Article 3a of EC Directive 80/181, amended by Directive 1999/103/EC,
states that authorisation of non-metric indications alongside metric for
"economic, public health, public safety or administrative" purposes will cease
from 1 January 2010. Non-metric expressions are referred to by the European
Commission as "supplementary indications", and sometimes in the United States
as "dual labeling". dual
plain English, the European Commission says the expression of non-metric terms
will not be permitted for any economic, administrative, health or safety
purposes from January 2010, in any type of media, including the following:
packaging and labels
- manuals and
- books and
There are many practical problems arising from this ban, including
export, safety, health and consumer information matters. Although BWMA regards
these concerns as very important, we believe these points are most
appropriately made by the affected industries.
issue that BWMA raises is that the debate about supplementary indications is
seen by the EC as "metric versus non-metric". This perspective is misplaced,
since supplementary indications do not constitute an alternative to metric, but
Under Directive 80/181, only metric units are authorised for the
above purposes. Non-metric units ceased to be authorised in October 1995 and
have since existed outside the EU's legally recognised set of weights and
measures. Therefore, the perceived grounds for de-authorising them again in
2010 are anomalous, since units cannot be de-authorised twice. Supplementary
indications constitute additional information only, and do not form part of any
transaction or contract in EU weights and measures law.
Prevention of supplementary non-metric expression is therefore not
only unnecessary for accomplishing a single measurement system, but invasive,
since it prevents the private provision of information alongside the legal
requirement. BWMA believes that any perception of supplementary indications as
an alternative to metric should be replaced with an appreciation of the right
of parties to express information freely, in addition to the legal
BWMA is aware of two specific concerns expressed by the EC over
non-metric indications. One is that EU workers and consumers may not understand
them. This concern is already addressed by making metric mandatory; no further
solution is necessary.
Second, the EC has expressed concern that the US requires the use of
non-metric units, thereby requiring EU firms to display them also. However, US
law requires metric as well as US customary. This has been the case since 1994,
meaning that metric labelling is obligatory on both sides of the Atlantic.
Whether US law requires customary units alongside metric is not a matter that
should be of concern to the EC, since all countries have information
requirements (indications of content, date of production, etc). That the US
requires non-metric as well as metric should be regarded in the same light and
as an internal matter for its own citizens. Whether US units 'spill-over' into
the EU marketplace is immaterial since EU law does not recognise them for the
Eliminating the option of displaying supplementary indications is not
necessary to achieve the Commission's goal of metric-only use. This arrangement
already exists in law, and has done so since October 1995.
Preserving the option of supplementary indications ensures that
businesses and organisations retain the flexibility to express additional
information as required. It should not matter why information is provided; it
is the right to do so that should be respected.
Preserving the option also demonstrates awareness of the cultural
importance of traditional units. People should not be fearful of infringing a
law simply for referring to them alongside metric.
Click here for Word document of BWMA's submission to
|Businesses and health
& safety organisations that are concerned about this Directive should
contact BWMA. Email will ensure the quickest response.