Six reasons

Reason six

On this page11

The provision Which closes a loop across this whole library So the label rules and the fill rules are connected It is phrased as an inability, not a preference Two limbs, and both have to fail The example is illustrative For a pet food container the label is substantial Those requirements are not federal And our shelf gives you the area to work with Design the panel, then justify the space References

Where some minimum package size is necessary to accommodate required food labeling.

The provision

Inability to increase level of fill or to further reduce the size of the package, with the example given as where some minimum package size is necessary to accommodate required food labeling.

Which closes a loop across this whole library

Five other properties here are about the room a required statement needs. This one says that needing the room is a lawful reason for the package to be larger than the food.

So the label rules and the fill rules are connected

A panel that must carry a certain amount of text at a certain size sets a minimum area, and a minimum area sets a minimum container.

It is phrased as an inability, not a preference

Inability to increase level of fill or to further reduce the size of the package. So the question is whether a smaller package was possible, not whether a larger one was convenient.

Two limbs, and both have to fail

Inability to increase the fill AND inability to further reduce the size. If the fill could simply be increased, the reason is not available.

The example is illustrative

Introduced with e.g., so required food labeling is one instance of a minimum package size and not the only one. The provision names discouraging pilfering and accommodating handling in similar terms elsewhere in its drafting.

For a pet food container the label is substantial

A guaranteed analysis, a nutritional adequacy statement, feeding directions and an ingredient list, none of which this property describes and all of which take area.

Those requirements are not federal

They come from state feed laws and the model regulations those laws adopt. Which does not change the slack-fill analysis and does change where you look them up.

And our shelf gives you the area to work with

Height and diameter are published, so the available wall area is calculable before anything is ordered.

Design the panel, then justify the space

Which is the order reason six implies. The space is defensible because the panel needed it, not the other way round.

References

21 CFR 100.100(a), the six functional reasons, verbatim: "(1) Protection of the contents of the package; (2) The requirements of the machines used for enclosing the contents in such package; (3) Unavoidable product settling during shipping and handling; (4) The need for the package to perform a specific function (e.g., where packaging plays a role in the preparation or consumption of a food); (5) The fact that the product consists of a food packaged in a reusable container where the container is part of the presentation of the food and has value which is both significant in proportion to the value of the product and independent of its function to hold the food; (6) Inability to increase level of fill or to further reduce the size of the package (e.g., where some minimum package size is necessary to accommodate required food labeling)". law.cornell.edu

The Davis Pack Supply catalog, measured 19 October 2026. 196 rows: 39 containers and 157 closures, and the largest-capacity shelf in this library. 950 to 18,927 mL with a median of 3,785, which is exactly one US gallon; all 37 containers with a capacity on file are over a quart, 21 are over a gallon and 5 are at five gallons. 32 HDPE and 7 PET, with no glass, polypropylene or metal. 22 white, 8 natural, 7 clear, 1 blue, 1 black. 20 tubs and pails, 10 jars, 9 bottles, and 12 of the 20 are pails. 9 plastic round pails, 5 PE wide mouth containers, 4 HDPE round tubs, 4 HDPE round tubs with handle, 4 plastic square grip containers, 3 HDPE single wall canisters, 2 tight head pails. 20 of the 39 have no neck finish recorded, which are the pails; 8 are at 110-400 and 5 at 120TT. Closures: 111 continuous thread polypropylene lids, 16 metal or aluminum CT caps, 10 dome lids, 7 plastic round pail lids, 6 round tub lids, 3 sealing discs. Liners: 46 heat induction seal, 22 F217, 22 No Liner, 21 unrecorded, 20 pressure sensitive, 10 foam, 8 Plastis standard, 8 PE foam.

Written from 21 CFR 100.100 and from the catalog as it stood on 19 October 2026. That section concerns misleading containers and is not a pet food labeling guide: the guaranteed analysis, nutritional adequacy statement, feeding directions and ingredient definitions that govern a pet food label come from state feed laws and the AAFCO model regulations, which are not federal and are not described here. Our capacity field is the actual capacity of the container, which is one of the two terms in the regulation's own definition of slack-fill; the other is a property of your product.