Supplementary Indications revisited

Supplementary indications received a reprieve in 2007, and will now, subject to the Brexit deal negotiated with the EU, need to serve only the needs of the UK economy. Ronnie Cohen wonders where US influence is likely to lead us.

Supplementary indications are justified on the basis that they are necessary for trade with the United States and that if they were not permitted, a trade barrier would be created. This insistence on mutual acceptance of supplementary indications contrasts with the tolerance of different requirements for nutrition information and ingredients. Boxes of US and UK Pringles illustrate this inconsistency.


Common Supplementary Indications

Supplementary indications are additional non-metric units that can appear alongside metric units. These non-metric units are voluntary in the EU and mostly appear on products imported from the US. Dual labelling is still a legal requirement for goods regulated at federal level in the US under the Fair Packaging and Labelling Act.


As you can see from the image on the box of Pringles, the product weight is expressed in both ounces and grams. As a result of discussions between the European Commission and the US government in 2007, the EU agreed to extend the use of supplementary indications to support trade between Europe and the US.

Different Nutrition Information

However, let’s look at the differences in nutrition labelling for the UK and US markets. The differences reflect different legal requirements.

Pringles - US nutrition information
Pringles – US nutrition information

Pringles - UK nutrition information
Pringles – UK nutrition information

While there are some similarities between UK and US nutrition labelling, there are considerable differences. These differences are described here.

US nutrition information shows the following information:

  • Information in English and Spanish
  • Serving size in ounces and grams
  • Number of crisps per serving
  • Servings per container
  • Food energy in calories only
  • Food energy per serving only
  • Breakdown of total fats for saturated and trans fats
  • Amounts of cholesterol and sodium shown
  • Breakdown of total carbohydrates for dietary fibre and sugars
  • No salt figures given
  • Nutrition figures for amount per serving and % of daily value (based on a 2000 calorie diet)
  • Amount of protein shown
  • % daily values of Vitamin A, Vitamin C, calcium and iron
  • No allergen information is provided
  • Maximum daily intakes of total fat, saturated fat, cholesterol, sodium, total carbohydrates and dietary fibre are given for 2000 and 2500 calorie diets

UK nutrition information shows the following information:

  • Information in English only
  • Serving size in grams only
  • Number of crisps per serving
  • Servings per container
  • Food energy in kJ and calories
  • Food energy per 100 g and per serving
  • Breakdown of total fats for saturated fat only
  • No cholesterol or sodium figures given
  • Breakdown of total carbohydrates for fibre and protein
  • Amounts of salt shown
  • Nutrition figures for amount per serving and per 100 grams
  • No figures given for Vitamin A, Vitamin C, calcium and iron
  • Allergens are highlighted in capital letters (e.g. FIBRE)
  • No maximum daily intake information is provided

Different Ingredients Lists

Pringles - US ingredients list
Pringles – US ingredients list

Pringles - UK ingredients list
Pringles – UK ingredients list

Even though the UK and US ingredients lists look similar. there are some notable differences in the information provided. The British label provides allergen information (in this case, using capital letters), ingredients derived from genetically modified sources, E numbers (alongside descriptive names) and % of dried potatoes of the total contents. The American label provides none of this. Other differences in ingredients lists can be seen in the following table. Ingredients are listed in the order they appear on the labels.

US ingredients list UK ingredients list
  1. Dried Potatoes
  2. Vegetable Oil (contains one or more of the following: Corn Oil, Cottonseed Oil, Soybean Oil, and/or Sunflower Oil)
  3. Cornstarch
  4. Degerminated Yellow Corn Flour
  5. Rice Flour
  6. Maltodextrin
  7. Mono- and Diglycerides
  8. Contains 2% or less of salt
  9. Dextrose
  10. Monosodium Glutamate
  11. Whey
  12. Onion Powder
  13. Citric Acid
  14. Spices
  15. Natural and Artificial Flavours
  16. Autolysed Yeast Extract
  17. Tomato Powder
  18. Garlic Powder
  19. Torula Yeast
  20. Sugar
  21. Lactic Acid
  22. Sodium Diacetate
  23. Disodium Inosinate
  24. Disodium Guanylate
  25. Paprika Extract
  26. Wheat Dextrose
  1. Dried Potatoes (92.3%)
  2. Vegetable Oil (Corn* Oil, Cottonseed Oil, SOYA* bean Oil and Sunflower Oil)
  3. Corn* Starch
  4. Corn* Flour
  5. Rice Flour
  6. Maltodextrin
  7. Emulsifier: Mono- and diglycerides of fatty acids (E471)
  8. Salt
  9. Dextrose
  10. Flavour Enhancer: Monosodium Glutamate (E624), Disodium Inosinate (E631) and Disodium Guanylate (E627)
  11. Whey (MILK)
  12. Onion Powder
  13. Acidity Regulator: Citric Acid (E330), Lactic Acid (E270) and Sodium Diacetate (E262)
  14. Spice
  15. Natural and Artificial Flavouring
  16. Autolysed Yeast Extract
  17. Tomato Powder
  18. Garlic Powder
  19. Torula Yeast
  20. Sugar
  21. Paprika Extract
  22. WHEAT Dextrose

On the British label, whole words written in capitals warn about allergens and words marked with * indicate that the ingredient is derived from a genetically modified source.

I leave you to spot other differences in these lists.

Other Labelling Differences

Other differences in the labels including format and layout, spelling differences (e.g. for words such as “flavour”, etc.), importer information and best before date.

Supplementary Indications and Labelling Issues

A large number of differences in product labelling regulations exist between the United States and the European Union. The way that European importers solve this problem is to stick a label over the section with US nutrition and ingredients lists to conform with EU regulations. However, the British repeatedly argued that the abolition of supplementary indications would create a trade barrier between the US and the EU until they were permitted indefinitely in 2007. Why are potential differences in the use of supplementary indications seen as a trade barrier whereas other differences in labelling regulations are not? Surely, a sticker can overcome not just one problem, but both.

28 thoughts on “Supplementary Indications revisited”

  1. @Ronnie

    I agree there are differences. Some could be resolved by options the US allows:
    1. Spanish is optional, not required. Same for French (to accommodate Canada)
    2. Energy in kilojoules is allowed as supplemental, but Calories (kilocalories) are required.
    3. Nutrition values per 100 g or 100 mL is allowed as supplemental, but per US serving size is mandatory.
    4. We highlight allergens (WHEAT and DAIRY). I don’t believe we consider fiber to be an allergen.
    5. We do require sodium, rather than salt, and it includes any form of sodium present, not just sodium chloride.
    6. Low levels of vitamins and minerals don’t need to be declared, but can be. If you declare any, there is a panel that must be displayed even when the value is zero (I think that is changing in a recent update).

    The bigger problem is that we each have certain requirements, and a panel that covers both sets would be large and confusing. I would agree that high volume manufacturers consider it better to have a unique panel for markets with different requirements to keep it simple, and have efficient ways of doing so. That is less true for small manufacturers.

    We import food from a number of EU countries. They comply with our label laws and I am sure they are not the same labels they use at home. I like a certain French jam and I am pretty sure they don’t use an English-only label in their home market.


  2. Tailoring labels for local markets is not a big issue. It’s done all of the time. I don’t know how many American products end up in EU countries or elsewhere, but the labels always have to be tailored for language. In most cases if not all, the USC would be removed anyway.

    Canadian products more often than not even if in USC sizes have a metric only declaration on the label. So, it can be done and often with no complaints from the manufactures.

    What the big fear among American manufacturers is concerning metric only labels is that the next step will be a requirement to go to rounded metric sizing. In fact, decades ago when the issue first appeared a member of the FMI voiced his opposition to metric only by stating this very reason. Over time a list of nonsensical reasons were added:

    A number of American products come in sizes just shy of the nearest rounded metric amount.

    Can you imagine these labels showing 400 g? I’m sure the fills of these products exceed 400 g anyway and putting 400 g on the label would be no issue. But as far the companies filling the containers are concerned is is a big deal as they want to present a rounded USC product to the market and not metric.

    But then again maybe this isn’t an issue for every company and in every situation. We only hear from those that cry the loudest. Here is a catsup product in English with a rounded metric volume fill and a non-rounded mass fill. At least with this product we see their intended fill is by volume and the density of the product can be calculated. This would be nice for all products where practical, meaning if you need a dual declaration do mass and volume. That is more useful than adding ounces.


  3. One of the problems with labelling is “What do we mean by the product containing X grams?” Does it mean that each item is guarenteed to contain X grams or does it mean that the average contents of each item in the consignment is X grams? In earlier years UK law used the single item law (which is why so many tinned goods had a declared weight of 15.75 oz). EU regulations use the average contents law.

    Supplementary indicators bring in additional problems – how accurately do they have to reflect the contents? Must they always underestimate the quantity. The EU directive is silent in this respect.


  4. @Martin Vlietstra:

    Wouldn’t the presence (or absence) of the e-mark ℮ preempt this issue, even for exports outside the EU? The supplementary unit would tighten up the percentages, depending on how it is rounded from the primary, but still have the same meaning as when there is only one unit?


  5. @Martin,

    Assuming the supplemental indication is to satisfy US law, the larger of the two declarations (using conversions which are exact or accurate to at least 6 significant figures) must be true on an lot average basis, and no extreme underfills. I’m not sure our rules on sample and lot sizes, statistical test, intolerable underfills are exactly the same as yours, but the rules can be laid out. At worst, a little extra fill would ensure the most restrictive rule is met.


  6. @Daniel Jackson

    This whole business of turning back the clock on metrication will backfire if seriously attempted. As the UK tries to whip up a bunch of bilateral trade deals to replace being a member of the EU, it will quickly discover that the rest of the world (aside from the USA) has no use for Imperial.

    Let’s hope business good sense prevails including the need for the UK to present an international face to the world, which also means a metric face.


  7. I read recently that after we leave the EU we will no longer use metric measures. Is this true, and why in the 21st century is there talk of going backwards? So much for ‘Global Britain’.


  8. We’ve already seen many taking the BREXIT vote as de facto permission to ignore metrication rules and some in the tabloid press as well as at least one government minister (Leadsom) seeming to be doing their best to fuel this.

    While I don’t think industry as a whole will start to re-tool and switch to imperial, what we would likely see is some smaller businesses trying to appeal to the Daily Mail set and drop metric from their price lists and trying to belittle those of us who insist on using metric; this may even be fueled by some more vocal consumers stating “We’re no longer in Europe, we want to go back to British measures”. The knock-on effect may well be that businesses who do remain metric will wind up taking on the cost of mistakes and re-training.

    We’re probably moving off-topic here but I do think we need to be a lot more vocal about this, we could draw a parallel with the EU referendum and Trump’s election: many took the stance that “nobody would be that stupid.” Sadly that attitude is allowing the vocal minority to win the day and drag us all back into the 18th century.


  9. Alex,

    I don’t think there will be a noticeable change. Those shops that have resisted metrication all along will continue to do so. Those who have silently embraced it such as all industries will continue to do so. Remember that of those that voted for Brexit, the percentage was just barely over 50 % and those that voted to remain is just barely under 50 %. It was not an overwhelming victory for the Brexit camp. This also can imply that the the metric vs anti-metric camp may also be split down the middle.

    What will result is a divided economy. Those in the big cities and industry supporting metrication and continuing to use it defying those apposed, and those in small towns doing just the opposite. This will create a huge divide in the nation where one side will be angry at the other and constant fighting will go on for decades. Couple this with countries like Scotland and possibly Northern Ireland and Wales who oppose the English to deliberately boycott things imperial and make an effort to use metric even more just to spite the English.

    One can fight the Luddites by organising boycotts of towns and businesses that have made noises against metrication. Even to the point of organising protests in front of shops not using metric.


  10. @Alex Bailey
    Perhaps after Brexit, we should lobby for another referendum to inform politicians which measurement units the British population want use.


  11. @Charlie P

    Measurement regulations and legislation are not decided by referendum anywhere. I have seen the problems with the Alternative Vote and EU Membership referendums. Both sides were full of lies and propoganda by both sides in these referendums and relatively few facts given. It was hard to tell what was true and what was not. Hence the BBC had a Reality Check section on its website to help the public to assess claims made by both sides.

    For these reasons, I do not think that it would be a good idea to hold a referendum on measurement units. I suspect it would contain a lot of lies, propoganda, emotion, nostalgia and sentimentality and not many facts.

    While the completion of metrication may be unpopular in the short term, I can point out that no country that has completed its transition to the metric system has gone back to the old units. It was originally unpopular in France, the first country to adopt metric measures. Now the metric system is used all over the world. This would not be the case if all leaders just paid attention to opinion polls on this issue. If they did, there probably would be no metric system. Today, the benefits of the metric system are now taken for granted.


  12. @Charlie P

    What is stopping anyone now from using whatever units they want? You go into a shop and ask for a pound of something, the salesperson measures out your pound in grams, say 500 g. You get your “pound”, pay for it and depart. No one told you you they won’t serve you unless you say grams. So as far as you are concerned you were served the pound you asked for.


  13. @CharlieP

    If there were to be a referendum on units of measure, would everybody’s vote count the same? In particular, why should the vote of somebody who only weighs themselves once a year count the same as the vote of a medical practitioner who has to regularly log and collate patient’s weights, calculate averages etc?


  14. Hands up those who think that decimalisation would have happened if there was a referendum first.

    Not all issues can be decided by referenda. Some have to be decided on the basis of reason and practical necessity.


  15. @CharlieP

    The whole referrendum argument has, in the opinion of many people, been proven extremely flawed by the last two that have been held in this country. Those who actually bother to go out and vote are seemingly persuaded more by emotion and rhetoric rather than facts and reasoned thinking; the result is nothing more than an opinion poll, a snapshot of “feeling” on a single day. Often people don’t like something for no better reason than the fact that it hasn’t been properly explained to them, asking people to vote on that basis is never going to be a proper way to run a country and make a mockery of the word democracy.


  16. @Ronnie Cohen
    The Swiss had a weights and measures referendum, I’m not sure what the question was though. A referendum is a good way of settling an argument over an opinion where neither side are right or wrong, like the one about which measurement units are best. Even if it’s a close call, the losers tend to accept the majority decision and the sqabbling ends after a cooling down period. Generally, It is those who think their preference will lose who argue most vociferously against holding such a referendum.

    @Daniel Jackson
    It is not only the buying of goods (which I know can be done in imperial by those who prefer it that way) but it is the selling and pricing too, not to mention all other “official” uses of weights and measures.

    @Martin Vlietstra
    Are you possibly suggesting that “All animals are equal but some animals are more equal than others”?

    Any suggestions for the referendum question? How about something like “Should imperial and metric measurement units be given equal status in law”?


  17. @CharlieP – I was not suggesting that some animals/people are more equal than others, but rather that some were better informed than others.


  18. @Charlie P

    You recommend a referendum on what weights and measures should be used in the UK. You only need to look at the problems with recent referendums to find out what is wrong with deciding issues like weights and measures by referendum.

    I tried to find info about the Swiss referendum on weights and measures, albeit without success. However, Switzerland uses the metric system in any case. I disagree with you when you say that “a referendum is a good way of settling an argument over an opinion where neither side are right or wrong”. It did not work with last year’s EU membership referendum. The whole of government was completely unprepared for the vote in favour of Brexit when the result become known. Since then, there have been endless arguments about all kinds of issues related to Brexit. The most recent one was about guaranteeing the rights of EU citizens living in the UK.

    It was not without reason that former UK prime minister Clement Attlee described referendums as “a device of dictators and demagogues”. This quote was repeated by Margaret Thatcher in March 1975 when she criticised the in-out referendum on EU membership [or European Economic Community as it was then called] proposed by the Labour prime minister of the day, Harold Wilson. Referendums are unpredictable. As The Economist said in an article, “all too often they [the voters] have voted not on the issue itself but to punish unpopular governments”.

    You can read about that at

    Once again, I describe the problems with holding a referendum on weights and measures and, indeed, on other issues as well.


  19. @Daniel Jackson:

    Good points, but a minority of the Welsh can be equally swivel-eyed to their English counterparts—they just have different names for the units: milltir, cilogram, peint, etc. 😉 The number of fully committed metric opponents is actually quite small and much of their activity has the effect of converting some of the majority ambivalents into metric supporters, without proponents having to do or say anything!

    BTW (and strictly anecdotally), a few of my leave supporting neighbours have died this winter. Another few cold snaps could wipe out enough of them to ensure that it doesn't drag on for even one decade… In any case, the leave voters had several different—and frequently contradictory—aims, so are already split amongst themselves! By contrast, the remain voters were and are much more unified.

    @Martin Vlietstra:

    Presumably, corporate entities (private companies, governments, [international] NGOs, etc.) would have a vote which counted greater still? After all, they have a much larger investment in measurement equipment and a bigger stake in continuity of metrology over periods of time longer than a human lifespan.

    @Charlie P:

    Not quite. As [Mr.?] Nigel Farage once said: ‘a result like 48:52 would be “unfinished business” ’.


  20. Martin Vlietstra says @2017-03-03 at 21:22, WRT weighting each person’s vote in a referendum based on how much they use metric measures: “I was not suggesting that some animals/people are more equal than others, but rather that some were better informed than others.”

    Oh dear. How would you define “well informed”? Let me guess… those who support SI are well informed and those who don’t aren’t? Who would decide the weight of each person’s vote – the UKMA thought police?

    Would you have supported something similar for the Brexit referendum too – each pro-European got one vote and each Brexiteer got none, perhaps?

    I don’t think you understand democracy Martin, or referenda.


  21. @Ronnie Cohen 2017-03-07 at 13:38:

    It sounds like you are saying that referenda are a problem if the “wrong” result is returned. The Brexit result is only a problem to those who voted to stay in, it is a victory for those who wanted to leave.


  22. @Mark Williams

    You are quite right, corporate entities have a larger interest in units of measure than do the general population, but much of their work is unseen by the general population. In my view, the general population really wants a system of units of measure that cannot be exploited by one group to the detriment of another as was the case in France on the eve of the French Revolution where traders often had two measures going by the same name; one used for buying and another for selling.

    The problem with having a referendum on units of measure is the danger that the debate will be dominated by rabble-rousers who have no real interest in units of measure, but are using the debate to further their own agenda which is independent of units of measure.


  23. @Ronnie Cohen 2017-03-07 at 13:38:
    It sounds like you are saying that referenda are a problem if the “wrong” result is returned. The Brexit result is only a problem to those who voted to stay in, it is a victory for those who wanted to leave.


  24. @ Charlie P
    Re referendums:
    The Nation’s most popular newspaper is the Daily Mail or the Sun.
    The most popular TV show is The Great British Bakeoff or Game of Thrones.
    The most popular restaurant is Nandos or Wetherspoons.
    Don’t confuse what is popular with the public with what is best.


  25. Martin said:

    “You are quite right, corporate entities have a larger interest in units of measure than do the general population, but much of their work is unseen by the general population.”

    But, the reason in the past it was necessary to metricate the whole country not just business and industry and let the population go about their way using obsolete units is because industry needs people out of the population to produce their goods and services and they have to be assured the work force can work in metric. For every one person who can work in both as some claim there are millions who can’t.

    If metric is used in the marketplace as well as the factory and engineering office they add to the experience. Units used in the marketplace give the workforce a working knowledge so that work in the office and shop is not confusing.


  26. @Charlie P

    There have only ever been 3 national referenda in the UK. Two were on the issue of membership of the European Union in 1975 and 2016 and one was on the issue of the Alternative Vote voting system for general elections. The EU membership referenda were only held because of internal divisions within the governing party. The AV referendum was only held because of divisions between the Lib Dems and the Conservatives on electoral reform and was a Lib Dem condition for forming a coalition with the Conservatives.

    I wonder whether we would have a decimal currency today if that issue had been decided by referendum. Issues like this example are not normally decided by referendum. There are good reasons for that. You can find them in the following article in The Economist:

    This article describes several referenda that have gone “wrong” and the problems with referenda.

    I disagree that “the Brexit result is only a problem to those who voted to stay in”. Brexit has created problems for everyone that need to be resolved (e.g. EU laws after Brexit, trading relationship with the EU, soft Brexit versus hard Brexit, rights of EU nationals living in the UK, Britons’ rights in other EU member states, whether Parliament will get a meaningful vote on the final deal, the forthcoming negotiations, the threatened break-up of the UK, business uncertainty, a weak currency, higher inflation, postponed investment decisions, etc.). I could go on and on.

    After seeing what the AV and EU membership referendums were like in recent years, something I have described in previous comments here, I do not wish to see any more national referenda and that includes no referendum on the outcome of the UK negotiations withe the EU, whether the UK gets a good deal, a bad deal or no deal. Whether the issues to be decided relate to voting systems for elections, international treaties, new infrastructure projects or weights and measures regulations, we elect people to make decisions like these on our behalf. Such issues are not normally decided by referendum.


  27. @Charlie P:

    Not surprising, really, as the British (and especially the English) have little knowledge and scant practical experience of actual democracy.

    IME, anyone who is vociferously anti-metric in a pitch/ interview does not get offered the job. The most rabidly pro-imperial are usually pretty haphazard and error-prone in their measurements. So, a vote of zero for them and +1 for the pro-metric types seems about right. Also a vote of −1 for contrarians such as yourself, of course. :-/

    A leave referendum majority cannot possibly be a ‘problem’ solely for remain voters—because it's [generally] not their responsibility to devise a withdrawal plan, or make it work. Triumphalism such as yours might be gratifying now but has its limits in the longer term. As UKMA correctly predicted at the time, either result would ineluctably favour further metrication; a win–win.

    @Daniel Jackson:

    The point is that ‘the whole country’ also includes marketplaces & workplaces and not just human voters—but they are [at present] completely disenfranchised. If we're going to have a referendum on rolling back/ undoing metrication, it really ought to include all those with a stake in the outcome according to how much they would be effected by the result.


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