The small package was assumed to get relief
On this page12
A scaling table was assumed
Because most type size rules have one. The cycling property quotes a table indexed by panel area and the hair care property a proportion of label space.
Here there is a floor
In no case may the letters or numbers be less than 1/16 inch in height. No band, no proportion, no small-package row.
Paragraph (b) was read as an exemption
It is a route to a rulemaking. The Commissioner may establish an alternative by regulation, on a petition submitted as an amendment to the section.
Which nobody does while laying out a label
So in practice the floor is the floor, and the container has to be chosen to accommodate it.
The bold requirement was left out of the measurement
Bold is wider than regular in almost every typeface, so a line measured in the regular weight understates what will print.
And the contrasting background was left out
A reserved block with margins takes more room than the line length, and type over artwork fails the contrast requirement anyway.
A published character width was looked for
We do not publish one, because it is a property of the typeface. A number from us would have been invented and laid out against.
Height was ignored in favor of circumference
49 of 106 containers here are wider than they are tall, and a wide short jar has plenty of circumference and almost no vertical room for a multi-line block.
And substantiation was treated as the slow route
It is the only route that removes the problem rather than accommodating it. The warning is triggered by an absence, not by a hazard.
And the container was chosen before the panel was planned
Which is the order that costs money. A mold is a long lead time and a layout is an afternoon, so the layout should test the container rather than the other way round.
Measure with your own face, on your own panel
Diameter and height are published on 97 and 104 of the 106 containers, so the panel is known before anything is ordered.