PACKAGING
PACKAGING AND BEYOND
Alastair McLaughlin, senior engineer at TÜV SÜD, explains product and packaging labelling requirements and shows how a systematic approach works best
roduct and packaging labelling requirements are multi-faceted and legislation can often be complex (both in-country and inter-country). This means that identifying the correct information for a particular product is not always simple. In the UK, UKCA marking (UK Conformity Assessed) has replaced EU CE Marking requirements. The UKCA mark is now required for products placed on the market in England, Scotland and Wales (GB). Initially UKCA requirements will align with CE marking, but over time, divergence is possible. Additional requirements may need to be considered for products and packaging in Northern Ireland (NI), as it aligns with relevant EU rules relating to placing manufactured goods on the market, and CE marking will continue to be accepted. The UKCA mark cannot be used for goods placed on the NI market. If a UK body carries out a mandatory third-party conformity assessment, then a UKNI marking must be applied - accompanied by a EU conformity marking (e.g. CE marking). Goods with both the CE and UKNI marking cannot be placed on the rest of the EU market. If a mandatory third- party conformity assessment was carried out by an EU-recognised notified body, goods with the CE marking can be placed on NI and EU markets. For products that do not require third-party conformity assessment, in most cases marking requirements will be satisfied by combined CE and UKCA markings for the GB, EU and NI markets.
P 8 JUNE 2021 | PROCESS & CONTROL
Qualifying NI goods can be placed on the GB market based on the conformity markings used in NI, such as the CE, and CE/UKNI markings. Qualifying goods are those in free circulation in NI - not under a customs procedure or in an authorised temporary storage facility before being moved between NI and GB.
When it comes to labelling, there are some basic rules that must be considered, including requirements for manufacturers and importers, mandatory and voluntary requirements, and on-product versus packaging labelling.
a product is large enough to accommodate the marking, it must go on the product, aesthetic factors are not an excuse
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I have frequently encountered confusion over the legal status of markings. It may be well known that it is an offence to omit the UKCA marking, CE marking, WEEE marking, or a safety warning on a product. It is less well known that mis-using such marks is also an offence.
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Labels are intended to enable market traceability – back to the manufacturer,
The law requires that if
importer or distributor. As far as labelling is concerned, each one of these economic operators has different responsibilities. The EU and UK requires that if the manufacturer is based in that common market, the product need only be marked with their address – even if the actual production is taking place elsewhere. However, if the manufacturer is outside the EU, the products must be marked with both the manufacturer’s and importer’s address. Retail chains’ own-branded products may be marked with the importer’s and distributor’s address only. Each legal entity must mark their full company name, as well as any trade name they use.
A label must include the type, batch, serial or model number, or another element that allows identification. For example, a Stock Keeping Unit (SKU) which contains a string of characters that uniquely identify a product. Whatever is used, it must link to the product’s Declaration of Conformity and technical files.
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