Start with responsibility and intended use
Packers using the average system must control the batch against the three packers rules, use suitable equipment and retain required records. Filling-machine accuracy alone is not the complete quantity-control system. Define who supplies, integrates, installs, owns and uses the equipment, and record the final product, packaging, environment, operator tasks and maintenance interventions. A generic certificate or checklist cannot replace that project-specific scope.
Questions for the project team
- Is the product packed under the minimum system or average system?
- What nominal quantity and tolerable negative error apply?
- How will tare, density, sampling, verification and rejected packs be controlled?
- Is the checking equipment suitable for the quantity and production environment?
Documents and evidence to plan
The exact records depend on the project, but the following deliverables provide a practical starting structure:
- documented quantity-control method
- sampling and checking plan
- approved weighing or measuring equipment
- tare or density controls where relevant
- batch records and escalation rules
Apply the controls across the machinery lifecycle
Review the requirement during specification, supplier selection, design review, factory testing, installation, site acceptance, training, routine operation, cleaning, maintenance and modification. A change that appears small—such as a new solvent, bottle size, cap, guarding opening, extraction system or line speed—can alter the original risk or conformity basis.
Current official sources
Use the official sources below as the starting point and check their update dates when the project is reviewed.
- GOV.UK: packaged goods ↗
- GOV.UK: equipment and records ↗
- GOV.UK: packaged goods weights and measures regulations ↗
Common questions
What is the starting point for packaged goods average-system planning?
Packers using the average system must control the batch against the three packers rules, use suitable equipment and retain required records. Filling-machine accuracy alone is not the complete quantity-control system.
Does a conformity mark replace the user risk assessment?
No. Supply obligations and duties for safe installation, use, inspection, maintenance and workplace risk control are related but distinct.
Who should confirm the legal interpretation?
Use current official guidance and competent legal, safety, engineering, metrology or food-safety advice appropriate to the project and jurisdiction.
When should the assessment be reviewed?
Review it when equipment, product, packaging, formulation, process, controls, room layout, use or official requirements change, and after relevant incidents or findings.