17. Process control
Quantity control
A highly regulated process control, to ensure that the weight, volume and count of the product is accurate.
Quantity control
Quantity control includes weight, volume, and count. This means that it includes average weight, minimum weight, catch weight, volume, and count. This is one area of the standard which is highly regulated, therefore it’s critical that the legislation relevant to the country where the product will be sold – must be followed.
The aim of quantity control is to ensure that the correct amount of product or number of units, meets the declared information on the pack.
The following article focuses on the legal requirements for weight in the UK and EU. For requirements for other countries, please refer to their own legislation. Where we have them, these will be listed on our legislation page.
IMPORTANT
Before applying average weight rules, please ensure that you have to have an average weight mark on your pack. If your customer doesn’t specify it and you don’t sell the product in the EU, then it’s recommended that you use minimum weight instead.
The standards
This article is written to meet the following quantity control requirements:
| BRCGS Food Safety Issue 9 | 6.3.1, 6.3.2 Quantity control |
| BRCGS Packaging Issue 6 | No specific clauses |
| BRCGS Agents & Brokers Issue 3 | No specific clauses |
| BRCGS Storage & Distribution Issue 4 | 15.10, 16.1 – 16.5, 16.7 Quantity control |
| FSSC22000 Version 6 | 2.5.9 Quantity control |
| IFS Food Version 7 | 5.5 Quantity control monitoring |
| SQF Edition 9 | No specific clauses |
| FSMA Preventive controls for human food (Final 2015) | No specific clauses |
| Additional standards | Tesco, M&S |
The requirements
Quantity control procedures must:
- Meet the legal requirements for the country of sale.
- Meet customer requirements.
The system used for quantity control must be defined as one or more of the following:
- Average weight or volume.
- Minimum weight or volume.
- Catch weight.
- Net weight.
- Count.
The procedure for quantity control must include:
- Details of applicable legal requirements.
- The quantity monitoring process and who is responsible for the checks.
- Quantity parameters and acceptable limits.
- Corrective action procedures.
- Accuracy checks for measuring equipment.
- Completion of records.
Average weight
Where product is packed to average weight/volume/count it must be compliant to the relevant legislation, such as; the Weights and Measures Act 1985 and the Weights & Measures (Packaged Goods) Regulations 2006 as amended.
BRCGS Food Safety Issue 9
There were no changes in Issue 9 that impact the clauses in this article.
Customer
This is a general overview of the type of quantity controls detailed in customer codes of practice, however your business must refer to your customer’s standards to identify the requirements that are applicable.
The customer standards provide more detail on how to comply with the relevant legislation. They also provide requirements for component weight checks, to ensure that quantities defined in the ingredient declaration (QUID) are compliant.
Their standards also define their expectations for the equipment that you must use and the minimum fail-safe systems that must be in place.
Understanding average weights…
If you’d like to know more about average weights and how to apply the rules, please join Smart Knowledge Plus. Your subscription includes access to our legislation and document library, as well as detailed information about topics – including average weights and the 3 packers rules.
Process control
Pack 17: Process control
If you’re updating your quantity control systems, for average weights or minimum weights, you need our documentation pack – Pack 17: Process Control. Not only does it include quantity control, process control and traceability – it provides everything you need to improve process control on your site.
Hello, I don’t think I’m clear on the “and when checks are carried out at the end of the line, the maximum number for a batch is the hourly throughput”. So if we are producing approx. 800 packs an hour and the runs are minimum 4h and maximum 8h and we checking the weight of the finish product do we need to check 50 packs every hour or do we need to check 50 packs in the 4-8h period as the production will be <10k packs?
Your help will be much appreciated.
Hi Kamila
The first point is to work out the batch size. 800 packs an hour, for a maximum of 8 hours is 6,400 packs. Therefore, the batch can be 6,400 and so you need to do 50 samples across that batch.
Kassy
Really helpful article and comments from others. ☺
My query is: on an inline check weigh system at the start of the run we check the t2 test piece which is always rejected. however the t1 test piece is not always rejected.
My thought process is: Based on the actual number of ‘product’ passed through the on line check weigh, at that time, (2 = the test pieces) as long as the weight is identified as the t1 weight or below, it should be automatically rejected, as the percentage t1 would be 50%.?
To put simpler if i started a run and ran two products through that were both t1 weights, they should both be rejected via the automatic rejection system.
Hope this makes sense. Can you advise please.
Thank you
Hi Becky
I’m not sure what you’re trying to achieve? Is your machine set up to reject T1? Why are you calculating the percentage T1 reject for your test samples?
Kassy
what happens if i export a product of north american origin (25kg) to germany, where the legal tolerances in the USA are 1% maximum and minimum. considering the TNE rule, would my product be in trouble?
Hi Team,
Slightly different question, if we have chocolates packaged in a plastic jar. The jar states 50 chocolates per jar, is there an established tolerance here. For example is there an acceptable range either side of 50?
Thanks
Jon
Hi Jon
If you state that there is 50 chocolates in a jar, you have to make sure there is at least 50 chocolates in the jar.
Thanks
Kassy
Is it right to label a product with net weight as (600-700g e ). This is a variable weight product, eg whole chicken, Roasted half chicken. Should the ‘e’ mark be used.
Hi Rebecca,
This sounds odd. Are you able to email me the label so I can understand this a bit more? You can email on kassy.marsh@techni-k.co.uk
Kassy
Hi Kassy, The explanation which you have provided on three packers rules is very simple and easy to understand however need to check on assembling of multicomponent products which are all packed to different average weights e.g. 20g , 84g, 150g into one final pack. So what weight we are allowed to declare on the final packaging. Should we go with sum of pack weight of all components as they are already packed to average weight or do we need to check any variance, if so are there any guidelines on it.
Hi Runal
It depends on what you’re declaring on the pack. If you’re declaring one weight – then it’s the average weight of the total product. If you list the components and their weights separately, then you don’t need a total weight.
Does that make sense?
Kassy
Hi there,
If we are allowed no more than 2.5% of T1s in the a batch (I assume this is between T and T1), what percentage are we allowed between T1 and T2?
Second question, can the sample batch be taken as a whole at the end of the run or does it have to be done at defined intervals during production?
Thanks
Elena
Hi Elena
There’s no percentage for weights between T1 and T2 (T1). The purpose of these weights is to determine the average. The samples ideally should be taken throughout the run, so that you get a result that’s representative of the whole run.
Kassy
Hi Kassy,
First of all many thanks for such a good explanation.
I have a question that might be a bit silly but I am not fully confident about the average weight checking process itself if we want to extrictly the law… By reading the legislation, literally, I see the following:
“the number of packages checked shall be equal to the number in the samble, as indicated in the table (…)”,
but does not seem to give the option to take more? (again, literally speaking). I would expect to see “…shall be equal or greater than the number of the sample…”. So, basically, if I “sample” the whole batch, instead of just 50, 80 or 125, according to the table, I understand I would still be complying with the “3 packers rule”, wouldnt’t I?.By my concern is that, as it is written, the legislation would now allow that?? It should be alright, otherwise the checkweighers doing the checks all the batch through at the end of the line wouldn’t be valid, but with the extrict writing of the law, I don’t know what to think…
Hope this makes sense? What do you think?
Many thanks in advance!
Jose
Hi Jose
Yes of course you can take more, if you look it like that – then the number is a minimum.
Kassy
Hi Kassy,
If we pack to minimum weights can we display the e mark? By packing to minimum weight we know that all are above average weight (if that makes sense).
Thanks,
Thank you for the information Kassy. Could you elaborate more on this point “2.6 When packages are checked at the end of the packing line, the number in each batch shall be equal to the maximum hourly output of the packing line, without any restriction as to batch size.”? How does this impact the number of packages to be checked?
Hi Renata
It’s talking about the fact that the size of the production defines the sample size, as I’ve explained in the article.
Kassy
Hi Kassy,
I am trying to classify what our batch should be.We have a inline Checkweigher and our hourly production varies from 3,600 – 8,160 units per hour. We currently start a new batch every hour even though its the same production run/order. Can we class the one order as a batch? The number of units per order also varies from 1,000 – 20,000. Because of changes in density and not knowing when the density swings are coming we get excessive rejects especially at the start of a new hour as we havent built up enough cartons to stay below 2.5%.
I hope that is clear?
Many thanks
David
Hi David
The batch requirements are detailed on the article, please see the blue section called ‘defining a batch’.
Thanks
Kassy
Hi Kassy
We are currently reviewing our weights procedure and feel like we are going round in circles with our sampling size.
We fill on average 20,000 bottles per hour. These then get packed into cases of 12 (equivalent to 1666 cases). Which number needs to be used when calculating the required sampling size? If it’s bottles then we should be sampling 50 bottles every half an hour? I don’t want to go upset our production team until I know the answer!!!!
– Just for context – The finished cases of 12 are sold to our customers. Our consumers then purchase the bottles individually each marked with the weight of the bottle.
Hi Matthew,
You’re quite right – that you need to weigh 50 units every 30 minutes, if you’re doing that throughput. However, the sampling is a guideline in the legislation. If you do less that it says, you take on the risk associated with that. Given that you’re filling liquids, do you have something that looks for fill height? You can use a combination of manual weight checks (I’m presuming you don’t have an inline checkweigher from your comment) and other checks to reduce the exposure.
Drop me an email if you’d like to discuss in more details. kassy.marsh@techni-k.co.uk
Kassy
Hi Kassie,
We supply product to the catering/service sector. Our customers then sell our product to pubs/restaurants etc.
Previously we have sold directly to the customer, but don’t now. You’ve stated above that B2B doesn’t need to declare an e mark.
Can you please give me a pointer in the direction of information regarding whether we need to comply to average weight or minimum weight for B2B? For example, could we just state 12 units?
Hi Kassy,
Can I just check that it is not fundamental to have a checkweigher in place when packing to average weight, as long as we have a sufficient sample size for our batch which is checked manually on scales. We pack no more than 5000 packs in a batch therefore we would need a minimum of 50 packs for our sample to be checked manually? Is this correct?
Many thanks
Becky
Hi Becky
Yes that’s quite right. 🙂
Kassy
Hi Kassy,
Many thanks for your reply. One other quick question. Is it stated in legislation that 50 packs is the minimum? I don’t seem to be able to find reference to this. I have found reference to 10,000 packs being one batch but no reference to 50 being the minimum sample size.
Kind Regards
Becky
Hi Becky, I’ve added a reference to the article – so that you can see where this comes from.
Hi Kassy,
I’ve just had a chat with the (now upset) production manager, and he asked that as our production run is only 300 pies then do we still have to weigh 50 of them? They are sold as individual packed rte products so I’m assuming the answer is yes?
Cheers again, David
Thank you Kassy, very much appreciated.
Cheers,
David
Hi Kassy,
Hope you can help me, we produce between 300-500 products in a run, we are looking to use the 3 packers rule and weigh the finished prepacked product on a calibrated scale, question is (product is 200g), how many should we weigh? Would it still be 50 products? Even for such a small run?
Hi David
If you’ve defined the batch to be 300-500 products, then yes – you need to do 50 products per batch.
Kassy
Thank you Kassy, very much appreciated.
Cheers,
David
Thank you Kassy,
This confirms we should be fine with sampling number of packs at agreed frequency by placing packaging on the scale, taring it each time and checking component weight to then establish final total average weight, which will always be equal or above declared as essentially we are asking packers to pack to the minimum.
Hope you can help
We are packing product that goes into scallop shell, which is acting as as packaging. Due to the nature of the scallop shell the difference in weight of one shell to another can be up to 40g, meaning finished product tare can have up to 80g difference in tare (with declared weight 148g, 2 x scallop shell)
Due to that we cannot wight product based on a established tare of the packaging as this presents too much variance. Destructive test, where components are removed from shell and weight individually is limited due to nature of components (not able to scoop out them fully from the shell) and high value of the product.
Does legislation offer exception to the sampling requirement?
Hi Sylwia
No – you’ll need to take the variation into consideration when working out the target weight, so that essentially you’re giving product away.
The only way of not doing this would be to do sampling tests without the shell (deposit into a known weight piece of packaging). Does that make sense?
Kassy
Thank you Kassy,
This confirms we should be fine with sampling number of packs at agreed frequency by placing packaging on the scale, taring it each time and checking component weight to then establish final total average weight, which will always be equal or above declared as essentially we are asking packers to pack to the minimum.
Thanks Kassy. That’s a great help.
Hi Kassy,
Is there a legal requirement to mark an outer pack with an ‘e’mark if it follows Packers Rules regarding average weight? The products are supplied to caterers and not directly to consumers.
Hi Alan, Only if the product is retail and going to Europe. B2B products don’t have to have it. Kassy
Hi, we are struggling to work out the reference test sampling procedure for our product. The packs are checked manually at the end of the packing line which runs at 4800 packs per hour.
I would need a little more info to help you with this. For example, why does the product/batch not fit within the given details?
Hi, hope you are well and can help. We produce to the average weight system as we have an e mark on our packs. We have 2 filling heads. We currently take 5 packs across both lanes (10 packs) at start of run, every half hour thereafter and at the end of the run. We produce pack sizes of 250g/454g/500g on this line. All checks are the same for every pack size. I’m getting challenged on why it is every half hour. Any suggestions?
Hi Patricia
Well the first thing I’d do is work out how many samples you should be taking over the run, based on your batch size. How many is that?
Kassy
Hi Kassy, One batch is 5200T = 1 mix. We could make 2 mixes per product or we could make 12 mixes per product.
Question. How often should we check the checkweigher accuracy? Currently my company does a 60 bag pass of same product 2 times per year to certify the accuracy. But we also do a 10 bag pass of whatever product we are running at the start of the run to check accuracy and then 12 hourly if running more than 12 hours. Is this 10 bag check required or will 1 pack be sufficient if it weighs no more than 1/5th of t.n.e as it takes alot of time to do the 10 bag check and I’m trying to get it down to the 1 bag pass as, as far as I’m concerned the checkweigher has already been validated by the 60 bag check and this extra check seems unnecessary.
Hi Gary. That does sound a little excessive. Annually, I would expect there to be a calibration (not accuarcy). Then, the accuracy checks need to be more frequent. How often you do these (as long as you don’t have customer standards to comply with) is up to you and should be based on risk assessment. I would refer to the manufacturers guidelines and also use the data that you’ll have from all the previous checks you’ve done. That way you can come up with a solution that’s based on the risk of the machine failing.
Sorry not a black and white answer, but I hope that helps.
Kassy
Hi Kassy,
Just wondering about the behavior of the T.N.E. table, why is it not a continuous function? for example, any value of target weight between 50g and 100g yields a T.N.E of 4.5g but then for 105g is 4.725g and for 110g is 4.95g.
Kind Regards
Hi Felice
Gosh – I don’t know. This is something that’s been around a long time and is part of legislation (which is always hard to read and understand).
Kassy
Hi Kassy,
We are producing soft and spirited canned drinks in 250ml and 330ml size. With e-mark on our package. So I’m trying to understand how to comply 3 packers rules. How can I work out density for can ? I just can’t get my head around it. I have worked out for example if tare weight for 250ml is 256.7g, then -2T would be 256.7-18(2T)=238.7g ?
What’s the easiest way to work out density and then back to volume?
Do these checks need to be done every time when making same product?
Thank you
Kind regards,
Agnese
Hi Agnese,
To work out density you need to measure 1 litre and then weigh it – don’t take the can into account. The can should be tared off (so you’re only weighing the product inside). The weight can then be calculated to volume.
Feel free to send me your calculations and I’ll check them for you. kassy.marsh@techni-k.co.uk
Kassy
Looking at the rule. 10,000 per hour /day same batch 50 units across run. ( 1 hour or whole day)
If my batch is only 3000, will it be right to sample 15 packs during the run?. ie 5 at start , 5 after 30 minutes and 5 at end of run? supposing the run is finished in an hour.
This should be reasonable? is the rule saying 50 for same batch under 10,000 units for a run?
Hi Patricia
No, it’s 50 samples per batch, and the batch can be a maximum of 10,000 units.
So a 3,000 unit batch would still be 50 samples.
Kassy
Hi Kassy,
If we are using an average weight system, have an inline checkweigher and our program is set up to record all weights and reject anything T2 or below and record this on a system with a print out
Is it sufficient to use this automated check system and do our verification checks on this or do we still need to complete manual checks on the line?
Thanks
Hi Kelsey,
No you don’t have to do manual checks as well. You just need to verify that the checkweigher is working, say once per shift and also verify (sign off) the 3 packers rules.
Kassy
Thanks Kassy, So if the ZOI is 1.5g we set the t2 test pack to T2 +1.5g, would that not prevent it being rejected in some cases?
Hi Kassy,
I’m a bit confused about the defining a batch section. I just don’t understand why a batch size is limited to 10,000 units (around 3 hours production for us). In our setup none of the staff come in contact with the product during packaging, therefor putting a limit on units per batch seems completely arbitrary. For us from a traceability perspective surely the important part is all about the raw materials in the product and that they have been processed correctly/safely?
All the best,
Jacob
Hi Jacob, I’m not sure I understand your question. You seem to be relating quantity directly to traceability? The ‘batch’ only refers to the batch for average weights. You don’t have to use the same definition of a batch for everything else too…
Hi Kassy,
It is such a good explanation.
I’ve got a question.
We are going to implement the average weight procedure for our product.
For using e-mark on our package, is there any concern about registration process in some authority or can add by ourselves by following e-mark specification?
Hi Zaw,
Yes – it’s detailed here: https://europa.eu/youreurope/business/product-requirements/labels-markings/emark/index_en.htm
Thanks
Kassy
My business runs product through an inline checkweigher system( loma). The batch report calculates the average weight no of T1s and T2s below 2.5%. Manual checks are every 30 minutes sampling 3 packs per 30 minute. Run time consists of 10 hours, up to 30000 units produced. My questions is do we need to do the weight checks? Are we covered by the automated batch report from the checkweigher.
Do we need to apply the packers rule 2 and 3 or are we legally covered.
T1 and T2 set automatically by the machine when entering the nominal. All T1 and T2 are set correctly accordingong to % guidelines.
Hi Stuart
You still need to apply the rules, but the verification is reviewing the report produced and signing it off. It will still require action if T1s are greater than 2.5% I presume, unless the checkweigher starts rejecting these for you?
Kassy
Hi Jawad
Thanks for your comments, we really appreciate your feedback on the article. For verification the tolerance needs to be based on the accuracy of the machine. I’m asking a specialist in this field if he could reply about the zone of indecision for me.
Thanks Kassy
Hi Kassy- Thanks for your reply, did you get any update for the specialist?
Hi Jawad,
We didn’t apologies – I was on holiday and I thought it would be quicker for them to reply than me. But I’m back now – so.. Regarding the zone of indecision this is the variation in weight that’s caused by the product travelling over the scale. I’m not sure how this relates to your question on T2 packs? The contractor that you use to calibrate your scales should be able to work with you to establish the zone of indecision and how that inaccuracy should be incorporated into the weight checks that you do.
If I’ve not answered your question, please come back to me.
Kassy
Can you direct me to any guidance on how much below T2 to set a reject test pack, is it suitable to say 1g below or should it be a percentage of the pack weight? Do we also need to take the ZOI into consideration at this stage?
Hi Pamela
You need to take the zone of indecision into consideration, but you always do it worst case. So add it onto the T2 ratehr than take it away – so you should go above, not below. Does that make sense?
Kassy
Hi Kassy
Great article and valuable comments from food industry colleagues. I have a question regarding tolerance in g or percentage when you verify online checkweighers as part of routine/ retailers requirements i.e. start/ middle/ end of each production run etc., where you put nominal weight on a calibrated scale and then check it on checkweighers in dynamic mode/ in operation- what should be the tolerance in +/-g or %age?
We are ware of zones in indecision and standard deviation to check accuracy of scales during annual calibration. This question is about tolerance during routine verification using nominal weight and how low the T2 test pack should be from the actual T2 weight. Is there any industry best practice around this?
Thanks
Hi,
If you have an in line flow meter set to only allow product through that have reached the desired target, is it acceptable to use a check weigher to verify the flow meter is accurate at the start of a run or do you still have to abide by the sampling rate you outlined.
The reason I ask is the units being produced are 45kg and we do not have an in line check weigher so to weigh 50 units would be quite cumbersome.
Hi Damien,
Average weight doesn’t apply to units more than 25kg. So you don’t need to do anything!
Kassy
Hi Kassy,
Thanks for the reply. From the documentation I can fid for Irish legislation it states weights between 5g and 55kg are deems a package.
Not sure if this has been updated as the document is from 1981 but would the flow meter check be valid in this case?
Thanks
Damien
Hi Kassy,
We are producing product e 300g, tare is 20 g, according to above calculation t2=282g, therefore 20g of tare is automatically subtracted by the in line checkweigher. If t2 is solely net weight of product, is testing 280g of a pack(product+tare) a correct weight set to challenge the checkweigher? In other words should t2 test pack weigh 282g+ tare 20g or just 282g(includes tare).
Thank you
Sam
Hi Sam
You need to remove the tare from the T2. So 282 + 20g.
Thanks
Kassy
Hi Kassy,
Regarding the no more than 2.5% -T1’s, is it pertaining to the batch per hour ( eg. 10000 output ) or to the 50 samples per hour?
Thanks,
Armie
Hi Armie, It’s for the batch. Kassy
The entire batch.
Hi Kassy,
Probably this was mentioned somewhere in the comments, but I have a query regarding manual checks and use of checkweighers.
Do I need to carry a manual weight check if I use a checkweigher that records the batch details and provides print out or information is recorded on a server? Of course this will be still calibrated and reject arm verified etc. Thank you!
Hi Petya
I’m not sure I totally understand your question. Do you mean – a manual weight check of the scale for accuracy? Or do you mean a manual weight check of the product? The answer to the first would be yes and the answer to the second would be no! I hope that helps whichever question/ answer it is 🙂
Kassy
Hi Kassy,
Apologies for the confusion. My question was related to the manual weigh check of the product, so your answer is very helpful.
Thanks
Petya
Hi Kassy,
Very clear article!
But still one question 😉
Can you give a reference to the ‘official’ text where the max of 2.5% T1 comes from?
I don’t find it in EU law. French customers are referring to their national law, and in there a max of 2% is mentioned.
thanks!
Sonja
Hi Kassy,
That is such an understandable explanation, thank you.
I’ve got a question.
Before each of the production run we need to verify the checkweigher (for each product)
Is it a requirement to use both T1 and T2 test packs to verify the checkweigher?
If I set up my checkweigher to reject anything below T1 shall I verify it with both T1 and T2 test packs?
Hope the question makes sense, thank you!
Hi Vika
If you check that it rejects T1, then you’re essentially checking T2 at the same time. So I’d just do T1.
Thanks
Kassy
Hi Kassy,
Can you clarify this please. How should a business weight code a pack that isn’t checkweighed, but the pre-packed components are?
e.g. 4 packs each of 100g are produced using the average weight system. These are packed into a sales unit (carton). Is it right to declare as 400g (4 x 100 g e)?
Hi
It’s typical to say 400g e – but you could also put (4 x 100g) as well. The key is not to be misleading, neither of which are.
Kassy
Hi Kassy,
Like the others above, this is a great article and very concisely written in plain English, and easy to follow. However, I have a query about multi-packs or packs containing multiple parts (each is packed individually) then collated in a carton (sales unit). e.g. a sales unit has 4 parts each of which is weighed at packing to average of 100g e. There is no weight control on the sales unit. Is it right to declare this as 400g (4 x 100g e )? Or should we be considering something different?
Hello there,
Could you explain where do we conduct -T1 test to verify that a checkweigher is working correctly? Also is it a legal requirement to conduct -T1 test?
Mostly -T2 is used in food manufacturing as a requirement to check that checkweigher are working accurately.
Many thanks,
Hi Shahzada
I’m not sure I’m following your question exactly. You have to carry out checks of your scales to prove they’re accurate. But you wouldn’t necessarily do this with -T1 or -T2 weights, unless you have an inline checkweigher. The key is to check that the scale is accurate for the range of weights you are putting on it – highest to lowest.
Kassy
Hi Shahzada,
I had exactly the same question and I’ve got an answer. It is only required by M&S to conduct T1 test to verify checkweigher. So if you do not supply to M&S – you are perfectly fine to test checkweigher only against T2
Hope it helps
Hi Vika,
Would you please mind explaining how you are verifying the T1 test for M&S?
Thanks
Hi Vika
Do you mean validating the test, or doing the verification (i.e how to do the test)?
Kassy
Hi and thanks for this interesting article.
A quick question, we are working with small meat producers in the UK, preparing cuts of meat rather than processed food.
Do these products have to be average weight, minimum weight or is this outside the regulation given the small ‘batches’ – there are only so many steaks you can produce from one cow!.
Also, post Brexit, is the ‘e’ symbol still compulsory for selling at average weights (e.g. mince, where the notion of batch is more relevant) – how do you prove that you were working at average weights or minimum weight?
Many thanks!
Hi Patrick
I would imagine that you’re labelling the product with the actual weight rather than average weight? In which case you wouldn’t have the e mark on the pack and average weights wouldn’t apply?
Kassy
Hi Kassy,
My question mostly surrounds understanding what a batch is. I work in the malting sector. We have a packing line for 25kg sacks. We are looking at putting an inline checkweigh in to reduce give away by going from min to ave. Our products are mostly the same, barley that has been steeped, germinated and then either kilned or roasted. The end process is where the product changes character. Roasting or kilning at different temps imparts different colour and taste characteristics. If we are running all day on the same pack sizes but changing between these different types of malt, say doing 10 t of one then 30 t of another, are these all seperate batches or all one batch. We also mill some of our product so we may run say 20t of a product and do 10t whole and 10t milled; again would these be two separate batches or all the same batch. We do not produce more than 10000 packs in one day all is produced on one line in succession. We also produce products such as wheat and oats…. I imagine that these would be separate batches.
Hi Ian
It’s up to you what you deem to be a batch. But, it does need to be by pack size as a minimum.
Personally, I would separate them by physical form too – so milled or whole.
The quantity in the batch depends on the number of packs, not the total volume… So, no more than 10,000 packs.
Kassy
Sorry that this is a little belated… But thanks for the reply.
I had forgotten that i had posted this as the project got postponed.
I have another regarding the checkweigh.
Is it necessary to create T1 and T2 test pieces, such as pre weighed bags, and run them through the machine each day?
I suppose my questions are, does it need to be done? What should the frequency be? Is it necessary to use a pre weighed / underweight sample bag of our product or could i use some actual weights?
Do you have any advice for such a large pack size (25kg)?
OK,
For example I am working in bakery plant (ready to eat product), so is there any legal requirement that I have to follow what type( minimum or average) of weighing system.
Hope you get my point.
In the UK bakery products of more than 300 or 400g have to be average weight. If you have an e mark on the product then it must be average weight. If you’re selling the product in the EU it must have an e mark and therefore average weight. Other than that, it’s up to you.
Hi kassy,
Thanks a lot for making this to easy to understand.
Although I have a question regarding the legal requirement of following minimum weight or actual weight. Is there any categorisation to follow these.
Hi Zeeshan
I’m not sure I understand your question. Can you please try to put it into a question for me?
Kassy
Hello,
How would you challenge/verify the T1-T2 other than having a ‘print out’ from the checkweigher.
Hi Chloe
You would calibrate and verify the accuracy of the weighing scales. The verification of the T1 and T2 is someone sense checking the results and signing them off.
Thanks
Kassy
Hi Kassy,
Thanks for coming back soo quickly.
We have in line checkweighers that are calibrated annually and we verify the accuracy of our scales. However, our customer would like us to verify our T1-T2, (it is not enough to sign off the print out).
Do you have any suggestions as to how we would do this?
Hi Kassy,
Thanks a lot for your article.
There is one detail I still do not understand. What to do with product which is between T1 and T2.
You have presented example of product weighing 450g T1 is 436.5g and T2 is 423g. You can’t have any below T2 and less than 2.5% of T1 – so far clear.
But what you should do with product which is e.g. 430grams aka between T1 and T2?
Many thanks
Milan
Hi Milan
Any product that is between T1 and T2 weights are classed as T1, so you treat them as a T1.
I hope that helps.
Thanks
Kassy
What happens if you are working with weights of <5g? What rules apply for these?
Hi Stacy
The rules do not apply to packs of 5g or less. This means that you don’t have to comply with the 3 packers rules. You still have to target a 5g weight, and you can still apply the same rules generally, but you don’t have to comply with T1 and T2.
Kassy
Hi there,
I would like to know if we get a product that has a weight somewhere between T1 and T2, how is it classified?
E.g. T1 216g and T2 is 207g, and the product weight is 214g?
Thanks for your help!
Nick
Hi Nick
Thanks for your question.
Any weight between T1 and T2 is classed as T1.
Thanks
Kassy
Hi Kassy.
Just to say firstly I really find the Techni-k to be an excellent resources for those working in the food industry. I just have one query related to T1 checks; we have been asked by a customer how we perform our daily checks for T1 using test packs. Now I am sure it is very simple and straight forward but just wanted to make sure that I am not missing something important.
Any help would be appreciated.
Thanks 🙂
Hi Siobhan
That’s great to hear! Can I please ask first – do you have inline check weighers?
Kassy
Hello, if I have a batch of 10000 units to pass through the checkweighing machine and I have a T1% of 2.5% (25 units) but I am reworking around 1000 units with damaged packaging etc while in run, the total amount of accept packs would show 11000 units at the end of the run. Would this mean that I could potentially have too many T1% than legally allowed? Hope that makes sense. Thanks.
Hi John
It does make sense yes. Couple of thoughts – if you’re reworking them because they have damaged packaging, shouldn’t they have already been check weighed and therefore, in theory – they should be of the correct weight? Or are you saying the damage to the packaging changes the weight. If that’s the case, I would rework these under a derorgation, so that you can explain the corrective action.
I hope that helps.
Kassy
Yes the units have already passed through the checkweigher but they need to be repackaged in the same area as the checkweigher and resent back through the machine for metal detection (and checkweighing) also once they have been opened. These rework units are reworked instantly (within 5 minutes or so) throughout the run until all units have been completed.
The order of machines are:
Packaging – checkweigh/metal detector – labeling.
The problem I would have control is if damage to packaging is after the checkweigh/metal detector.
Hi John
Ok, so I would run this under a concession (derogation). Because they have already gone through the check weigher they have in theory, already been verified. Therefore, any T1s that you get should come from the product that has just been weighed for the first time.
Does that make sense?
Kassy
Dear all,
can you help out with a industrial product in Bigbags 500 and 600 kg? What is the tolerance here? Some customers have really low tolerance and we are asking ourselves how to deal with weight claims.
Thanks.
BR
Kate
Hi Kate
If they are industrial bags, they won’t need an e mark and therefore you don’t have to comply with average weights. 🙂
Kassy
HI Kassy, I’ve done a bit of extra research since my original post. For batches <100 you have to have a sampling rate of 100% so this makes it not worth it.
For actual calculations and sticking to the statistics etc the Marco (and I assume similar systems) do all of this for you and along with the sampling scales make compliance easy. It was just the cost/benefit of small runs vs savings in using the average weight rather than minimum that I was querying.
First off great article – thanks.
Does anyone do small runs and average weights and is it worth it or even do-able? For the area we can change to average weights, some batches are <50 units, most are 50-300 and the biggest 500. We packs lots of different 100g packs of produce currently to minimum weights. We use the Marco weighing system for context.
Hi, if you’re doing minimum weight and you can stick to that, I would highly recommend doing that. I’d only do average weight really if you have to – either for your customers or if you’re exporting product. Thanks, Kassy
Do any other manufacturers create their own T2 test packs to ensure their machinery is working correctly?
If so, how do you go about this?
Yes and I think your online checkweigher company may provide these too. It doesn’t need to be actual product, it just needs to be the right shape, size and – weight of course! I would recommend you speak to the manufacturer first, as they may have the easiest solution for you.
The 75g – 4.5g example is incorrect. The answer should be 70.5g.
Oh my goodness! Thank you – now corrected!
Hi Kassy,
Great article really helpful,
One question when I was looking at the EC Directive the table that works out the ‘tolerable negative error’ is divided into Class A and Class B? I work in a bakery and just wanted to check I’m going by the right category?
Thanks
What’s the view on products that change weight after packing. For example, if at point of pack, product batch complies with average weight legislation, but during distribution/ shelf life, net product weight changes, due to for example moisture loss, oil migration etc, and may lead to products on sale that fall outside the legislation. Does this have to be compensated for?. UK Legislation states at point of pack, WELMEC guidance (which TSO’s generally use) ‘recommends’ adherence throughout distribution.
My view would be that the pack should weigh the nominal weight declared on pack, at the point at which the customer buys it. However, legally you would have a defence if challenged, if you could prove that the packs complied with the 3 packers rules…
Thanks so much. Very easy to understand.
Hi! Thank you for this – it’s always good when we can add to these posts in this way. Thank you, Kassy
Hi Kassy,
We are a small microdistillery. Our production run is an average of around 1344 bottles at 350ml. Production takes around one day as the process is mostly manual. We do not have the ‘e’ mark on our bottles. We have 4 pneumatic filling heads. Currently we do 12 samples in all, 3 each for each filling head at the beginning of each run. Are we currently sampling enough? What would be an ideal sample plan for a production run of this size and what would be the best way to record our sampling?
Thank you.
Hi,
I think Mel’s helped you out. If you do not have the e mark on your bottles, you don’t have to run to average weight and therefore, you can pick the sample size that you think works for you best.
Thanks
Kassy
Hi Kassy,
Just read about your comments on Andria’s questions. But my understanding is you can choose to declare e mark or not if you pack to average weight. In other saying, if you don’t declare e mark it means you pack either to average weight or minimum weight.
As Andria is not check every pack to ensure weight is above nominal weight, this means she packs to average weight. Therefore three packers rules should still apply?
Appreciate if can share your opinion?
Many thanks.
Hi Heidi
Yes, you can choose if you want to put an e mark on or not. But if you do put the e mark on, then you have to apply average weight rules. I don’t understand this question “As Andria is not check every pack to ensure weight is above nominal weight, this means she packs to average weight. Therefore three packers rules should still apply?” can you please explain a little more?
Kassy
Hi Kassy,
Thanks for this information
We run a spirits bottling line @ 200 bottles per minute both with/ without the e-mark. ( 192,000 bottles a day)
What quantity of bottles should you check for fill level & how often should you do it?
Thanks for the help
Larry
Hi Larry,
We have a calculator in our process control documentation pack, that you can use to work out your sample size/by time. https://techni-k.co.uk/shop/edocs/pack-17-process-control-edocs/
Thanks
Kassy
Hi. I used to run a line making ready meals. On a minimum weight system,the average weight is the number of kilograms produced divided by the number of meals produced and the more meals produced let’s say 5000 meals and you altered the weight slightly then it would take time for the average weight to lower as compared to less meals produced.
Now on nominal weight program, it doesn’t follow that rule. …Lets say i produced 5000 meals and the number of kgs produced was 2,040,000 then the average weight would be 408 grams and should take a while for it to lower if you altered the weights less but it doesn’t ….the average weight changes every few minutes. ..just wondered why. Hope you get in touch
Kind regards
Matthew
Hi Matthew,
I’d be happy to help, but I’m not sure I understand what you’re asking. Are you saying that if you reduce the weight of the product, the average weight on your system should come down slowly and it doesn’t because it goes up and down every few minutes? If that’s the case, it would either mean that the weights of the product being checked varied massively (a wide enough weight range to change the average weight quickly), the batch size in the machine isn’t set up right or there’s something wrong with it!
Let me know if I’ve misunderstood 🙂
Thanks
Kassy
Hi Kassi
Is there a need for T1’s to be destroyed? I have procedures from a previous business that states T1s should be destroyed as well as T2. Was the technical team there being overly cautious?
Hi Laura,
You can’t have more than 2.5% T1’s in the batch. Therefore, if your monitoring shows (during production of the same batch) that 2.5% or more has been achieved, then you could in theory increase the dough weight at the divider and/or increase the batch size (i.e keep producing) to ensure that the perecentage of T1’s is reduced across the whole batch.
If this isn’t possible, then the right number of T1’s would need to be wasted to ensure that there were no more than 2.5% in the batch.
Does that make sense?
Thanks
Kassy
Hi Kassy,
Appreciate if you could help with where the 2.5% and 50 unit sample size are mentioned in the regulation.
I tried to find the reference of them but no luck.
Many thanks.
Please see this part of the article, under calculating sample size: Looking for references back to the legislation, to substantiate why 50 samples are needed? Please see clause 3.5 of The Weights and Measures (Packaged Goods) Regulations 2006.
Good explanation.
Thank you!
Hi Kassy
Thanks for the above – very good explanation.
One question I have is:
We are planning to pack 1.5 litres of product into saleable units and use the minimum weight as packaging does not have the average logo.
We will weigh every unit and ensure that these are all above our calculated minimum of 1536 ( product and package ) or will be rejected.
These will then be packed in cases of 6. If we record the weight of 1 individual unit every 15 minutes along with 1 case of 6 is that sufficient
to meet the requirement – potentially we will produce 5000 individual units every 24 hours.
Regards
Keith
Hi Keith,
You’ll be pleased to know – that if you’re not declaring your product as being packed to average weight (by adding the e Mark) then you don’t need to comply to the average weight regs. So you can define your own sampling plan, which means what you are suggesting would be fine.
Thanks
Kassy
Hi
From my previous comment I meant the below list in particular – is this more of a guideline or a recognised definition by governments?
DEFINING A BATCH
It’s important that we understand what ‘a batch’ is, as there are a few rules around what can be defined as a batch.
A batch must be:
•The same product (recipe and weight)
….
etc. etc.
Hi
Ok, I see. The list is my interpretation of how to define a batch – its not part of the legislation.
Thanks
Kassy
Your definition of what a batch is is very helpful – is this an official recognised list or not?
Hi Alex
When you ask ‘list’ can you explain what you mean exactly, as there is quite a lot of information listed on the post.
Thanks, Kassy
Hi Kassy
Is there any legislation / guidance on the give away weight?
Thank you
Renata
Hi Renata
If you follow the letter of the law, you shouldn’t ‘give away’ more than 2.5% T1 or any T2’s. But in practice, Trading Standards are not going to worry if you are giving the customer too much. Unless, that is, you are producing a product with a nutritional claim, where the excess product could mean you are not meeting the claim.
Thanks, Kassy
Hi Kassy
How would you recommend keeping records of compliance to packer rule 2 and 3 when using manual checks? If I weight 10 packs per hour manually, 1 pack between T1 and T2 would straight away give 10% when the limit is 2.5%.
Best regards
John
Hi John
Keeping records of compliance to each of the packers rules is a must, so that you can prove that the product that you have produced in the past was compliant. You would need to prove this to Trading Standards on an inspection. Remember, you 2.5% is across your batch. So, if you weigh 10 packs an hour, yes you are right 1 pack would be 10%, but if you did a run of 4 hours on the same batch, then 1 pack over the 4 hours would be 2.5%.
Thanks, Kassy
Hi Kassy,
Is the weight of the packaging taken into consideration when calculating the T1/T2? Or is it solely on the contents of the packaging?
Thank you in advance for your help
Karlie
Hi Karlie
It’s just the product weight, hope that helps!
Thanks
Easily understandable and well written. It’s amazing what the brain remembers.
Thanks, I am declaring 90 grams but as you correctly suspected it is the retail customer that is taking that case of 60 pieces and repackaging it as they deem appropriate lets say into 3-packs. What I want to do is validate that the process delivers pieces that after final in store bake off will be 90 grams or more as per my specification. It is the Retailer who will have to deal with weights and measures.
Thanks again
Hello Kassy when you say ” unit” do mean retail unit as in a can of beans, a package of bacon or a bottle of pop? . My application is bread , frozen dough to be exact and I am running a slow line packing 60 pieces into each case. Probably doing about 100 cases per hour. My strategy was to take a case (60 pieces) at start , middle and end of run and do a verification check prior to shipping. This means N=180.
My nominal or declare weight is 90 grams, what do you think?
Clem
Hi Clem,
A unit for average weight, is the unit where the weight is listed. For example, a retail pack would have the nominal weight listed on the pack, so one unit is one product. If you are supplying a box of frozen dough, where is the nominal weight listed? Is it on the box or on the specification for the individual frozen doughs. It’s the nominal weight that you have to be able to prove. Are you sure you are working to average weight on your frozen dough? Typically, product that goes for further processing would not need average weight, and so, you’d work to minimum weight.
The number of samples you need to take depends on how big the production run is. 60 pieces would be a minimum for a run under 10,000 units. How long would it take you to produce 10,000 units? This will obviously depend on whether a unit is a box, or whether there are 60 units in a box…
Let me know and I’ll try to help further.
Thanks
Kassy
Hi Kassy,
say your units “per run” is only 1000 – do you sample proportionately or do you still have to do 50? Also, what if you have a multi-head filler – does this factor into it? We have a range of fillers from 1 filling head to 48 filling heads?
Hi Alex,
I’m afraid you’d still need to do 50. If you have 48 filling heads, in theory you should be able to show that you’ve sampled them all – because each head could be filling differently. Perhaps one rotation of the filler – gives you 48 samples per run. Producing just a 1000 samples on a 48 head filler must have it’s problems, so I can appreciate this probably isn’t the answer you’d like 🙂
Thanks
Kassy
Very informative. thanks for the easy break
Very well explained. Thank you.
Thank you very much. Easy and comprehensive.
Thanks Athanasios! 🙂
Hi all,
Our technical team state that the zone of indecision for check-weighers needs to be checked on every product annually. We currently reject everything less than T1 so that they don’t have to worry about checking the ZOI. I would have thought that checking the ZOI for one product (say 200g) would be the same as checking another product of the same weight? Can somebody clarify please? Do you know if that is a legal requirement or just a recommendation?
Thanks
Richard
The ZOI is a measurement of the noise the belts and bearings make when the Check-weigh scale measure weight. This should be allowed for in the pack Tare. A problem from before the year 2000. The Ishida, Boekal, et al [these are checkweigh machine brands] weigh continuously, tare the whole weigh head, and compensate for pack being unstable as they cross the weigh head. They even compensate for 2 packs being on the weigh head at the same time in the programming. The program and weighing accuracy are checked by NWL for scales used in Trade. The issues that arise in operation: belt bearing becoming noisy needed repacking or photocell – reflector be marked so pack position not accurate.