For the question on FORM 3, under item 12, what information should be used to determine if overfill is in excess of 2%? Should we simply compare the target value to the volume listed on the label?

Manufacturers often deliberately put more product into the container than listed on the label, so that the actual dispensed quantity matches the label. For example, if you put 8.3 oz of toothpaste into a tube, and there is 0.3 oz that won't come out because its stuck inside the tube, you may only list 8.0 oz on the label. This type of deliberate overfill (in excess of 2%) is the overfill we are referring to.

We understand that actual variation due to the mechanical parts of the manufacturing processes is often quite minor, in addition to being overwhelming to record. With all this in mind, we ask for the average overfill in excess of 2%. In summary, compare your target/average filling data to the label.

If you fill more than 2% over the amount stated on the label, please report that volume or mass as filled. More.

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