FEATURE FOCUS: PACKAGING, MACHINERY & LABELLING PRODUCT LABELLING REQUIREMENTS
(currently) the UK, there are no specific laws to mark Country of Origin (COO). However, fair trading laws require that no false impression of origin & customs must be given and that the import declaration documents must state COO. This is not the case internationally – for example, in the USA and Canada, COO marking is required. EU law requires warning markings must
be clear and legible – I recommend symbols should be at least 2.75mm high, and text is at least 1.5 mm high. Markings should also be in a contrasting colour. Alternatively, they can be engraved or embossed, in which case they must be at least 0.5mm deep or proud. These recommendations are based on certain harmonised standards – the law only requires the marking to be legible. EU law requires that if the product is
large enough to accommodate the marking, it must go on the product. Aesthetic factors are not an excuse for not applying the marking directly to the product. Only if the product is physically too small may the markings be placed instead on the packaging.
by Alastair McLaughlin, senior engineer at TÜV SÜD P
roduct labelling legislation can often seem complex and identifying the
correct information for a product is not always simple. When conducting business in or with the UK, Brexit causes further uncertainty. The UKCA mark is planned for use if there is a ‘no deal’ Brexit, but while the UK remains in the European Union (EU) (which we still are at the time of writing) CE marking directives still apply, so the UKCA mark cannot be applied. EU Directives are already transposed
into member states’ national law, so the UK’s legal framework requires little change. The UKCA draft legislation amends existing laws to include the UKCA mark and change some terminology. For example, although the term ‘harmonised standards’ will change to ‘designated standards’, the standards themselves will remain the same, so that there will be a single standards model between the EU and UK. Consequently, for product labelling purposes, very little will change. 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. I have frequently encountered
confusion over the legal status of markings. It may be well known that it is an offence to omit the CE marking, WEEE marking, or a safety warning on a
8 AUGUST 2019 | IRISH MANUFACTURING
product. It is less well known that misusing such marks is also an offence - including the use of the CE marking on products that are outside the CE Marking Directive’s scope. Labels are intended to enable market
traceability – back to the manufacturer, importer or distributor. As far as labelling is concerned, each one of these economic operators has different responsibilities. The EU 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.
WHAT GOES ON THE LABEL? 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. In the EU, including Ireland and
When it comes to labelling, there are some basic rules that must be considered
TESTING REQUIREMENTS Markings must be durable and last the expected lifetime of the product. The standards for household goods, audio- visual equipment, IT & business equipment therefore include a rub test applied to markings. The label is rubbed by hand for 15 seconds, firstly with a cloth soaked in water, and secondly with a cloth soaked in petroleum spirit. When checking the durability of the
marking, the effects of normal use are considered. For example, markings by means of paint (other than enamel coating) on handles or parts that are likely to be cleaned frequently is not considered to be durable. Therefore, engraving or embossing is recommended in such cases. Similarly, if your equipment uses harsh solvents, be sure to additionally test your markings against those solvents. Thankfully, there is a lot of guidance
online from the EU and national governments. A good starting point for guidance on CE marking is the EU’s “Europa” website:
https://ec.europa.eu/growth/single- market/ce-marking_en While product labelling may at first
appear to be confusing, a systematic approach works best. Once you identify the directives and regulations that apply to your products, the labelling requirements simply follow.
TÜV SÜD
www.tuvsud.co.uk
/ IRISHMANUFACTURING
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