Putting product labelling to the test

September 13, 2019 //By Alastair McLaughlin
labelling
Testing goes beyond the physical assessment of products and extends to ensuring that the correct markings are applied in the correct manner, if it is to comply with market access requirements. In my experience, products often clear all the physical test requirements of a standard but fall down at the marking and instructions hurdle.

During assessment of a product, it often becomes clear that end users or service persons need to be warned of a hazard in the equipment. For example, where large capacitors could electrically shock a service engineer, or moving parts have enough force to injure an operator. In these cases, we need warning markings, also known as instructional safeguards. Aside from warnings, product legislation always requires traceability marking. Electrical products also need rating markings for their connection to mains, fuse characteristics, and so on.

Product labelling requirements can feel confusing, as identifying the correct information buried in the legislation relating to a particular product can be difficult. Thankfully, there are some basic rules that can be applied. In this article I look at marking requirements for manufacturers and importers, consider warning symbols, text and legibility, and highlight the need for on-product versus packaging labelling.

 

Identification and traceability

Identification labels are intended to enable market traceability – back to the manufacturer, importer, or distributor. You must mark your full company name, as well as any trade name you use. Manufacturers must also put their name on their products. The EU requires that if the manufacturer is based in the Common Market, the product need only be marked with their address, even if the actual production is taking place elsewhere. On the other hand, if the manufacturer is based outside the EU, the product must be marked with both the manufacturer’s and importer’s address – the importer being whoever brings the product into the EU. Lastly, the distributor must check the manufacturer and importer marked the product properly. There is an exception to this for retail chains’ own-branded products, as these need only be marked with the importer’s and distributor’s address, so that they can protect their sources from competition.

Your identification label must include the type, batch, serial or model number, or another element that allows identification. Whatever is used, it must link to the product’s Declaration of Conformity and technical files.

Country of Origin (COO) need not be marked on a product in the EU. However, fair trading laws require that there is no false impression of origin, and customs laws require that import declaration documents must state COO. Internationally, other laws apply – for example, in the USA and Canada, COO marking is required.


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