METROLOGY AND QUALITY OF PREPACKAGED PRODUCT BATCHES: UNDERSTANDING THE DGCCRF REGULATIONS
Compliance rules and law regulation policy concept on virtual screen.

According to the French Committee of Weighing Industries (CoFIP), a prepackaged product is “a product […] packaged, outside the presence of the purchaser, in a package of any kind, covering it totally or partially in such a way that the quantity of product contained cannot be modified without opening or making a detectable change to the package, or a detectable change to the product”.

Thus, prepackages can be of variable or fixed weight. They are found in many industries, such as the chemical industry (household products, fertilizers, etc.), cosmetics (creams, perfumes, etc.), the food industry (meat, vegetables, dairy products, etc.), the pharmaceutical industry (medicines, etc.) or various industries such as construction (bags of cement, lime, etc.).

Pre-packaged products are subject to a strong regulation, sometimes complicated to understand. This regulation is based on the “Guide of good practices concerning the modalities of the internal metrological control to be carried out by the packers and importers of prepackaged products”, published by the General Directorate of Health and Safety and the General Directorate of Competition, Consumption and Fraud Control (DGCCRF).

Thus, we will see in this article how to apprehend the regulatory compliance with the DGCCRF guide for pre-packaged products.

WHAT REGULATIONS APPLY TO PREPACKAGED PRODUCTS?

The following legal texts will constitute the regulatory framework concerning the aspects of packaging and metrology of prepackaged products:

  • Directive n°76/211 of January 20, 1976 relating to the pre-packaging by mass or volume of certain prepackaged products
  • Decree n°78-166 of January 31, 1978 modified on the metrological control of certain prepackaged products
  • Order of October 20, 1978 modified for the application of the decree of 31/01/1978
  • WELMEC guides (6.4, 6.5 and 6.11)
  • AFNOR standard XF X06-030 (Guide for the implementation of Statistical Process Control)
  • AFNOR NF X06-031-1 standard and ISO 7870-2 and ISO 8258 standards on measurement control charts

WHAT ARE COMMON METROLOGY ISSUES AND HOW TO COMPLY WITH BATCHES TO AVOID NON-QUALITY OF PRE-PACKAGED PRODUCTS?

The main challenges of batch compliance with regulations lie in the correct use of metrology and control. Thus, the instruments used must ensure the conformity of batches and produce usable statistics to avoid non-conformities.

Metrology includes all measurement and interpretation techniques to guarantee the accuracy of data. In an industrial context, this requires a high level of traceability in order to control the manufacturing process.

Concerning prepackaged products, two main criteria are taken into account:

  • The average weight of the products in the batch must be greater than or equal to the nominal weight
  • The lot must contain less than 2% of defective lots. A batch is considered defective when the content is lower than the nominal quantity announced.

Obtaining the European marking “e” is related to the Directive n°76/211 of January 20, 1976 relating to the pre-packaging in mass or volume of certain products in pre-packages. This marking is not mandatory, but it is a guarantee of superior quality addressed to the final customer. It only concerns pre-packaged products between 5g and 10kg.

In order to obtain the marking, two types of controls are to be carried out within the framework of the metrology activities:

  • Continuous controls
  • Control by sampling according to the AFNOR NF X06-031-1 standard

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