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Net Quantity Marking and Measurement in Malaysia: Do You Really Need the e-mark?
First, let's dispel a common misconception: the "℮" symbol (e-mark) you see on many imported goods is a mark of the EU's average-quantity system, not a legal requirement in Malaysia, and Malaysia does not recognise it as replacing the local quantity-marking obligation. In Malaysia, the net quantity marking of pre-packaged goods is overseen by the Ministry of Domestic Trade and Cost of Living (KPDN), with the legal source being the Trade Descriptions (Marking of Quantity for Pre-Packaged Goods) Order 2023 (effective 4 June 2024) made under the Trade Descriptions Act 2011, which replaces the earlier order that took effect on 1 September 2023; measurement accuracy is separately governed by the Weights and Measures Act 1972 and KPDN's metrology division. Food is additionally subject to the parallel net-quantity provisions of the Food Regulations 1985.
SI units and marking method
The new Order requires net quantity and net count to be marked in the International System of Units (SI); there are five common types of measurement:
| Measurement type | Usage | Applicable range (as cited by the Order) |
|---|---|---|
| Weight | Solids, powders | 5 g – 50 kg |
| Volume | Liquids | 5 ml – 50 L |
| Count | By piece | Per piece |
| Length | One-dimensional | End to end |
| Area | Two-dimensional | Flat |
The marking must be clearly legible and in a colour contrasting with the background; as for language, local goods use the national language (with the country-of-origin language added where necessary), while imported goods may use English. Notably, the new Order has one major change compared with the old version: the product name and manufacturer name and address are no longer mandated by this Order (these are handled instead by other regulations or category rules), and this Order focuses on "quantity" itself.
Minimum character height rules
The Order sets a minimum character height that increases with the magnitude, the detail most easily overlooked yet most often picked up in inspections:
| Net content (weight/volume) | Minimum character height |
|---|---|
| ≤ 50 g / 50 ml | 2 mm |
| > 50 – 200 g / ml | 3 mm |
| > 200 – 1000 g / ml | 4 mm |
| > 1000 g / ml | 6 mm |
For count, length and area quantity markings, the minimum character height is uniformly 2 mm. When designing small-capacity packaging (such as a 30 ml serum or a 50 g trial size), 2 mm may not seem large, but under a cramped layout it often cannot be achieved — this is a high-frequency rejection zone for samples and travel sets.
The concept of average quantity vs minimum quantity
The EU "℮" represents the average quantity system: the actual average content of a batch must not be less than the marked nominal quantity, and a small shortfall within a tolerance range is permitted. The logic behind this is statistical sampling. Malaysia's measurement management follows the Weights and Measures Act system, emphasising that the actual content must match the marking and must not be short or deceptive; therefore the focus is not on "whether to stamp ℮" but on whether your filling process can stably reach the marked net quantity. Rather than agonising over the EU symbol, it is better to get your fill tolerance, sampling inspection and tare correction right.
Imported vs local
For the same product, the difference between imported and local lies mainly in language: locally manufactured goods are marked in the national language (the country-of-origin language may be added), while imported goods may carry the quantity information in English. As for the accuracy of the quantity itself, the SI units and the character-height rules, imported and local are treated alike and are not relaxed just because a product is imported. Importers should not treat the ℮ on the original overseas label as a talisman; they must still confirm compliance with the units, character height and language of the Malaysian Order.
Parallel net-quantity provisions for food
Note that the quantity-marking order is not the only regulation reaching net quantity. Food is simultaneously governed by the Food Regulations 1985, whose net-quantity marking also requires presentation in metric units, clearly marked on the label; cosmetics, medicines and other categories each have their own authority's marking requirements. So for food businesses, one label must satisfy both KPDN's quantity-marking order (units, character height, contrast) and the overall labelling rules of the Food Regulations, with the two overlaid and the stricter prevailing. When designing, it is advisable to treat the "quantity field" as a cross-regulation intersection zone, aligning SI units, character-height thresholds and position all at once, to avoid attending to one at the expense of the other.
Common mistakes
- Thinking that printing ℮ means compliance: ℮ has no legal force in Malaysia and cannot replace local quantity marking.
- Insufficient character height: using 2 mm on large packaging when 4–6 mm is required.
- Using non-SI units: such as marking only oz or lb without metric.
- Quantity not matching the actual measurement: a shortfall is illegal and carries the highest risk.
- Insufficient contrast: light-coloured text printed on a light background, judged as unclear.
- Forgetting tare correction: mismarking the packaging weight as part of the net content.
Frequently asked questions (FAQ)
Q: Must a product carry the "℮" symbol? No. ℮ is an EU-system mark; Malaysia neither requires it nor recognises it as replacing local quantity marking; what you must satisfy is KPDN's quantity-marking order.
Q: Can net quantity be marked in ounces (oz) only? Not advisable. The Order requires marking in SI (metric); imperial units may at most be added and cannot replace metric.
Q: How large should the text be on a 30 ml sample? For net content ≤ 50 ml the minimum character height is 2 mm, and it must be clear and contrast with the background.
Q: Can imported goods keep the quantity field of the overseas label? Check it item by item. Units must be SI, the character height must meet the threshold, the language may be English, and the actual content must match the marking.
Q: What happens if the quantity is mismarked or short? It is a violation under the Trade Descriptions Act and may face enforcement action; a shortfall in content is the most serious category, so control it with process and sampling.
Self-check list
- [ ] Net quantity marked in SI (metric), with correct units
- [ ] Quantity text character height meets the magnitude threshold (2 / 3 / 4 / 6 mm)
- [ ] Font is clear and contrasts sufficiently with the background
- [ ] Language meets local (national language) or imported (English) requirements
- [ ] Actual fill quantity matches the marking, with tare correction done
- [ ] Not relying on the EU ℮ symbol as proof of compliance
Conclusion
In Malaysia, the key to net-quantity compliance is KPDN's Marking of Quantity Order 2023 plus the Weights and Measures Act: use the correct SI units, meet the 2–6 mm character-height threshold, maintain contrast with the background, and ensure the actual content is not short. The EU ℮ symbol is optional either way, but it has never been your basis for compliance.
Further reading: net quantity marking rules, Malaysia market-entry master roadmap, round-up of common label rejection reasons.
This article is compiled from official sources for reference only; actual compliance is subject to the latest text and review of the governing authority.
📚 Sources / official references
- SGS Safeguards:Malaysia Publishes New Order on Marking Quantity on Pre-Packaged Goods(2023 量標命令,2024-06-04 生效)
- Intertek:Malaysia Approved a New Order on Product Quantity Labelling(SI 單位、字高 2–6mm、重量 5g–50kg/容量 5ml–50L)
- Your Europe:The e-mark(歐盟 ℮ 符號定義,說明其非馬來西亞制度)
This article is compiled from the official sources above for reference only; actual compliance is subject to the authorities' latest regulations and review.
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