Overfill is the extra product a cosmetics factory puts into every unit above the quantity on the label, and the brand pays, because bulk is bought by the kilogram while finished goods are counted by the unit. A target of 2 to 5 percent above the declared quantity is normal and partly required by law: in the EU, UK and US the average content of a batch must not fall below the declared amount. This guide covers skincare, haircare and colour cosmetics made by OEM and ODM factories for the EU, UK, US and ASEAN markets; figures are illustrative. First step: ask your factory in writing for the target fill weight and tolerance before you accept a unit price.
Key takeaways
- Overfill is how the law is met, not a factory mistake. Under the average system used in the EU and UK, and the two-part test used in the US, a batch whose average content sits exactly on the declared quantity fails about half the time, so every competent factory aims above it.
- The cost is small per unit and large per year. On a 50 g cream with bulk at USD 30 per kg, 2% overfill costs about USD 300 per 10,000 units; 10% costs about USD 1,500. The difference is the price of a well-set filling line.
- Fill tolerance and delivered-quantity tolerance are two different clauses. One governs how far each unit may sit from the target fill (typically within 1–2%); the other governs how many finished units you receive from a batch (commonly within 5–10% of the order), and overfill is one of the reasons the count comes in low.
- The filling line, not the mixing vessel, usually sets the real minimum run. A 3-hour changeover on an automatic line costs the same whether you fill 800 units or 8,000, which is why MOQ (minimum order quantity) quotes below about 2,000 units rarely go onto automatic equipment.
Who is this guide for?
This guide is for brand owners and product managers who buy finished cosmetics from an OEM (Original Equipment Manufacturer) or ODM (Original Design Manufacturer) and want to understand three numbers on a quote or batch record that are rarely explained: the target fill, the fill tolerance and the delivered quantity. It is most useful when you are comparing quotes, setting a product specification, or trying to work out why a batch of “4,000 units” arrived as 3,700. If you are still deciding what quantity to order at all, start with our explainer on what MOQ, lead time and turnkey mean in cosmetics manufacturing, then come back here for the arithmetic underneath the MOQ.
What is overfill in cosmetics manufacturing, and why does every factory do it?
Overfill is the planned difference between the quantity declared on the label (the nominal quantity) and the quantity the factory actually aims to put in each container (the target fill). If a serum is sold as 30 ml and the line is set to deliver 30.9 ml, the overfill is 0.9 ml, or 3%. The fill tolerance is a separate figure: it describes how far individual units are allowed to drift either side of that target, for example 30.9 ml ± 0.3 ml. Factories talk about both in grams rather than millilitres, because scales are faster and more repeatable than volume checks, and the two are converted using the product’s density measured at 20 °C.
Four things drive the overfill upward. The first is the law, covered in the next section: in every major market the average content of the batch must at least equal the declared quantity, so aiming exactly at the nominal guarantees that roughly half the units are short. The second is the filler itself. Most cosmetic creams and serums are dosed by piston or peristaltic fillers that meter volume, and a volume dose changes with viscosity, temperature and the amount of air carried into the bulk during mixing; the same piston stroke delivers less cream at 22 °C than at 35 °C. The third is the pack. Water-based products in polyethylene tubes and some PET bottles lose a measurable amount of water through the wall over a 24 to 36-month shelf life, and because trading-standards officers weigh packs on the shelf, not at the factory gate, the fill has to allow for that loss. The fourth is the user. A pump that leaves 2 to 4 ml at the bottom of a bottle does not change the legal net content, which is what is in the pack, but many brands add a “dispensable” margin on pumps and airless packs so that the consumer can actually get the declared amount out. Our overview of cosmetic packaging and filling options explains why that residual is larger in dip-tube pumps than in airless pump bottles.
Overfill is not the same as headspace. A jar sold as 50 ml is usually a 55 to 60 ml container, and the gap between the surface of the cream and the lid is deliberate: it stops the product touching the liner and allows for thermal expansion. A legally perfect 51.5 g fill in a 60 ml jar can therefore look mean to a customer who judges by eye, and brands sometimes buy a smaller jar or a deeper insert for this reason. Headspace is a packaging decision that affects appearance; overfill is a filling decision that affects legality and cost. The two are often confused in quotes, so ask which one a factory means when it says it “fills to the shoulder”.
A final definition matters for the rest of this article. Net content is the quantity of product in the pack, excluding the pack itself; it is what the declared quantity on the label describes and what regulators measure. The factory fills by gross weight on the line, subtracts the average tare (empty component) weight it recorded before the run, and compares the result with the target. If the tare weights in the component lot vary more than expected, for example a glass jar lot with a 3 g spread, the net content check becomes noisy and the factory will quietly raise the target fill to stay safe. That raise is paid for by you, which is why the component specification and the fill specification belong in the same conversation.
What do fill-tolerance rules require in the EU, UK, US and ASEAN?
In the EU and UK, prepacked cosmetics are controlled by the “average system”, which sets three rules for every batch; in the US, state inspectors apply a two-part test from NIST Handbook 133; and in ASEAN markets the declared net content on the label is checked under each country’s trade-measurement law. None of these regimes penalises a pack for containing too much, so the entire design problem is how little overfill you can run while still passing.
The EU rule comes from Directive 76/211/EEC on prepacked products, which the European Commission’s legal-metrology page on pre-packaging describes as a harmonised method for filling prepackages, recognisable by the ℮-mark placed next to the quantity (checked 20 October 2026). The UK carried the same system into the Weights and Measures (Packaged Goods) Regulations 2006, and the UK government’s guidance for packers and importers states the three packers’ rules in plain words: the contents of the packages must not be less on average than the nominal quantity; the proportion of packages short of the stated quantity by more than the tolerable negative error must be less than a specified level; and no package may be short by twice the tolerable negative error (checked 20 October 2026). The tolerable negative error, usually shortened to TNE, is a sliding scale that depends on the nominal quantity. The same scale appears in the international recommendation OIML R 87, Quantity of product in prepackages, which most non-EU trade-measurement authorities, including those in ASEAN, use as their reference.
Table 1 reproduces the scale for the pack sizes that matter in cosmetics. Read it as a floor, not a target: the second rule limits how many units may fall between the nominal and the TNE line, and the third rule forbids any unit at all below twice the TNE.
| Nominal quantity (g or ml) | Tolerable negative error | Example pack | Lowest acceptable single unit (nominal minus 2 × TNE) |
|---|---|---|---|
| 5 to 50 | 9% of nominal | 15 ml eye cream | 12.3 ml |
| 50 to 100 | 4.5 g or ml | 75 ml hand cream | 66 ml |
| 100 to 200 | 4.5% of nominal | 150 ml toner | 136.5 ml |
| 200 to 300 | 9 g or ml | 250 ml shampoo | 232 ml |
| 300 to 500 | 3% of nominal | 400 ml body lotion | 376 ml |
| 500 to 1,000 | 15 g or ml | 750 ml conditioner | 720 ml |
| 1,000 to 10,000 | 1.5% of nominal | 5 L salon backwash | 4,850 ml |
Two practical points follow from the table. First, the TNE is generous compared with the precision of a decent filler: a 50 ml serum may legally be 4.5 ml short in an occasional unit, yet a correctly set piston filler holds most units within 0.5 ml. The average rule, not the TNE, is therefore what sets the overfill on a modern line. Second, the ℮-mark is voluntary. It is a declaration by the packer that the batch was controlled under the average system and that records exist to prove it; packs without the mark still have to carry an accurate declared quantity, and in the UK the government guidance notes that the mark is not a requirement. If you want the mark, your factory must keep the per-batch check records that an inspector can ask to see, and the symbol itself must be printed at least 3 mm high next to the quantity. Our tutorial on setting up cosmetic labels for compliance covers where the quantity and the symbol sit on the pack.
The United States uses a different test with a similar effect. The declared net quantity of a cosmetic must appear on the principal display panel under 21 CFR 701.13, as set out in the FDA’s Cosmetics Labeling Guide (checked 20 October 2026). Whether the pack actually contains that quantity is checked by state and county weights-and-measures officials using NIST Handbook 133, Checking the Net Contents of Packaged Goods, whose current edition was adopted by the 109th National Conference on Weights and Measures (checked 20 October 2026). The handbook’s test has two parts: the average net content of the sample must be at least the labelled quantity, and no individual package may be short by more than the Maximum Allowable Variation, a figure that, like the TNE, scales with the pack size. Because US cosmetics are commonly labelled in both millilitres and fluid ounces, make sure the target fill satisfies the larger of the two declarations. A pack labelled “50 ml / 1.7 fl oz” has a US declaration equal to about 50.3 ml, so a line set to 50.5 ml is cutting it fine for the US while being comfortable for Europe.
In ASEAN markets the cosmetic rules themselves, harmonised under the ASEAN Cosmetic Directive as summarised by Singapore’s Health Sciences Authority, require the net content to be declared on the label but leave the question of whether the pack contains it to national weights-and-measures authorities, most of which follow OIML R 87 in substance. Table 2 sets the four regimes side by side using the same columns, so you can see what your factory must be able to show in each case.
| Market | Governing rule | What must be true of the batch | Who checks, and where | Evidence your factory should hold |
|---|---|---|---|---|
| EU | Directive 76/211/EEC (average system; ℮-mark voluntary) | Average at or above nominal; limited units below nominal minus TNE; none below nominal minus 2 × TNE | National metrology or market-surveillance authority, at the packer and at retail | Per-batch fill-check record with sample size, individual weights, mean and standard deviation; tare record; density record |
| UK | Weights and Measures (Packaged Goods) Regulations 2006 | Same three packers’ rules as the EU | Local Authority Trading Standards | Same as EU; suitable, checked equipment and records of checks are an explicit duty |
| US | 21 CFR 701.13 (declaration) and NIST Handbook 133 (verification) | Sample average at or above labelled quantity; no unit short by more than the Maximum Allowable Variation | State and county weights-and-measures officials, usually at retail or distribution | Fill-check record in both declared units; evidence the fl oz declaration is met, not only the ml |
| ASEAN | ASEAN Cosmetic Directive (labelling) plus national trade-measurement law, generally aligned with OIML R 87 | Declared net content present and accurate; average and individual limits per national law | National metrology or consumer-affairs enforcement | Fill-check record; label artwork showing net content in metric units |
A factory that cannot produce the records in the last column for a recent batch of someone else’s product is telling you something about how it will fill yours. Checking for that record is one of the quieter items in our checklist for auditing a cosmetics factory before you sign.
How much does overfill cost, and who pays for it?
Overfill costs the brand the price of the extra bulk, plus the finished units that the extra bulk would otherwise have become, and which of those two you notice depends on how the factory prices the job. Per unit the figure is small, usually a few US cents; across a year of reorders it is often the single largest avoidable cost on a mature product, because unlike a component price it is never negotiated.
Table 3 works the arithmetic for three typical products at four overfill levels. The bulk prices are illustrative mid-range figures for finished, preserved bulk delivered to the filling line, not quotes from any factory, and density is taken as 1.0 so that grams and millilitres are interchangeable.
| Overfill level | 30 ml serum, bulk at USD 60 per kg | 50 g face cream, bulk at USD 30 per kg | 250 ml shampoo, bulk at USD 6 per kg | Extra bulk per 10,000 units |
|---|---|---|---|---|
| 2% (a well-set automatic line) | USD 0.036 per unit; USD 360 per 10,000 | USD 0.030 per unit; USD 300 per 10,000 | USD 0.030 per unit; USD 300 per 10,000 | 6 kg, 10 kg, 50 kg |
| 4% (typical semi-automatic line) | USD 0.072; USD 720 | USD 0.060; USD 600 | USD 0.060; USD 600 | 12 kg, 20 kg, 100 kg |
| 6% (viscous or aerated product, older filler) | USD 0.108; USD 1,080 | USD 0.090; USD 900 | USD 0.090; USD 900 | 18 kg, 30 kg, 150 kg |
| 10% (hand fill, or a factory playing safe) | USD 0.180; USD 1,800 | USD 0.150; USD 1,500 | USD 0.150; USD 1,500 | 30 kg, 50 kg, 250 kg |
The per-unit numbers look trivial next to a USD 2 to 4 ex-works price, which is why brands ignore them. Seen from the other side they are not trivial: on the face cream, moving from 10% to 2% overfill saves USD 1,200 per 10,000 units, which on a brand selling 60,000 units a year is USD 7,200, roughly the cost of a full stability study or a season of paid sampling. Our breakdown of what it costs to manufacture a private-label skincare product shows bulk at around a quarter to a third of the ex-works unit cost for a mid-priced cream, so an 8-point swing in overfill moves the unit cost by about 2 to 3%, which is about the same as a typical annual price increase from a factory.
The second cost is the one that generates the most disputes, and it shows up as units rather than money. A factory makes bulk in batches of fixed size, then fills until the vessel is empty. Table 4 shows what happens to a 200 kg batch of the 50 g cream as the target fill rises, after allowing 3% of the batch for the product that stays on the vessel walls, in the pipework and in the filler at the end of the run.
| Target fill per unit | Overfill | Fillable bulk from 200 kg (after 3% hold-up) | Finished units | Shortfall against a “4,000-unit” order |
|---|---|---|---|---|
| 50.0 g (nominal, non-compliant in practice) | 0% | 194 kg | 3,880 | 120 units (3%) |
| 51.0 g | 2% | 194 kg | 3,804 | 196 units (4.9%) |
| 52.5 g | 5% | 194 kg | 3,695 | 305 units (7.6%) |
| 55.0 g | 10% | 194 kg | 3,527 | 473 units (11.8%) |
This is the arithmetic behind the “we ordered 4,000 and received 3,700” email. The factory did nothing wrong: 200 kg divided by 50 g is 4,000 only on paper. Most supply agreements therefore carry a delivered-quantity tolerance, commonly plus or minus 5 to 10% of the ordered quantity for a single-batch order, and the brand is invoiced for the units actually delivered. If your contract has no such clause, the factory will usually assume one anyway. Our review of what a good manufacturing contract looks like treats the clause as a standard term; the point here is that the tolerance you accept should be consistent with the overfill the factory has told you it runs. A factory quoting 2% overfill and asking for a 10% delivery tolerance is leaving itself room for something else.
Who pays depends on the quote structure, and you should ask which one you have. Where the factory quotes an all-in price per finished unit, it has already built an overfill assumption into the bulk cost per unit, and a factory with a well-controlled line can quote a little lower than one without; the overfill is invisible to you but still paid. Where bulk is priced per kilogram and filling per unit, as is common when the brand owns the formula, uses a separate bulk compounder, or orders a semi-finished product, the overfill is a line item you can see, and it is yours. In both cases the way to control it is the same: specify the target fill and tolerance rather than leaving them to the factory’s default, and ask for the mean fill of each batch to be reported on the certificate of analysis. Our tutorial on reading a cosmetic spec sheet and certificate of analysis shows where that figure should appear.
What are filling-line minimums, and how are they different from MOQ?
The MOQ you are quoted is normally the largest of three separate minimums: the smallest batch the mixing vessel can make, the smallest run that is worth setting up the filling line for, and the smallest quantity of each component you can buy; for most first orders the filling line is the binding one. Brands negotiate MOQ as if it were a single number set by policy. It is closer to three physical constraints, and each responds to a different argument.
The vessel minimum is the one most people have heard of. A mixing vessel needs a minimum working volume, often about a third to a half of its nominal capacity, for the agitator and homogeniser to work, which is why a 500 kg vessel cannot sensibly make 60 kg. We covered that physics in our explainer on scale-up in cosmetics manufacturing, and it is often the easiest minimum to get around, because many factories keep a 50 or 100 kg pilot vessel for exactly this purpose.
The line minimum is different, and it is almost entirely about changeover time. Before your product runs, the line is stripped, cleaned, sanitised, swabbed if the previous product was a different type, fitted with your change parts (nozzles, star wheels, tube holders, capping chucks), loaded with your components, and run until the fill weight is stable and signed off. On a semi-automatic line that takes one to two hours; on an automatic line with a checkweigher and a labeller it is commonly three to four hours, and on a tube line with a diameter change it can be longer. A line crew of four plus overhead costs a factory in the region of USD 100 to 200 per hour in most manufacturing countries, so a three-hour changeover costs USD 300 to 600 before a single saleable unit is made. Spread over 800 units that is USD 0.40 to 0.75 per unit; spread over 8,000 it is a few cents. That is the whole explanation for why factories will hand-fill 500 units, reluctantly put 2,000 on a semi-automatic line, and will not touch an automatic line below 5,000 to 10,000. Table 5 sets out the four common filling routes with the same columns for each; all ranges are what we observe in quotes and factory visits, not survey data, and individual factories vary widely.
| Filling route | Typical speed | Typical changeover | Practical minimum run | Fill accuracy usually held | Best fit |
|---|---|---|---|---|---|
| Hand fill on a bench scale, under GMP | 5 to 10 units per minute per operator | Under 1 hour | 200 to 500 units | Within 2 to 5% of target, operator-dependent | Samples, pilot and launch quantities, high-value small SKUs |
| Semi-automatic piston or peristaltic filler, 1 to 2 heads | 15 to 40 units per minute | 1 to 2 hours including cleaning | 1,000 to 2,000 units | Within 1 to 2% | First commercial runs of creams, serums and gels |
| Automatic in-line or rotary filler with checkweigher | 60 to 200+ units per minute | 3 to 4 hours including validation of fill weight | 5,000 to 10,000 units | Within 0.5 to 1% | Mass-market shampoo, body care, repeat orders |
| Automatic tube filler and sealer | 30 to 120 tubes per minute | 2 to 3 hours, longer with a diameter change | 3,000 to 5,000 tubes | Within 1% | Hand creams, masks, cleansers in laminate or PE tubes |
Notice the trade in the fifth column. The route that will accept your small order is also the route with the loosest fill accuracy, and loose accuracy forces higher overfill to keep the batch average safe. A 500-unit hand-filled launch run at 8% overfill is therefore paying twice: once in labour per unit and once in bulk. It is still often the right choice for a first run, because the alternative is a 5,000-unit commitment to a product that has not yet sold, and our analysis of launching with one hero product explains why stranded stock is the more expensive error. The point is to go in knowing which cost you are choosing.
The component minimum is the third constraint, and it is set by packaging suppliers rather than the factory. Stock bottles and jars typically ship in cartons or pallets of several hundred to several thousand, decorated components (screen printing, hot stamping) usually carry their own minimum of a few thousand pieces, and a custom colour or mould takes the figure into tens of thousands. A factory that quotes a 3,000-unit MOQ on a product that could physically be made and filled at 1,000 is often passing through a component minimum, and the negotiating move is to ask for the MOQ with a stock component instead. Our guide to the mistakes brands make when negotiating MOQ covers that conversation, and the factory directory on oemhallmark lists manufacturers by category and stated minimums so you can compare before you ask.
How should you specify fill weight, tolerance and delivered quantity?
Write the fill into the product specification as a target weight with a tolerance, state how it will be checked and recorded on every batch, and put the delivered-quantity tolerance and the cost of overfill into the supply agreement rather than leaving either to the factory’s default. The following eight items, in the order a factory will ask about them, are enough for most products.
- Declared quantity in both units, and the density that links them. State the nominal as 50 ml and as the equivalent mass at a measured density at 20 °C, for example 50 ml = 51.0 g at 1.02 g/ml. The factory fills and checks by weight; without an agreed density, a dispute about volume cannot be settled.
- Target fill and overfill. For example, target 52.0 g, which is 2% above the nominal mass. Ask the factory to justify anything above 3 to 4% for a pumpable product; viscous, aerated or very low-viscosity products may genuinely need more.
- Per-unit tolerance. For example, 52.0 g ± 0.5 g, with no unit below the nominal mass. This is tighter than the legal TNE on purpose; the legal limit is a backstop, not a control limit.
- Check method and frequency. How many units are weighed, when (at start-up, at a set interval, after any stoppage, at the end), on what scale, and against what tare. Automatic lines use an in-line checkweigher that weighs every unit; semi-automatic and hand lines rely on sampling, and the sampling plan is where loose practice hides.
- What goes on the certificate of analysis. At minimum, the mean fill, the lowest individual fill and the number of units checked for that batch. If the factory’s standard certificate does not carry fill data, add it; the testing checklist for a first batch treats fill weight as a release test alongside viscosity and pH.
- Which declaration governs for dual-unit labels. Where the label carries millilitres and fluid ounces, state which one the target fill must satisfy; the safe answer is the larger of the two.
- Whether the ℮-mark is used. If yes, the factory is taking on the record-keeping duty of the average system, and the label artwork must carry the symbol at the legal size. Our walkthrough of getting cosmetic packaging artwork print-ready lists it among the fixed elements the designer must not move or shrink.
- Delivered-quantity tolerance and the overfill cost basis. State the acceptable range of delivered units against the order (for example plus or minus 5% for orders above 5,000 units, plus or minus 10% below), confirm that invoicing is on units delivered, and state whether the bulk price per unit assumes the target fill in item 2 or the nominal. This matters most on reorders, where the quantities are larger and the fill should be tighter; our guide to reordering and scaling production suggests revisiting the overfill at the first reorder, once the factory has real line data.
Questions to ask the factory before you accept a quote
- What target fill and tolerance will you run for this product, and what did you run on the last three batches of a similar product? A factory with a checkweigher can answer in a minute.
- Which filling route will my order go on at this quantity, and at what quantity would it move to the next route?
- What is your changeover time on that line, and is it included in the unit price or charged as a set-up fee?
- Does your unit price assume the nominal fill or the target fill, and will you show the mean fill on the certificate of analysis?
- What delivered-quantity tolerance do you apply, and is it different for a first order and a reorder?
- How much of the batch do you lose as hold-up on this product, and is that already in the unit count you have quoted?
Mistakes to avoid
- Treating the MOQ as one number. Ask which of the three minimums is binding; a component minimum can be moved by changing the component, a line minimum by changing the route, a vessel minimum by asking for the pilot vessel.
- Specifying volume only. Without a density, “50 ml” is unenforceable on a weighing line. Agree the density at the sample stage; our guide on ordering a sample batch from a private-label factory suggests requesting it with the first approved sample.
- Accepting a delivery tolerance without knowing the overfill. The two numbers should be consistent; if they are not, ask what else the tolerance is covering.
- Choosing a jar for its look and then discovering the headspace. Check the brimful capacity of the component against the nominal fill before artwork is approved, and ask for a filled sample under normal light.
- Letting the fl oz declaration drift. A rounded-up fluid-ounce figure quietly raises the legal fill for the US; have the label reviewer confirm both declarations against the target.
- Never revisiting the overfill. First-run overfill is set conservatively because nobody has seen the product on the line. By the second or third batch there is data, and most factories will tighten the target if asked; almost none will do it unasked.
Frequently asked questions
What is a normal overfill percentage for cosmetics?
For pumpable creams, lotions, serums and shampoos on a properly set automatic or semi-automatic line, a target of about 2 to 4% above the declared quantity is typical. Hand-filled runs, very viscous or aerated products, and products in packs that lose water through the wall often run 5 to 10%. Ask the factory for the actual mean fill on recent batches rather than accepting a round number.
Is overfill required by law?
No law states an overfill percentage, but the EU, UK and US rules all require the average content of a batch to be at or above the declared quantity, and some overfill is the only way to meet that reliably with real filling equipment. The amount needed depends on how tightly the line controls each unit: better control, less overfill. The legal texts also cap how far individual units may fall below the declared quantity.
What is the ℮-mark, and do I need it?
The ℮-mark is a voluntary symbol used in the EU and UK that declares the pack was filled and checked under the average system of Directive 76/211/EEC or the UK Packaged Goods Regulations. It is not required to sell cosmetics, but retailers and distributors in Europe often expect it, and it allows free movement of the pack across EU markets. Using it commits your factory to keeping per-batch fill records that an inspector can ask to see.
Why did I receive fewer units than I ordered?
Usually because the order was planned as bulk weight divided by nominal fill, and the real fill was higher than nominal and part of the batch stayed in the vessel and pipework. A 200 kg batch at a 50 g nominal rarely yields more than about 3,700 to 3,800 units. Check whether your supply agreement has a delivered-quantity tolerance and whether you are invoiced on units delivered, and ask for the batch’s mean fill and hold-up to see where the difference went.
Can a factory fill below its MOQ by hand?
Many will, for a few hundred units, under the same GMP conditions as the line, usually at a higher unit price and with a wider fill tolerance. It is a legitimate way to launch or test a product, as long as the batch record, fill checks and release testing are the same as for a machine run. Ask whether the hand-filled batch will be acceptable as evidence for the markets you sell in and whether the overfill will be higher.
What is the difference between fill tolerance and delivered-quantity tolerance?
Fill tolerance is how far each individual unit may sit from the target fill, typically within 1 to 2% on a machine line, and it is a quality specification checked by weighing. Delivered-quantity tolerance is how far the number of finished units may vary from the number ordered, commonly plus or minus 5 to 10%, and it is a commercial term in the supply agreement. Both should appear in writing, and the second should be consistent with the first.
Sources and limitations
Regulatory points were checked on 20 October 2026 against the European Commission’s legal-metrology page on pre-packaging (Directive 76/211/EEC and the ℮-mark), the UK Weights and Measures (Packaged Goods) Regulations 2006 and the UK government’s guidance for packers and importers, the US FDA’s Cosmetics Labeling Guide (21 CFR 701.13), the current edition of NIST Handbook 133, the OIML R 87 recommendation on the quantity of product in prepackages, the European Commission’s cosmetics legislation page for Regulation (EC) No 1223/2009, and HSA Singapore’s ASEAN Cosmetic Directive page. The tolerable negative error scale in Table 1 is the published scale; the example packs and the lowest-acceptable-unit column are our arithmetic from it. The bulk prices, overfill levels, line speeds, changeover times, labour rates, hold-up percentage and delivered-quantity tolerances in Tables 3 to 5 and in the text are illustrative figures prepared by oemhallmark from quotes, batch records and factory visits we have seen; they are not survey data and no named factory is described. Real values depend on the product, the pack, the equipment and the country, and the US Maximum Allowable Variation tables and some national trade-measurement rules in ASEAN were not reproduced here. Confirm the current rules with the relevant authority for each market you sell in.
This article is general information for beauty brand owners and is not legal, metrological or regulatory advice. Confirm current requirements with the relevant authority and your own advisers before you finalise a product specification or supply agreement.