This guide provides a summary of AQS regulations and how they affect manufacturers, packers and importers of pre-packaged goods.
The Average Quantity System (AQS) confirms the measurement or quantity of packaged goods being sold by measure (weight, volume, length, area or number).
Average Quantity System
The Average Quantity System (AQS) is an internationally agreed method of determining the size or quantity of pre-packed articles with a ‘constant nominal content’. This means it provides confirmation of the measurement or quantity of goods in the package, being sold by measure (weight, volume, length, area or number).
AQS is based on recommendations developed by the International Organization of Legal Metrology, (OIML R 79 Labelling Requirements in Pre-packages and OIML R 87 Quantity of Product in Pre-packages) and is intended for use in large-scale packaging plants where goods (e.g. breakfast cereals) are packed in the same quantity in batches of at least 100 packages.
Under Australia’s trade measurement legislation, manufacturers, packers and importers can use either:
- the average system
The average system
- The average content in a sample of pre-packaged articles of the same measurement cannot be less than the stated quantity marked on the packages.
- No pre-packaged article can have a shortfall greater than 5% of the stated quantity.
- The average net content in a sample from the production run of pre-packed articles cannot be less than the stated quantity marked on the packages.
- Allowance is made for a small number of packages to exceed a ‘tolerable deficiency’.
- None of the packages in the sample can have more than twice the prescribed tolerable deficiency.
AQS provides a 97.5% assurance that goods are the correct quantity within the prescribed tolerances. These tolerances are proportional to the quantity of product and related difficulty of accurate filling.
Note: Australian AQS requirements align fully with OIML recommendations and may differ from those of other countries that do not fully implement the OIML recommendations. Importers should be aware of these differences when importing products using AQS.
Average quantity system requirements
AQS and the average system operate concurrently and inspectors need to be able to identify which measurement system has been used.
If you choose to adopt AQS in your business, pre-packaged goods must be marked with the AQS e-mark. The shape, size and location of the e-mark must be:
- at least 3 mm high
- close in position to the stated quantity
- on the principal display panel
Australian manufactured pre-packed articles without an e-mark will be assessed for compliance with the average system and tested by trade measurement inspectors accordingly.
Packers must be aware that it is an offence to mark a package with a mark that is not an AQS e-mark but which is likely to give the impression of being one.
In the case of imported products with an e-mark, the inspector would not normally have access to the production records from the overseas manufacturer and may require the products to be tested at the warehouse.
Download AQS e-marks
Download these zip files for EPS and PDF versions:
‘Shortfall’ is a term used throughout the packaging sections of the national trade measurement legislation. It means the extent to which production or output falls short of expectation.
Where a package is tested in accordance with the national single article test procedure, a shortfall occurs where the measured quantity of a package’s contents falls short of the declared quantity marked on the package.
In other cases, the term refers to the failure of a group of packages of the same kind, when tested according to AQS or average system rules. While a large proportion of the packages in a group may be compliant, if a shortfall has occurred then the whole group of packages cannot be sold and the packer must take remedial action.
The AQS threshold is the inspection lot size from which the sample number of packages is selected. The sample will be inspected to decide if the lot conforms to AQS requirements. These are the requirements stipulated for an inspector to assess for compliance with regulation, as distinct from a testing program adopted by industry. These thresholds are given in Table 1.
|Inspection lot thresholds (number of packages)||Sample size requirements number of packages)||Number of packages in sample allowed to exceed tolerable deficiency|
|100 to 500||50||3|
|501 to 3200||80||5|
|3201 or more||125||7|
AQS sampling procedures
An inspector will select a sample from a lot of packages at random in accordance with accepted statistical sampling practice. If the sample selected from a lot of packages produced on a production line:
- is collected from the production line, the size of the batch from which the sample is collected must be equal to the maximum hourly output of the production line
- is not collected from the production line, where there is a maximum hourly output of:
- >10 000 packages, the size of the batch from which the sample is collected must be equal to the maximum hourly output of the production line
- ≤10 000 packages, the size of the batch from which the sample is collected must not be more than 10 000 packages
AQS test procedures
Testing for compliance with AQS involves testing against the following three rules:
- Rule 1 — the average contents of the packages in the sample must not be less than the declared quantity marked on the packages.
- Rule 2 — the number of ‘inadequate’ packages (that is, packages with a deficiency greater than the tolerable deficiency listed in Table 2) in the sample does not exceed the number listed in the third column 3 of Table 1.
- Rule 3 — there must be no inadequate packages with a deficiency more than twice the tolerable deficiency.
|Nominal quantity of product (Qn)||Tolerable deficiency (T) as a percentage of Qn||Tolerable deficiency (T) in g or mL*|
|Weight or volume||0 to 50 (g or mL)||9||—|
|50 to 100 (g or mL)||—||4.5|
|100 to 200 (g or mL)||4.5||—|
|200 to 300 (g or mL)||—||9|
|300 to 500 (g or mL)||3||—|
|500 to 1000 (g or mL)||—||15|
|1000 to 10,000 (g or mL)||1.5||—|
|10,000 to 15,000 (g or mL)||—||150|
|15,000 to 50,000 (g or Ml)||1||—|
|Length||Qn ≤ 5 m||No tolerable deficiency allowed|
|Qn > 5 m||2|
|Count||Qn ≤ 50 items||No tolerable deficiency allowed|
|Qn > 50 items||1#|
* T values are rounded up to the next: tenth of a g or mL for Qn ≤ 1 000 g or mL and whole g or mL for Qn > 1 000 g or mL.
# Compute the value of T by multiplying the nominal quantity by 1% and rounding the result up to the next whole number. The value may be larger than 1% due to the rounding but this is acceptable because whole items cannot be divided.
Examples of average quantity system testing
AQS tests for weight and volume
In Table 3, 3 500 packs of butter are identified as the inspection lot. Using Table 1, 125 packs of butter are chosen at random as the sample or threshold. Table 2 shows that a 500 g net package is allowed a T of 3% or 15 g. Therefore an inadequate package (T1 error) is allowed to contain between 485 g and 470 g.
A package weighing less than 470 g would be more than twice the tolerable deficiency and would fail rule 3 (T2 error). The reference test identifies two inadequate packages, no packages with a T2 error and an average net weight of 501 g. Therefore the packs of butter pass all three rules.
If potatoes had been chosen from Table 3, an inspection lot of 148 would have resulted in a sample or threshold size of 50 packages. Table 2 indicates a T of 1.5% (45 g) for a 3 kg bag. The reference test identifies no inadequate T1 packages and one inadequate T2 package. The inspection lot fails the reference test because of the one inadequate T2 package when none are permitted under rule 3.
|Product||Quantity||Lot size||Sample size||Sample average||Number of inadequate T1 packs||Number of inadequate T2 packs||Pass or fail|
|Potatoes||3 kg||148||50||3.1 kg||0||1||F|
AQS tests for number
Consider packages of oysters labelled ‘12 Pacific oysters’. There are a total of 150 packs which make up the inspection lot. Therefore, using Table 1, 50 packages must be chosen at random to form the sample.
Testing identifies that 49 out of 50 packages contain a dozen oysters and one package contains 11 oysters. This means the inspection lot fails because under Table 2 no deficiency is allowed.
A second example involves the inspection of mild steel washers. Each of the 500 packages contains 200 washers, according to their labels. Therefore the sample size is 50 packages chosen at random. Testing identifies five packages that contain 197 washers. Table 2 shows that the tolerable deficiency for packages containing more than 50 items is the nominal quantity (Qn) x 1% (T = 200 x 1%) or two items. Because the number of inadequate T1 packages permitted would be three (using Table 1) the lot fails the reference test.
The Average Quantity System and your business
The Average Quantity System (AQS) gives manufacturers and packers an opportunity to:
- reduce compliance costs associated with packing substantially above the stated quantity to avoid rogue packages being included in the sample
- align with international trading partners using the AQS e-mark — allowing for easier export
- use statistical sampling methods providing greater assurance that the packaged goods they sell and buy contain the quantity stated on the label
- have e-marked packaged goods to compete under the same rules as their international competitors in both domestic and international markets
- have greater confidence that exported products will not be rejected due to quantity issues
Packers and importers have a duty to carry out sufficient checks to ensure that all batches of pre-packaged goods meet the legislative requirements for correct measurement. The company does not need to follow the sampling requirements illustrated below for trade measurement inspectors, but it is strongly recommended to implement testing procedures and practices that provide a statistically robust and verifiable measure for compliance with these requirements.
When inspectors visit premises to inspect pre-packaged goods, they will be checking what policies and procedures are in place to ensure the articles on the premises are the correct measurement. Inspectors will request information about:
- controls to ensure the production process is operating correctly
- sampling and check-measuring plans
- training relating to check-measuring and whether it ensures that staff are competent to conduct these checks
- records being kept and their appropriateness, including actions taken when non-conforming packaged articles are detected
- equipment being used for check-measuring and its suitability for these checks
If inspectors decide that that they need to test products to assess the validity of these procedures, the testing will be performed at the manufacturing or packing site as outlined below.
All goods pre-packed for sale must be marked with the net measurement (e.g. the weight of the contents without the packaging material).