FEATURE u Labelling & Packaging
Putting product
labelling to the test
By Rob Campling, Senior Manager at TÜV SÜD, a global product testing and certification organisation.
P
roduct and packaging labelling requirements are multi-faceted, and legislation can often be complex. Whilst some of the more complex legislative areas, such as medical, marine and pressure equipment, have their own requirements, for most consumer products the following approach can be used as guidance. The UKCA (United Kingdom Conformity Assessment) mark will be required for most products placed on the market in England, Scotland and Wales (GB) from 1 January 2023. At present UKCA requirements align well with CE marking, but over time divergence is possible. There is currently a transition period until 31 Dec 2022, where UKCA is optional (suggested) and CE marking is accepted. Additional requirements may need to be considered for products and packaging in Northern Ireland (NI). NI remains predominantly aligned with the European Union (EU) conformity assessment approach, and the sale of a CE marked product continues to be permitted throughout the 27 EU countries. If type examination with a UK Conformity Assessment Body (CAB), the UK equivalent of an EU Notified Body, has been done you would use the UKNI mark in conjunction with the CE mark. However, products labelled in this fashion are not permitted to be sold in the EU27. Goods manufactured in NI can be sold
to the rest of the UK under rules regarding ‘unfettered access’. This means that, as part of
32 October 2022 Irish Manufacturing
the UK, a manufacturer in NI is permitted to sell CE marked equipment on the GB market after the current transition date of 31st Dec 2022. The Republic of Ireland, of course, remains in the EU and hence CE marking continues to apply.
THE PHYSICAL LABEL The manufacturer’s label must include their name and address; the type, batch, serial or model number; or another element that allows identification. Whatever is used, it must link to the product’s declaration of conformity and technical files. If applicable, the importer’s label must include their local (EU or GB based) name and address.
In both the EU and UK, there are no specific
laws to mark country of origin (COO). However, fair trading laws require that no false impression of origin and 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 where COO marking is required. EU and UK law requires warning markings
must be clear and legible, with both the CE and UKCA marks being at least 5mm in height, whilst maintaining the dimensions of the original template. Contrasting colours are suggested as a way of making sure that the CE and UKCA logos are clear. EU law also indicates that if the product is large enough to accommodate the marking, it must go on the product. Aesthetic factors are
not an excuse for failing to apply the marking directly to the product. Only if the product is physically too small may the markings instead be placed on the packaging. This is not presently the case for UKCA where no such consideration on the size of products exists, but further guidance is evolving all the time. It is also worth noting that UKCA
currently has a transition period of leniency about labelling. Until the end of 2025, the UKCA mark may be applied to either product, via sticky label, or on accompanying documentation, such as a user guide. After that date only the product itself is permitted to carry the UKCA logo, but again that is expected to evolve over time and may end up aligning with the EU regarding smaller devices Markings must be durable and last the expected lifetime of the product. When checking the durability of the marking, the effects of normal use are considered. Similarly, if your equipment uses harsh solvents, be sure to additionally test your markings against their effects.
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.com/uk
www.irish-manufacturing.com
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