Six reasons

Reason three

On this page13

The provision Which is the dry bulk reason Unavoidable is the limiting word So it is not a blanket allowance Which is a measurement, not an assumption Our capacity figure is the reference point Large containers settle more visibly A freeze dried product is the extreme case Protection and settling often co-exist And the closure affects it A removable pail lid is different Record which reason you are relying on References

Unavoidable product settling during shipping and handling.

The provision

Unavoidable product settling during shipping and handling. Three words doing the work: unavoidable, shipping, handling.

Which is the dry bulk reason

A kibble, a treat, a freeze dried piece or a powder all pack down in transit. The volume at the filler and the volume on the shelf are different.

Unavoidable is the limiting word

Settling that could be prevented by settling the product before closing, or by a different fill method, is not obviously unavoidable.

So it is not a blanket allowance

The reason covers the settling you cannot design out, which means knowing how much that is for your product.

Which is a measurement, not an assumption

Fill a container, ship it, and look at it. The difference between the two levels is the settling, and it is specific to the product and the route.

Our capacity figure is the reference point

Actual capacity, published on 37 of 39 containers. The settled volume is measured against it.

Large containers settle more visibly

Five of our containers are at 18,927 mL, and a few percent of settling in a five gallon pail is a large visible gap.

A freeze dried product is the extreme case

Very low bulk density, very fragile pieces, and substantial settling as the pieces break down. Which brings reason one into play alongside reason three.

Protection and settling often co-exist

Headspace that protects the pieces is reason one, and the space left after they settle is reason three. Both can be true of the same gap.

And the closure affects it

A container closed with a heat induction seal is sealed at the filler and settles in transit with no chance to top up. 46 of the 157 closures here carry one.

A removable pail lid is different

7 plastic round pail lids and 6 round tub lids, which could in principle be opened and topped up. Which is one of the things reason three asks whether you could have done.

Record which reason you are relying on

Because the list is exhaustive and the analysis is per product. A gap without a named reason is the thing the section is about.

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 regulation defines slack-fill as the difference between the actual capacity of a container and the volume of product contained therein. The Davis Pack Supply capacity field is the actual capacity of the container, measured in millilitres and published on 37 of the 39 containers in this group as at 19 October 2026. The volume of product is a property of the buyer's product and we publish no fill volume and no fill weight.

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.