What goes wrong

The capacity was read as the fill

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Our capacity was read as a fill volume Or as the declared net quantity So a correct label was assumed to settle it The fill was measured in a graduate And it was measured before shipping A translucent container was treated as clear Scale was ignored A liquid leaf was analyzed like a dry one And wet pet food was expected to be here Measure the fill in the shipped container References

Actual capacity, fill volume, and declared net quantity. None of them is the others.

Our capacity was read as a fill volume

It is the actual capacity of the container, which is the first term in the regulation's own definition of slack-fill. The fill is the second term and it is not ours.

Or as the declared net quantity

Which is a third number, usually a weight for a dry product. A correct net quantity statement does not answer the slack-fill question.

So a correct label was assumed to settle it

The two rules measure different things. A package can declare its contents accurately and still be filled as to be misleading.

The fill was measured in a graduate

Rather than in the container. Bulk density changes with the vessel and the fill method, and the regulation is about the vessel.

And it was measured before shipping

A dry product settles in transit, so the level a consumer sees is not the level at the filler. Settling is reason three and it has to be quantified rather than asserted.

A translucent container was treated as clear

8 of our 39 are natural polyethylene, which shows a level and does not allow the contents to be fully viewed. We publish a color and not a transmission figure.

Scale was ignored

Ten percent of a 950 mL jar is 95 mL and ten percent of a five gallon pail is nearly two litres. Five of our containers are at 18,927 mL.

A liquid leaf was analyzed like a dry one

Pet broth does not settle, so reason three is not available to it and the fill can be measured exactly.

And wet pet food was expected to be here

It is retorted or canned, and this catalog holds no can, no retort pouch and no pressure-rated container. One of five leaves is not served at all.

Measure the fill in the shipped container

After transit, in the container you will use. That is the number the subtraction needs and it is the only one we cannot supply.

References

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.

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. Of the 39 containers in this group, 22 are white, 8 natural, 7 clear, 1 blue and 1 black. So 32 of 39 do not allow a consumer to fully view the contents, which is the condition 21 CFR 100.100(a) attaches its slack-fill test to.

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.