Overview of the different labeling and marking requirements, including any restrictive advertising or labeling practices and where to get more information.
There is a broad array of EU legislation pertaining to the marking, labeling, and packaging of products, with neither an “umbrella” law covering all goods nor any central directory containing information on marking, labeling, and packaging requirements. This overview is meant to provide the reader with a general introduction to the multitude of marking, labeling, and packaging requirements or marketing tools to be found in the EU CCG website at https://www.trade.gov/country-commercial-guides/eu-labelingmarking-requirements.
This text is focused primarily on the mandatory marks and labels seen most often on consumer products and packaging, which are typically related to public safety, health, and/or environmental concerns. It also includes a brief overview of a few mandatory packaging requirements, as well as more common voluntary marks and/or labels used in EU markets.
It is also important to distinguish between marks and labels. A mark is a symbol and/or pictogram that appears on a product or its respective packaging. These range in scope from signs of danger to indications of methods of proper recycling and disposal. The intention of such marks is to provide market surveillance authorities, importers, distributors, and end-users with information concerning safety, health, energy efficiency, and/or environmental issues relating to a product. Labels, on the other hand, appear in the form of written text or numerical statements, which may be required but are not necessarily universally recognizable. Labels typically indicate more specific information about a product, such as measurements, or an indication of materials that may be found in the product (such as in textiles or batteries).
Mandatory Marks & Labels
- Dangerous Substances
- Explosive Atmosphere
- Electrical & Electronic Equipment
- Household Appliances
- Units of Measurement
- Tire labeling
- Materials in Contact with Food
- Noise Emissions
- Wood packaging
- Energy Efficiency
Voluntary Marks and Labels
- Cup/Fork Symbol (material in contact with food)
- Green Dot
- Energy Star
- ‘e’ Mark
- Recycling Marks
Mandatory Marks and Labels
This is probably the most widely used and recognized marking required by the EU. Found in all “New Approach” legislation with a few exceptions, the CE marking demonstrates that a product meets all essential requirements (typically related to safety, health, energy efficiency, and/or environmental concerns). CE marking is required for the following products/product families:
- Cableway installations
- Civil explosives
- Construction products
- Electrical/electronic products
- Electromagnetic compatibility
- Low voltage
- Restriction of Hazardous Substances
- Energy efficiency
- Equipment and protective systems in potentially explosive atmospheres (ATEX)
- Gas appliances
- Hot water boilers
- Medical devices
- Non-automatic weighing instruments
- Personal protective equipment
- Pressure equipment
- Radio equipment
- Recreational crafts
- Refrigeration appliances
- Simple pressure vessels
While other non-EU standards may be used to demonstrate a product’s compliance with the applicable directive(s), the manufacturer will have to provide detailed information regarding the compliance process. An array of standardized safety warning symbols/pictograms may also be applicable to each of the above product categories.
In February 2014, to align product harmonization legislation with the provisions of the NLF (most notably Decision 768/2008), the EU adopted an “Alignment Package” consisting of eight revised CE marking directives. These newly aligned directives will be applicable in 2016.
Directive 2010/30/EU “on the indication by labeling and standard product information of the consumption of energy and other resources by energy-related products” sets a framework for the adoption of product-specific directives on the proper energy efficiency labeling for each concerned product. This 2010 Directive broadens the energy labeling scope substantially.
Suppliers are to supply free-of-charge labels or product fiches containing information about consumption of electric or other energy sources to their dealers. Dealers display labels in a visible and legible way and make the fiche available in product brochures or other literature.
For more information, visit the official EU website on Energy Efficient Products
Devices for Use in Potentially Explosive Atmosphere (ATEX)
In addition to applying a CE marking for products falling under the ATEX Directive (2014/34/EC), it is necessary to display the Ex mark, which is a specific marking of explosion protection. Located next to the ‘Ex’ mark will be a symbol designating the product group or category as specified in the directive.
The revised ATEX Directive (2014/34/EC) was adopted in February 2014 as part of the New Legislative Framework alignment package. It replaced the existing directive and became applicable on April 20th, 2016.
For more information, visit the official EU website.
Noise Emission of Outdoor Equipment
Machines used outdoors are subject to CE marking requirements. Noise emission levels are covered separately. The mandatory label specifies noise emission levels.
Resource: EU website on noise emissions.
The “steering wheel” mark is the equivalent of CE marking for marine equipment. It applies to equipment for use on board any new EU ship, wherever the ship is situated at the time of construction, and to equipment placed on board existing EU ships, whether for the first time or to replace equipment already carried on board. It does not apply to equipment already on board on the date on which the Directive entered into force in 1997. The Directive applies to the following equipment categories:
- Life-saving appliances
- Marine pollution prevention
- Fire protection
- Navigation equipment
- Radio-communication equipment
A revised Marine Equipment Directive (2014/90/EC) was adopted in July 2014 and will be applicable on September 18th, 2016.
Directive 96/98/EC on Marine Equipment
Textile products must be labeled or marked whenever they are put onto the market for production or commercial purposes (sale). The names, descriptions, and details of a textile’s fiber content must be indicated on products available to consumers. Except for trademarks or the name of the undertaking, information other than that required by the Directive must be listed separately. Romania requires labels to be in Romanian, English or all languages.
Labels must convey information relating to the upper, the lining and insole sock, and the outer-sole of the footwear article. The information must be conveyed by means of approved pictograms or textual information, as defined by the Directive.
The label must be legible, firmly secured and accessible, and the manufacturer or his authorized agent established in the Community is responsible for supplying the label and for the accuracy of the information contained therein. Only the information provided for in the Directive need be supplied. There are no restrictions preventing additional information from being included on the label.
For more information, visit the official EU website on footwear industry.
Containers and/or packaging (in certain cases) must bear, in indelible, easily legible and visible characters, the following:
- The name, trade name and address, or registered office of the manufacturer or person responsible for marketing the cosmetic product within the Community
- The nominal contents at the time of packaging (by weight or volume)
- The date of minimum durability indicated by “Best before end,” for products with a minimum durability of less than 30 months
- The period after opening during which the product can be used without harm to the consumer, for products with a minimum durability of less than 30 months
- Precautions for use
- The batch number or product reference, for identification
- The product’s function
If it is impossible for practical reasons to print on the packaging all the conditions of use and warnings, an enclosed leaflet, label or tape must be provided.
Member States are to draw up procedures for providing the information set out above in the case of cosmetic products that have not been pre-packaged. The product function and list of ingredients also have to appear on the container or packaging. Romania requires that the information on the label be in Romanian.
Regarding the labeling of nanomaterials present in cosmetics, the Cosmetics regulation indicates that from July 2013 “all ingredients present in the form of nanomaterials shall be clearly indicated in the list of ingredients” and that “the names of such ingredients shall be followed by the word ‘Nano’ in brackets.”
More information: Regulation 1223/2009.
The labeling of dangerous substances must indicate the following:
- The name of the substance
- The origin of the substance (the name and address of the manufacturer or distributor)
- The danger symbol and an indication of danger involved in the use of the substance
- A reference to the special risks arising from such dangers.
The dimensions of the label must not be less than a standard A8 sheet (52 x 74mm), and each symbol must cover at least one-tenth of the label’s surface area. Romania requires that the labeling of dangerous substances be in Romanian. Where the packaging is too small, the labeling may be affixed in some other manner. The packaging of products considered dangerous which are neither explosive nor toxic may go unlabeled if the product contains such small quantities of dangerous substances that there is no danger to users.
Symbols must be employed if the substance can be defined as any one of the following: explosive, oxidizer, flammable, harmful, toxic irritant, corrosive, or harmful to environment. Containers of hazardous substances should include, in addition to the appropriate symbols, a raised triangle to alert the vision-impaired to their contents. Note that this directive has undergone numerous amendments relating, among other things, to the marking and labeling of additional substances. Accordingly, it is advisable to consult all literature.
Regulation 1272/2008 introduces new classification, labeling, and packaging requirements for chemicals based on the Worldwide United Nation’s Globally Harmonized System (UN GHS). It replaced the Dangerous Substances Directive (65/548/EC) and the Dangerous Preparations Directive (1999/45/EC).
Additional Resource: Regulation 1272/2008/EC on classification, labeling, and packaging.
Legal Metrology and Metric Units of Measurement
This legislation specifies permissible ranges of nominal quantities, container capacities and the weights or volumes of prepackaged products. Manufacturers are advised to take note that all labels require metric units, although dual labeling is also acceptable.
Resource: EU website on meteorology and metric units.
The Directive requires an indication of the selling price, and price per unit of measurement, on all products offered to consumers. The aim is to improve the information available to the consumer and to facilitate price comparison. This information must be unambiguous, clearly legible and easily identifiable. If advertising mentions the item’s selling price, it must also indicate its unit price. For products sold in bulk, the unit price is the only item whose indication on the label is mandatory.
Nearly every vehicle component must be certified for safety as specified under the various directives relating to automobiles. The number shown in the rectangle on the label indicates the Member State in which the approval process was conducted. The number for Romania is “19”. A “base approval number” must also be provided adjacent to this certification. This four-digit number will correspond to the directive and type of device in question.
A similar marking is an ‘E’ surrounded by a circle, which applies to the testing of headlight lamps, brake light lamps, and turning signal lamps of all vehicles seeking EU market entry. These include consumer vehicles, low-volume production trucks, light and heavy goods vehicles, trailers, motorcycles, cranes, agriculture and forestry tractors, and special-purpose and off-road vehicles.
Tire label legislation requires that tire manufacturers declare fuel efficiency, wet grip, and external rolling noise performance of C1, C2, and C3 tires (i.e., tires mainly fitted on passenger cars and light- and heavy-duty vehicles). The objective of the regulation is better information for the consumer and a contribution to a more energy efficient transport policy.
The EU Packaging and Packaging Waste Directive harmonized member state legislation regarding packaging material composition and the management of packaging waste. Composition of packaging material is addressed in a series of EU-wide standards.
Resource: Directive 94/62/EC
Like the United States, the EU has adopted legislation to ensure pest control in wood packaging. The marking used for regulated materials is based on the International Plant Protection Convention compliance symbol. For more information, visit the official website on EU requirement for wood packaging.
Voluntary Marks and Labels
Materials in Contact with Food
Manufacturers of containers, plates, cups, and other material that is intended for food are required to check the compliance of their product with EU chemical safety requirements. It is mandatory to comply with the legislation, but the use of the symbol is voluntary. For more information, visit the official EU website on material in contact with food.
The e-mark acts as a metrological “passport” to facilitate the free movement of prepackaged goods. It guarantees that certain liquids and other substances have been packed by weight or volume in accordance with the Directives. While compliance is not mandatory, free movement throughout the EU is guaranteed for prepackaged products that comply with the provisions of the Directive.
Containers with an e-mark also bear an indication of the weight or volume of the product, known as its “nominal” weight or volume. The packer (or importer, if the container is produced outside the EU) is responsible for ensuring that the containers meet the Directive’s requirements. For more information, visit the official EU website on pre-packaging.
The European Eco-label enables European consumers, including public and private purchasers, to easily identify officially approved green products across the EU, Norway, Liechtenstein, and Iceland. Introduced in 1992, the label communicates to the customer that the marked products meet specific eco-friendly criteria that have been developed to apply to everyday consumer goods and services.
The symbol may apply to the following 27 product and services groups:
All-purpose cleaners and cleaners for sanitary facilities
Household cleaning products
Copying and graphic paper
Detergents for dishwashers
Tourist accommodation service
Paints and varnishes
Printed paper products
Growing media and Soil improvers
Hand dishwashing detergents
Soaps, shampoos and hair conditioners
Hard floor coverings
The Eco-label program has recently been expanded to cover fish and fishery products. This means that eco-labeled products have been produced in accordance with specific environmental standards.
Private eco-labels have been developed by the seafood industry to “influence the purchasing decision of consumers and the procurement policies of retailers selling seafood products, to reward producers involved in responsible fishing and aquaculture practices leading towards sustainable use of natural resources.”
There are multiple eco-label schemes, and logos, developed by a variety of operators and according to different characteristics. This confusing situation has led to a need for harmonization and coherence. In response, the UN Food and Agriculture Organization (FAO) has developed a “Guideline for the Eco-Labeling of Fish and Fishery Products from Marine Capture Fisheries” http://www.fao.org/3/i1119t/i1119t.pdf)
The U.S. government has decided not to engage in the development of such marketing tool. Instead, NOAA Fisheries has developed a comprehensive website where stakeholders, including consumers, can find facts about a specific species of fish and related fisheries. Consumers can then make their own purchasing choice as posted on NOAA’s Fishwatch website.
The EC is currently preparing, at the request of the European Parliament and the Council, a feasibility report on options for an EU-wide eco-label scheme for fishery and aquaculture products.
For more information, visit the European Eco-label website.
The “mobius loop” (sometimes known as the “chasing arrows”), based on an international standard, may be found on products throughout Europe and is meant to help consumers identify and participate in recycling schemes for product packaging and materials. As well as being used on printed packaging, the chasing arrows symbol is sometimes featured in the molds of glass, metal, paper, or plastic products. Various kinds of loops indicate whether the product is recyclable, recycled or contains recycled material.
The EU has mandated that certain products be sold in standardized quantities. Council Directive 2007/45/EC harmonizes packaging of wine and spirits throughout the EU. Existing national sizes will be abolished with a few exceptions for domestic producers. For more information, visit the official EU website on pack sizes.
There are no EU-wide symbols used to designate the recyclable nature of glass. However, it is certainly encouraged on the national level with an array of symbols.
The Energy Star
The Energy Star symbol is a voluntary labeling program to help consumers identify the most energy-efficient office equipment on the market, i.e., computers, monitors, printers, copiers, scanners, and multifunction devices. The Energy Star may be placed on products that meet or exceed energy-efficiency guidelines. Initiated by the United States, agreement with the EU was signed in December 2000 and then renewed in 2006 with the goal of coordinating the labeling program in the two markets. The agreement lays out a common set of energy-efficiency specifications, with a common logo that doubles as a marketing tool. For more information, access the official Energy Star website..
The Green Dot
The Green Dot system is a scheme in which participating bodies coordinate the collection, sorting, and recovery of used packaging. This system is administered according to national packaging laws (adhered to by packaging manufacturers, fillers, retailers, and importers), and it should be noted that all participating national systems operate independently. The umbrella organization, PRO-Europe, is responsible for managing the Green Dot labeling system in Europe. Use of the Green Dot in Romania is voluntary; Eco-Rom Ambalaje issues the Green Dot licenses. More than 460 billion pieces of packaging marked with the Green Dot are distributed worldwide. Interested applicants should contact one of the national administering authorities at: PRO Europe S.R.L. (Packaging Recovery Organization Europe) & Eco-Rom Ambalaje.