Product Label Reviews and Checks: A Complete Guide

Shipping incorrectly labelled products can result in recalls and fines. Ensuring that your products are correctly labelled is crucial. However, navigating the maze of complex, conditional and sometimes open-ended labelling requirements is a challenge even for those who have years of experience.

Label reviews, which are performed by companies like QIMA and TUV Rheinland, can help you reduce the risk of selling incorrectly labelled products.

What is a product label check or review?

A label check and review refers to an assessment of the contents of a product or packaging label file. In short, the purpose of a label review is to verify if the label conforms to the requirements of one or more applicable product regulations.

Checklist

Product label reviews are often performed as part of the product testing process to determine the following:

1. Is the product label correct?

2. Is the packaging label correct?

3. Is the format and placement correct?

4. Are all required compliance marks present?

5. Are warnings and safety instructions correct? (if any)

Below are two examples of label reviews for a fictional baby carrier sold in the European Union and the United States:

Example A: General Product Safety Regulation (EU)

Regulatory requirement	Label contents	Result
Type, batch or serial number or other element enabling the identification of the product	Baby Carrier 2025	1. Product name present 2. Batch or serial number missing
Manufacturer name, registered trade name or registered trade mark	Amsterdam Baby Carrier B.V.	Manufacturer name present
Manufacturer postal and electronic address	Kruisweg 305, Hoofddorp, 2132 NA, Netherlands	1. Postal address present 2. Electronic address missing
Labelling regarding age suitability for children	Age group: 1 to 3 years Max weight: 15 kgs	Age suitability present
Warnings and instructions for its safe use and disposal	–	Warnings and instructions for its safe use and disposal missing

Example B: CPSIA (USA)

Regulatory requirement	Label contents	Result
Name of the manufacturer or private labeler	Amsterdam Baby Carrier LLC	Company name present
Location (city/state) and date of manufacture	Production location: Istanbul, Turkey Date of production: 05 2025	Location present Date present
Cohort information, such as a batch or run number	–	Batch number missing
Manufacturer contact information (U.S. address and telephone number, toll-free if available)	–	Manufacturer contact information and phone number missing
Model name and number	Baby Carrier 2025	1. Product name present 2. Model number missing

Why are product label reviews necessary?

Most products are subject to labelling requirements in the United States, European Union, United Kingdom, Canada and other countries. Ensuring compliance requires that you first and foremost know which regulations apply to your product, which is not always obvious.

Labelling requirements can also be conditional and differ depending on the following factors:

1. Company type and supply chain

2. Product type

3. Age group

4. Risks

To make it even more complex, some labelling requirements are not clearly defined in legislation but open-ended and up to the manufacturer or importer to interpret. This is particularly challenging when it comes to warnings and safety instructions, which are now mandatory for many products in the EU and elsewhere.

Labelling requirements also change as existing product regulations are amended, and new regulations are introduced.

The stakes are high, as an incorrectly labelled product can result in fines and recalls. While you may be given the opportunity to re-label such products, doing so is often costly and time-consuming, if at all technically possible.

A third-party label review can help you reduce the risk of shipping products that are incorrectly labelled. Label reviews and checks also tend to be inexpensive.

Which products may require a label review?

I am not aware of any regulation, directive or standard that explicitly mandates third-party label reviews. However, any product subject to labelling requirements could also be sent for a label review.

The more complex the labelling requirements are, the more necessary it is to submit a label for review. Here are some examples of products that are often subject to label reviews:

• Toys
• Other children’s products
• Electronics
• Batteries
• Machinery
• Cosmetics

How much does a product label review cost?

Label reviews are often performed as part of the product testing procedure. Some companies do not list a separate cost for the label review at all. In the cases where the cost of the label review is specified, it tends to range between 30 and 50 USD per label check.

Keep in mind that each label check corresponds to a certain regulation or standard.

Products subject to multiple product regulations and standards may therefore require multiple label checks.

This is also the case if you sell your product in multiple countries, each having its own set of labelling requirements.

Example

• EU GPSR: 40 USD
• US CPSIA: 35 USD
• UK GPSR 2005: 40 USD
• Canada CCPSA: 45 USD

At what stage should the label review take place?

In general, I recommend that all label reviews be completed before you enter production. Label reviews taking place after production or even after a product is placed on the market can be done, but bear in mind that correcting labels at this stage can be costly.

How do we prepare before a label review?

You cannot get a label reviewed unless you have a labelled product or packaging ready. At a minimum, you will need a prototype or pre-production sample or batch sample.

You must also identify all relevant regulations and standards applicable to your product, and ensure that your label files conform to the labelling requirements.

How does the label review process work?

The testing company must first determine applicable regulations and standards. This is normally done as part of the assessment process to determine relevant safety and substance tests.

That said, I strongly recommend that you do your own research and identify relevant regulations and standards prior to contacting a lab. Bear in mind that you must first create the label before anything can be reviewed, which requires that you know which labelling requirements apply.

The review process is essentially a matter of comparing the label contents on the product and the packaging to the regulatory requirements.

Which companies provide product label review services?

I have seen label checks performed by the following companies:

• QIMA
• TUV Rheinland
• Bureau Veritas

I am certain that there are other testing and certification companies offering label checks and reviews.

You can also request a label review as a standalone service.

How long does a label review take?

Label reviews are often performed as part of the overall product testing procedure, which tends to take between 1 to 3 weeks.

What can happen if we don’t get a product label reviewed?

Then you run the risk of shipping incorrectly labelled products, which can be expensive to correct later.

What can happen if the label review fails?

In the event the label review fails, you should correct your labels and resubmit your product and packaging for a follow-up label review.