In Part 1 of this three-part series we discussed navigating the product labeling regulations in the United States. This article, Part 2, discusses product labeling in the European Union. Stay tuned for Part 3, where we'll take up labeling for import into Australia. Please note that these guides are intended for education use only, and are not meant to replace qualified legal advice.
If you've already read our overview of U.S. labeling laws, you'll be relieved to know that consumer product labeling is a bit easier on the other side of the pond. Although the European Economic Area is comprised of 31 different countries, regulations are generally set out and enforced by the EU at large, rather than on a country-by-country basis. And remember, like we said in Part 1:
"Whether you plan on importing into the US, Europe or Australia, labeling is a serious and strictly regulated matter that requires specific attention from the importer. Because Western labeling regulations are so much more complex than in China, it’s unwise to leave this important aspect of production entirely up to your supplier. After all, it’s the importers and sellers who are held legally responsible for improper labeling, not the overseas manufacturers!"
What you need to know
You may have noticed the "CE" symbol on many of the consumer products you use personally.
It stands for "Conformité Européene" (European Conformity), and signifies that the product is in compliance with the laws that regulate health, safety and environmental standards specific to its product class. If your product falls into any of the two-dozen categories listed by the U.K. government here, you'll be required to do the following:
- Asses the product to make sure it's in compliance with all applicable EU directives. General product safety directives can be found here. All European Union directives can be browsed and searched in the EUR-Lex database as well.
- Keep files with all technical data, test results, information about where and by whom it was manufactured and stored, and the relevant regulations themselves. You may be required to produce these files at any time by national authorities.
- Affix the logo: the official "CE" image and proportions, as well as minimum size requirements can be found here.
Most electrical devices also require the WEEE symbol, which signifies that the manufacturer or distributor has contributed to a fund to divert thrown-away electronic devices from landfills.
This FAQ posted by the European Commission is a good place to start learning about WEEE compliance.
Food products, cosmetics, chemicals, pharmaceuticals and products that are or contain hazardous materials are all subject to regulations other than the ones covered under the "CE" directives. If your product falls into any of these categories, check this list of resources from EUbusiness.com.
Remember, it's the responsibility of the importer or distributor, not the overseas manufacturer, to comply with label laws. If you expect your supplier in China to make and affix the required labels, make sure you've supplied them with exact specifications, and that this is included in your signed purchase agreement. Don't expect a Chinese manufacturer to have an intimate knowledge of EU labeling regulations!