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Product labeling

6. June 2023 // Werner Schicks

Labeling products – as simple as this topic may seem at first glance, the actual product labeling on packaging, food, etc. is quite demanding. This is because the product labeling obligation serves to protect the consumer, ensure transparency during the purchase decision, product safety, smooth distribution, and efficient tracking. Required direct and indirect markings of products are based on numerous, sometimes industry-specific laws. What should be considered in the product labeling obligation of packaging and the product labeling of different foods? What are the legal requirements for self-declaration and which products, solutions and coding systems ensure the best result? The following article provides answers to these questions.

Contents

  1. Why is product labeling important?
  2. Marking procedure
  3. Industry-specific requirements
  4. Technologies in product labeling
  5. Mandatory and voluntary license plates
  6. Self-declaration and legal standards
  7. What must be printed on the labels?
  8. Possible legal consequences for errors in labeling
  9. Traceability and identification of products through labeling
  10. Conclusion
  11. Other questions

Why is product labeling important?

Whether product labeling food, product labeling packaging or mandatory information directly on the goods – a clear identification of the product is always provided. The information provided is primarily intended to ensure transparency and thus consumer protection. Take, for example, the issue of perishability and the important indication of the best-before date. Product labeling or mandatory information is also important when quality assurance, traceability and product liability issues need to be addressed. In addition, the marking of the goods helps to facilitate the entire commercial process of delivery and organization. For example, to inform the retailer of the correct price of the delivered goods. In summary: The product labeling obligation in the European Union (EU) ensures the necessary information and protection of the consumer. In economic and legal terms, mandatory self-declaration provides the basis for distribution and traceability.

Labeling products: What are the procedures?

All indications are carried by the labeled goods until they arrive at the retailer or subsequently at the end consumer. Required information to mark a product in accordance with the regulations is placed on the goods and packaging itself. In practice, the labeling industry distinguishes between two methods for serialized product labeling.

  • direct product labeling
  • Indirect product labeling

Direct labeling of products and packaging means that they are labeled directly. Thus, there is no need for labels or other carrier materials with this marking technology. Direct product labeling is considered inexpensive, fast and easy. But it has a very ambitious character, because the marking machine must be precisely aligned with the product in question. Even the smallest deviations result in illegible marking. High-quality solutions with digital reading processes are therefore required for direct marking. The technology used includes inkjet printers, roller stamps or modern, precise marking lasers.

Marked green package of a grated cheese pours cheese on a pasta dish in background.
Direct product labeling on a cheese package.

Indirect marking of products and packaging occurs when the goods are not suitable for the direct variant. In the comparatively costly indirect marking process, the required information is initially located on a carrier material. This carrier material, the majority of which is an adhesive label, is then applied to the product or packaging. Indirect product markings are thus detachable, suitable for almost any surface and offer a high level of marking security in compliance with the law. In addition, labels can be equipped with useful additional functions such as RFID technology: Radio chips have been doing their job in theft protection and copy protection for years. In the logistics industry, the chips are indispensable in tracking goods: RFID radio chips ensure that a product can be registered and tracked without direct visual contact.

Semi-automatic labeling system with fully electric dispensing function applies label to cardboard box
Indirect product marking with labels for coffee beans on a carton.

Industry-specific requirements

In addition to general labeling obligations, EU product labeling also includes industry-specific requirements. Depending on the industry, mandatory product labeling information for various consumer goods and durables varies in several aspects. Of course, the indication of the minimum shelf life for food is essential in order not to offer perishable goods. A best-before date, on the other hand, naturally has no relevance for new speakers. However, the following applies to all industries: Anyone who distributes physical and/or packaged goods must label their products in accordance with the law. Consequently, EU product labeling does not apply to digital-only offerings. This primarily involves downloads or streaming. If, on the other hand, digital information is located on physical surfaces such as a DVD, then the respective mandatory product labeling information is again valid.

The following industries have a high demand for marking solutions:

  • Food industry
  • Textile industry
  • Pharmaceutical industry
  • Consumer electronics
  • Equipment, tools, hardware
  • Cosmetics industry
  • Automotive industry

Because the products are either consumed by the consumer or worn directly on the body, the requirements for the food industry and textile sector are particularly high. Potential buyers must be able to make sense of their choice through the mandatory information on materials used and ingredients contained. In the specific case of a ready-made meal, for example, the product labeling or mandatory information prevents the consumption of possible allergens. With regard to foodstuffs, it should also be mentioned that the inks or stickers used in product labeling must meet hygienic or food law requirements.

Technologies in product labeling

Customers from the food industry, pharmaceutical industry, cosmetics industry, beverage industry and chemical industry (chemical products) as well as from pallet labeling require high-quality printing solutions for professional product labeling. Flexible, fast and intelligent-modern coding systems from Diagraph each meet the requirements for different production environments. At the same time, the precision and speed of the marking devices enable the effective printing process. The following technologies lay the foundation for product labeling that is as economical as it is qualitative:

TechnologyApplication
Continuous InkjetEstablished and widely used technology for small fonts at highest speeds and volumes for industrial product marking.
large character printerLarge logos, texts and barcodes. Suitable for absorbent packaging such as cartons or cardboard boxes.
Thermal InkjetThe printing technology ensures very high resolutions in a small space. It offers the ideal introduction to product labeling.
Thermal transfer printerChanging content on small and large areas with perfect print image.
Labeling systemsPrecise, robust and economical labeling is achieved by means of an electric drive.
Hot stampingAnalog and fast coding system for industry with up to 800 prints per minute.

Mandatory and voluntary license plates

Unfortunately, the assumption that a uniform labeling law for all products will facilitate orientation turns out to be false. Rather, the relevant regulations are distributed in different and industry-specific legislations. These regulations govern what must be obligatorily labeled in the respective industry sector.

Basically, a differentiation is made between mandatory and voluntary product labeling. In this context, the question is often asked what the differences are between mandatory product labeling information and voluntary labels? Product information, which is mandatory, must always be provided by manufacturers. In contrast, voluntary labels represent an optional declaration. Consequently, information that goes beyond the legal requirements does not have to be provided on the product or packaging. However, manufacturers are free to use useful or commercially relevant labels to promote sales of their products.

Voluntary labels include, for example, various quality seals, test marks, trademarks or organic labels. However, depending on the respective symbol, different strict or transparent standards/award criteria apply in order to be allowed to carry the respective symbol. On the one hand, there are low-threshold quality seals with very simple requirements and thus limited informative value. On the other hand, voluntary quality marks, which may be applied only after the decision of a competent jury or commission. Well-known voluntary marks and seals represent the GS mark or the Blue Angel. Some voluntary declarations signal qualitative, ethical, environmental or safety benefits from the customer’s perspective. The better known and more reputable the voluntary mark or quality seal, the greater the positive impact of the image on the opinion of potential consumers.

Self-declaration and legal standards

The self-declaration includes all legally indispensable product markings. If labeling beyond the legal requirements is provided by the manufacturer, then this is referred to as an optional self-declaration as outlined above. These are therefore “voluntary attachments” which go beyond the general labeling requirement. Voluntary claims thus tend to fall into the realm of advertising, while mandatory product labels implement legal norms and, consequently, legal frameworks. Often voluntary declarations signal advantages – they emphasize the high quality of a product.

Relevant guidelines or legal standards can be found in the following regulations, among others:

  • Product Safety Act (ProdSG)
  • 9th Ordinance to the ProdSG – CE Machinery Directive
  • Food Information Regulation
  • Medical Devices Act – CE Directive on Medical Devices
  • Cosmetics Regulation
  • Textile Labelling Ordinance
  • EMC Law – CE Directive on Electromagnetic Compatibility

What must be printed on the labels?

The most important information that must be printed on a product label includes the name or company and the address of the food business operator. This essential data is always used in case of complaints from consumers and/or authorities. For example, prepackaged foods carry the following labeling elements in summary:

  • Name and address of the food business operator.
  • Material designation: Designation of the foodstuff.
  • List of ingredients: This includes the ingredient classes, quantities of ingredients (QUID regulation) as well as the 14 most important substances or products that can trigger allergies or intolerances.
  • Net Quantity.
  • Best before date (BBD)/consumption date.
Packaging of Country Products Chilli Bites as an example of product labeling.
The most important information must not be missing, as this snack packaging shows.

So-called product-related labeling rules must also be observed. For example, the oval identity mark printed on packages of dairy and meat products. It indicates that the company that last handled or packed the goods monitors and complies with EU-wide hygiene standards. Product-related labeling rules also apply to fresh fish. In addition, there is an obligation to indicate the origin of pork, sheep, goat and poultry meat. Thus, in addition to the basic information described, sector-specific information must be implemented within the framework of the EU product labeling.

Possible legal consequences for errors in labeling

If legal requirements are not met, then these deficits quickly show up in business practice as well as in the form of legal consequences.

  • The traceability of batches is no longer given.
  • There is a threat of organizational problems in storage, delivery, distribution and sales.
  • The risk of accidents increases if the improperly labeled product is, for example, flammable or even dangerous for the customer to use.
  • Basically, missing information can diminish customer confidence and thus prevent a serious impression.
  • Regulatory authorities may initiate fines and regulatory proceedings.

There is always a risk of legal sanctions if mandatory information is missing from the product labeling. In case of detected violations, quite severe penalties can be imposed: If a company or some of its products do not meet the legal requirements of product labeling, then the responsible supervisory authorities are entitled to use high fines and regulatory proceedings as sanctions. The potential penalties are used to enforce compliance. The damage to a company’s image when such legal consequences are published by the press should not be underestimated.

Time and again, the competition also takes a close look at whether and how faultlessly other companies implement the EU’s product labeling. In the negative case, warnings will be issued against those companies that do not properly implement the self-declaration. This almost always results in a significant competitive disadvantage. In summary, product labeling of packaging as well as product labeling for food should always be done conscientiously and correctly to avoid adverse legal consequences.

Traceability and identification of products through labeling

A central function of product labeling in the EU is the traceability of goods. But why is traceability so important and how is it realized in practice? Early marking of products by means of symbols, codes and text provides a unique identifier. Whenever questions arise about the origin and properties of products, the available information can be used to initiate the necessary contact with the dealer or manufacturer. Anonymous goods with unknown hazard or hygiene status are not possible with serious product labeling and complete mandatory information. Thus, one advantage of the product labeling requirement is that the required information makes each product uniquely identifiable.

Marked label for Institut Virion-Serion GmbH Würzburg.
Traceability is mandatory in the pharmaceutical industry, for example.

Conclusion – Marking products

Those who want to mark products need efficient technologies, such as those offered by Diagraph’s various coding system and industrial printer offerings. On the one hand, robust, legible, high-quality and legally compliant product labeling facilitates the purchase decision. At the same time, labeling or printing on packaging and food serves to protect consumers. The main purpose of direct and indirect product labeling is therefore to make it clear what the food or the offered goods are made of and what properties they have. Based on the information, a well-founded and consequently correct purchase decision can be made. Likewise, mandatory product labeling information ensures the traceability of all batches. For manufacturers, the effort required to comply with the law should not be underestimated, because in addition to the general product labeling obligation, industry-specific requirements also apply.

Whether the topic is product labeling of the packaging or product labeling of the food – all manufacturers benefit from solutions that optimize the product labeling process not only in terms of quality, but also in terms of time and cost. For the future, it is clear that only coding systems that are powerful, economically efficient and can be integrated into production lines will ensure long-term competitiveness. Modern technologies and printers from Diagraph lay the foundation for this.

Numerous product identifiers exist, such as the batch number, barcodes or QR codes. In addition, the law requires that information such as lists of ingredients, ingredients or best-before dates must be clearly displayed on every container for food or other perishable goods.

Any questions?

What are the product labels?

Numerous product identifiers exist, such as the batch number, barcodes or QR codes. In addition, the law requires that information such as lists of ingredients, ingredients or best-before dates must be clearly displayed on every container for food or other perishable goods.

What does the term product labeling mean?

This term includes all (legally) relevant information for the clear identification of a product. This information must be applied legibly – e.g. by means of labels. Product labeling is used for transparency, consumer protection, traceability, goods organization and safety in handling products.

What are important mandatory food labels?

Foodstuffs on sale must carry information for better transparency, this is required by consumer protection. These include the date of the food’s shelf life and mandatory information about ingredients and potential allergens. However, it also depends on the food in question which mandatory information is required. Some basic information, including the shelf life and name of the food, is mandatory, while other declarations apply only to selected goods such as milk or meat.

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