The standard U.S. label does not comply with EU labeling requirements. While there is a broad range of legislation covering the marking, labeling, and packaging of products entering the EU, it is worth noting the distinction between what is mandatory and voluntary. Decisions related to mandatory marking, labeling, or packaging requirements may sometimes be left up to individual Member States. Furthermore, voluntary marks and labels are used as marketing tools in some Member States but not in others.

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 packaging. These range in scope from signs of danger to indications of methods of proper recycling and disposal. The intention of these marks is to provide market surveillance authorities, importers, distributors, and end users with information concerning safety, health, energy efficiency, and 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).

Manufacturers should be mindful that, in addition to the EU’s mandatory and voluntary schemes, national voluntary labeling schemes may apply additional requirements.

Mandatory Marks and Labels

• CE Marking: Many products must bear the CE marking before they can be sold in the EU – no matter where they were manufactured.
• Energy Labels: Product categories that require energy labels: light bulbs and lamps, heaters, fridges and freezers, washing machines and driers, air conditioners and fans, electronic displays, including televisions, kitchen appliances, and tires. As of March 1, 2021, regulation on energy labelling for electronic displays (EU) 2019/2013 repeals and replaces Regulation (EU) 1062/2010.
• WEEE Label: The symbol indicates that the product should not be discarded as unsorted waste but must be sent to separate collection facilities for recovery and recycling. The WEEE marking must appear on any electrical and electronic equipment placed on the EU market.
• Footwear Label: Clothes and other textile products sold in the EU are required to carry a label with information on the textile fiber composition. This enables your customers to make an informed decision when they buy. According to EU rules, the term “footwear” refers to all articles with applied soles designed to protect or cover the foot. For example: flat or high-heeled shoes, sandals, boots, slippers, espadrilles, and sports shoes (including specialist sports shoes and those with skates attached). There may be additional requirements, depending on the country where you plan to market the footwear.
• Textile Label: Every textile product must be labelled or marked to show its fiber composition whenever the product is marketed in the EU. These labels must be firmly attached to the product, for example, sewn in. This requirement concerns all products made up of at least 80% of textile fibers, calculated by weight, such as: clothing, furniture coverings, mattress coverings, camping tents.                 

Voluntary Marks and Labels

• EU Ecolabel: If you manufacture products which you believe have outstanding environmental features, they might qualify to use the EU Ecolabel. Today, over 37,000 products sold on the EU market bear the EU Ecolabel, meaning that they comply with rigorous ecological criteria. Current product groups are cleaning products, clothing and textiles, coverings, electronic equipment, furniture, gardening, holiday accommodation, lubricants, paper, personal care.
• E-MARK: Prepackaged (or prepacked) products sold in any EU country must provide information on the package specifying the nominal quantity (weight or volume) of their contents. Examples of prepackaged products include food, drinks, cosmetics, and cleaning products.

An overview of EU mandatory and voluntary labeling and marking requirements has been compiled in the Country Commercial Guide for the European Union. 

Starting in 2021, all CE marked products will need to have an EU address on the label. This also applies to products sold online. The name and address must appear on the product or the product’s packaging so that customs and market surveillance authorities can have a contact person in case the product is suspected to present a risk.

Detailed information on food and agricultural labeling requirements can be found in the GAIN report: Food and Agricultural Import Regulations and Standards Country Report.

Spanish labeling requirements are similar to those used elsewhere in the EU, except that they must be in Spanish and include the name and the EU address of the manufacturer, distributor, and/or packer. It should also be noted that all labels require metric units. In addition, the regional government of Catalonia requires that all products for distribution in the region must be labeled in the local language (Catalan).  Catalonia is the only region in Spain with this official requirement, making the need for close collaboration with a good local partner/importer/distributor even more important to ensure a smooth market entry.    

In view of the complexity and rapid change in marking, labeling and testing requirements in Spain, U.S. exporters are advised to request pertinent instructions from their importers prior to shipment.

Basic Labeling Requirements in Certain Product Categories

• Electrical Products: Those operate in a range of 50 to 1,000 volts alternating current or 75 to 1,500 volts direct current must comply with the EU low-voltage directive. There are three accepted forms of proof of conformity with this regulation: a mark issued by an authorized EU agency, a certificate issued by an approved EU authority, or a declaration issued by the manufacturer, which can self-certify the product.
• Used Equipment: Spain allows the entry of used equipment, material, and goods subject to the same standards concerning safety as new imports in the same product category.
• Foods: The Directorate General of Health implements human consumption standards for the preparation, residue content, and media storage for virtually all foodstuffs. Labeling must conform to EU requirements and must be in Spanish.
• Foods and Animal Feed: Product containing genetically modified organism (GMO) must be labeled “contains GMOs.”  “Traceability” through the production chain is required by the legislation. The GMO content of products must be documented along the production chain and kept on file for five years.
• Agricultural Products: Labeling requirements are fully harmonized with the EU labeling system and labels must be in Spanish. The standard U.S. label does not comply with the EU’s labeling requirements. On December 13, 2014, the EU’s new “Food Information to Consumers (FIC)” Regulation 1169/2011 became applicable and introduced new obligations and changes to the existing rules.  The FIC regulation establishes new horizontal labeling requirements and repeals labeling directive 2000/13/EC, as well as nutrition labeling directive 90/496/EEC and warning labels directive 2008/5/EC. For specific information on agricultural standards, please refer to the EU website.
• Fertilizers and Fungicides: Imported fertilizers must be registered with the local Ministry of Agriculture. Inspection and analysis will be performed prior to customs clearance. The Ministry of Agriculture must approve all printed advertising and publicity materials, and labels must be in Spanish and include detailed precautions. The Ministry web page includes a link for “phytosanitary products” and the online register.   
• Textiles: Customs and point-of-sale regulations require that textile goods and ready-made clothing have a Spanish label. Standard Spanish textile nomenclature and content requirements must be stated on the label. Requirements relating to textile content, labeling, and packaging are specific and extensive.
• Drugs, Pharmaceuticals, and Cosmetics: These goods are subject to technical inspection and registration by the Directorate General of Health prior to entry. There are also detailed marking and labeling requirements, which include detailed chemical composition.

The EU Eco-Label

The EU Ecolabel is a voluntary label, which U.S. exporters can display on products that meet high standards of environmental awareness. The Ecolabel is intended to be a marketing tool to encourage consumers to purchase environmentally friendly products. The criteria for displaying the ecolabel are strict, covering the entire lifespan of the product from its manufacture, use, and disposal. These criteria are reviewed every three to five years to consider advances in manufacturing procedures. EU Ecolabel criteria are defined for a wide range of product groups.

As of March 2023, 2,367 licenses have been awarded for 88,045 for goods and services in the EU market. Most licenses were awarded in Italy (17%), Germany (16%), Spain (15%) and France (14%). In terms of products, most were awarded in Spain (18%), followed by Italy (15%), France (13%) and Germany (10%).

Applications to display the Ecolabel should be directed to the competent body of the member state in which the product is sold. A one-time application fee and an annual fee are payable to the competent body that processes the application.

EU Ecolabel application fees:

• €200-€350 ($215.24-$376.67) for micro-enterprises.
• €200-€600 ($215.24-$645.72) for SMEs and companies from developing countries.
• €200-€2,000 ($215.24-$2152.40) for all other companies.

30% reduction for companies registered under EMAS or 15% reduction for companies certified under ISO 14001. Reductions are not cumulative and only the higher reduction applies where both systems are met.

A maximum annual fee for use of the Ecolabel has been capped at:

• €18,750 for microenterprises, SMEs, and applicants from developing countries.
• €25,000 for all other companies.

The annual fee can be a flat rate or based on the annual value of sales within the EU of the product awarded the EU Ecolabel. Where the annual fee is calculated as a percentage of the annual sales value, it will not be more than 0.15% of that value. In the case of SMEs, micro-enterprises, or applicants from developing countries, the annual fee is reduced by at least 25%.