Planning to import or export products to the European Union? In this guide, we explain what you must know about CE marking, WEEE, textiles labels, toy age warning, tracking ID, and other mandatory labeling requirements in Europe.
You will also learn which file formats to use when creating your label files and how to instruct your supplier.
The CE mark indicates that the product is compliant with all applicable ‘CE directives’, such as RoHS, EN 71 Toy Safety Directive and the Low Voltage Directive.
The CE mark is mandatory for all products falling within the scope of one such directive. Further, the CE mark should not be affixed on a product that is not covered by a ‘CE directive’.
- Android tablets
- Medical devices
In addition to the CE mark, the directives also require that the manufacturer or importer can provide a Declaration of Conformity (DoC), Technical file, and user manual.
The WEEE symbol indicates a separate collection of waste electronics. The WEEE mark is mandatory for most electronics, imported and sold within the European Union.
The WEEE symbol can be present on the product and the packaging.
- Laptop computers
- Video cameras
- Bluetooth speakers
- LED lights
- Electronic toys
- Laboratory equipment
EU Textiles Labeling
Clothing and other products containing a minimum of 80% by weight of textile fibers must be labeled with the correct fiber composition (e.g. 100% Cotton or 100% Polyester).
Further, the label must be permanent, which means it must either be attached to the clothing item or printed. A sticker is not enough.
- Children’s clothing
- Care labels (Recommended)
- Size (Recommended)
- Country of origin
Note: Some of the items listed above are required in individual EU member states. As such, it’s strongly recommended that you always include care labels and size.
EU Clothing & Textiles Ecolabel
The voluntary EU ecolabel for clothing and textile products can only be used if the product meets the following criteria:
- Limited use of substances harmful to health and environment
- Reduction in water and air pollution
- Colour resistance to perspiration, washing, wet and dry rubbing, and light exposure
Importers and manufacturers of toys must ensure that the product and the packaging carry the correct age warning labels, tracking ID, and contact details of the seller (e.g. manufacturer and importer).
You need a physical address in the EU, which could either be your office or a postbox. However, a website address is not sufficient. Note that the image above is outdated and only serves as an example.
Some products, including toys, must carry a tracking label to ensure that unsafe products can be recalled in an effective manner. A tracking label normally consists of the following parts:
- Purchase order date
- Manufacturing facility
- Country of origin
Food Contact Materials Labeling
Certain types of food contact materials, such as kitchen appliances and tools, must carry the glass and fork symbol represented above. However, it’s only needed if the products use as food contact material is not obvious to the end consumer.
For this reason, you don’t need this symbol in case you are manufacturing or importing ‘food contact materials’ used in daily life, such as cutlery, drinking glasses, and common kitchen appliances.
The EU Energy Labelling Framework Regulations apply to electronics, such as lighting products, kitchen appliances, electronic displays, computers, washing machines, and air conditioners. The Energy Label specifies device classification, and energy consumption – thereby incentivizing manufacturers to produce energy-efficient products.
You can create an Energy Label free of charge using the online Energy Label Generator.
- Lighting products
- Kitchen appliances
- Displays and TVs
- Computers and servers
- Washing machines and dryers
- Air conditioners and fans
The EU Ecolabel demonstrates that a certain product is made using more friendly processes, and materials. That said, unlike most other compliance marks in this article, the Ecolabel is voluntary.
Using the Ecolabel requires approval. In other words, you cannot use the Ecolabel based on self-certification. The specific criteria you must fulfill depends on the product. Below follows criteria for Textiles and Furniture:
1. The product shall not contain lead-based pigments.
2. Manufacturers shall perform colorfastness, washing, wet rubbing, dry rubbing tests on dyed yarn, final fabrics, or final products.
3. Manufactured elastane shall not contain organotin compounds
1. Manufactures shall not use restricted hazardous substances and mixtures such as lead and cadmium
2. Manufacturers shall use PVC-free plastic
3. Manufactures shall provide a minimum of 5 years of guarantee at no additional cost. Also, they shall make spare parts available to customers.
- Paper Products
- Electronic Displays
EU Directive Labels
In addition to the CE mark, some directives also require product labels to include additional information. This may include manufacturer or importer identity, address, SKU, user instructions, input voltage, or other information.
- Batch ID
- Contact details
- Model number
- Input/Output Voltage
- Safety Instructions
Packaging Recycling Labels
Product packaging recycling labels are used to indicate whether the material is recyclable, material types (e.g. plastic resin types), and the seller’s contribution to national packaging recycling schemes.
- The Green Dot
- Mobius Loop
- Plastic Resin Codes
The upper material, outer sole, and inside lining of the shoe must be correctly labeled. You can use written instructions to specify the materials or use a graphical representation of the shoe.
- Synthetic leather
- Coated leather
- Textile fiber
Amazon (EU) Product Labeling Requirements
While Amazon doesn’t set their own labeling requirements, they do require that all products sold on their platform are compliant with labeling and other compliance requirements in each respective country.
If you’re selling on Amazon.de, Amazon.co.uk, or Amazon.fr, you need to ensure that your product is labeled according to European Union product labeling requirements.
For example, products that fall within RoHS or the Low Voltage Directive must, therefore, be CE marked. Further, products should not carry labels that don’t apply. Amazon is strict about compliance and far more likely to take action against incorrectly or otherwise non-compliant products than the customs or other market surveillance authorities.
Amazon Label Check Example
Amazon may require product and packaging images as evidence supporting that your product is correctly labeled. Here is an example of such a request sent by the Amazon compliance team:
Hello from Amazon Selling Partner Support,
Thank you for your interest in selling [PRODUCT]. We have reviewed the information you provided and determined that it does not meet our requirements. To allow us to continue processing your application, please address the following issues:
Product Packaging Picture:
– The images provided do not meet the EU labelling guidelines, which state that address on the label must be that of an EU country. Please provide product images that meet this requirement.
– The images provided do not meet the labelling requirements, which state that any information added to the product packaging must be securely adhered and not easily removable. Please provide images that meet this requirement.
– The images provided do not meet the labelling requirements, which state that the label must contain a certification mark. Please provide images showing all sides of the product packaging including appropriate certification mark.
Please respond to this case and provide updated document(s) that remedy the issue(s) indicated above. You can respond to this case within the next 14 days or create a new application at a later time.
Why your product may need more than one label
It’s common that products are covered by more than one labeling requirement in Europe. Electronics, for example, must often carry the CE mark and the WEEE mark, in addition to directive specific labels.
Importers and manufacturers must take all applicable labeling requirements into consideration, rather than looking for labeling requirements that may apply specifically to that product.
In addition, labeling requirements also extend to the packaging and even user manuals.
Do I need a country of origin label when selling in the EU?
No, country of origin labeling is generally not required in the European Union. That said, many products sold in the European Union still carry a country of origin label (e.g. Made in China) as this is a requirement in many other countries, including the United States.
If you’re selling, or at least planning to sell, in the United States, you may as well get your product labeled according to US labeling requirements – in addition to those in the EU.
Further, although the country of origin is not required, you are not allowed to mislead consumers by claiming that the product is manufactured in another country than it actually is.
How do I know if my supplier labels the product correctly?
Manufacturers, at least outside the EU, are not compliance experts. They don’t keep track of labeling requirements in other countries and simply rely on their buyers to provide accurate label files.
As such, it’s essential that you create compliant label files and submit these to your supplier before entering production.
How do I create the label file?
You can use Adobe Illustrator, Photoshop or any other software. What matters is that you create a label file that is an accurate representation of the label you want to be printed on the product, packaging and user manual, if required.
Recommended file formats
- Print type
- Print position
How do I make sure my factory gets the label right?
I strongly recommend that you include a label check in your standard quality control checklist. Assuming you’re importing products from overseas, it’s only a matter of providing photocopies and design drawings showing the labels, dimensions, and where (e.g. product, packaging, and manual) the labels should be present.
The quality inspection agent can take photos of the labels, helping you decide whether the products are correctly labeled or not.
What should I do if my product is incorrectly labeled?
You need to instruct your supplier to relabel the product, assuming the items are still in their production facility. If not, you must either return or relabel the products.
However, it’s often impossible, or expensive, to relabel an incorrectly labeled product – so you better make sure that you provide label files and detailed documentation to your supplier to prevent such situations from occurring in the first place.
Can I label the product once it’s imported into Europe?
In general, a product must be correctly labeled ‘once it’s placed on the market’. This can be interpreted in different ways, which is why I recommend that you ensure that your product is correctly labeled before the product is imported into the EU.
It’s also more expensive to label products once inside the EU, compared to instructing your manufacturer to do it for you.
There are also cases in which the customs authorities have seized imported products for not being correctly labeled.
All in all, there’s no benefit in labeling the products once in Europe, assuming you are not manufacturing inside the EU.
Are barcodes required when selling in the EU?
Barcodes are not mandatory but strongly recommended if you intend to sell to retailers or online marketplaces.
Some of the companies that use and require GS1 barcodes include Amazon, Tesco, Sainsbury’s, John Lewis, WHSmith, Unilever, Ocado, Nestle, Google, Fruugo, La Redoute, New Egg, NHS, Walmart, Macy’s.