We have updated an article that was first published in 2013.

The new US President has said he wishes to renegotiate the Trans-Pacific Partnership (TPP), signed but not yet ratified. Does this mean the proposed EU-US trade agreement, known as the Transatlantic Trade and Investment Partnership (TTIP) is also dead? This agreement was supposed to remove regulatory barriers to trade, so it is likely that an opportunity to end the US ban on metric-only labelling of most packages has now been lost.

The problem is that the EU and the US have conflicting labelling requirements.

The EU’s Units of Measurement Directive requires metric labelling of packages, but following lobbying from both American and European exporters, an amendment in 2009 permitted a “supplementary indication” in non-metric units, provided that the supplementary indication was no more prominent than the legal, metric indication. Thus, the metric quantity is mandatory, but the non-metric is optional (and usually omitted except in the UK).

However, under the Fair Packaging and Labeling Act, the US requires that goods that are regulated at the federal level (i.e. most foodstuffs and some household goods) must be labelled with both metric and US Customary measurement units. (US Customary is similar to British “imperial” for mass (weight) and length, but differs for volume). Individual States may allow metric-only labelling for the minority of goods regulated at the State level, and all except New York have done so.

The one-sided result is that, as far as measurement units are concerned, US packaging and labelling is accepted in the EU, but EU packaging and labelling may not be accepted in the US. Consequently, any European exporter is faced with the choice of either (a) establishing a separate production line for export goods or (b) dual labelling all goods so that they can be distributed to either the home or the US market.

The reasoning behind the 2009 amendment to the EU Directive was that, if the amendment had not been agreed, exporters would have had to produce separate packaging for the two separate markets. It was claimed that this would be a significant additional business cost and hence a non-tariff barrier to trade, which would be illegal under the rules of the World Trade Organisation. Rather than insisting on an immediate reciprocal concession from the US, the European Commission decided, as a gesture of good will, to concede the point in the hope that the US Congress would relent and allow labelling that was legal in the EU to be imported into the US. So far, however, this has not happened as it is opposed by powerful industrial interests that are influential in Congress. The ostensible – and illogical – basis for their opposition, is that if metric-only labelling were allowed, manufacturers would have to change their package sizes to rounded metric quantities – e.g. 500 g rather than 1 pound (454 g), and this would entail major investment in packaging machinery. Since there would obviously be no such requirement, one can only conclude that the real basis of the opposition is protectionist.

The significance of all this for metric advocates on both sides of the Atlantic is this. If metric-only labelling were permitted in the US, then it would be possible for European manufacturers to dispense with supplementary indications completely. This would be particularly beneficial in the UK, where the ubiquitous presence of imperial units is a constant drag on adapting to metric units, as well as being a reminder that the process of metrication – begun 48 years ago – is still far from completion. In the US the increasing presence of metric-only labelling would provide an incentive for American consumers to visualise and familiarise themselves with the metric units that they may have touched on at school but have long since forgotten.

There are of course many other aspects of package labelling (such as specifying chemical contents and nutritional information) that may need to be resolved in any talks, but the crucial issue is whether “America first” means outright protectionism or adapting to survive and compete in the modern world.

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