack of a comprehensive and consistent standards setting organization 

mechanism, and therefore the original amendment approach should no longer be pursued. 

Chair Johnson has recommended they should switch focus (purpose) to developing other potential 

consumer protection language for labels. OWM recommends this item be Withdrawn. Any future 

items should be resubmitted to the L&R Committee for consideration.