Product Labeling Regulations in the US, EU and Australia

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About to import products from China or elsewhere in Asia? Then you need to ensure that the products are properly labeled.

In this article, we explain what every importer must know about labeling requirements in the EU, US and Australia.

We also explain why you cannot rely on your manufacturer to ensure compliance on your behalf. In fact, most of them don’t even know how products must be labeled in your market.

Keep reading, to ensure that your products are not seized by the customs authorities!

What is ‘Product Labeling Requirements’?

Most countries have legal requirements for how a product shall be labeled. A label can, for example, inform the customer about the following:

  • The manufacturing country
  • If the product meets certain legal safety requirements (i.e., compliance marks)
  • Size, material and other general product information
  • Warning labels and user instructions

Some labeling requirements apply to all, or a wide range of, product categories.

For example, all products in the US must be labelled with the country of origin (i.e., Made in China). In the European Union, many products must be CE marked.

Other labeling requirements apply to specific products. Examples include toys, electronics and textiles – each with their own set of unique labeling requirements.

Notice that labeling requirements are usually just one of many requirements that importers must fulfil to ensure compliance with certain regulations.

In addition, you may need to keep track of the following:

Technical Compliance: This means that the product is manufactured according to certain technical standards, or substance restrictions. The product is therefore able to pass the necessary tests.

Documents Requirements: The Importer is required to create and store a set of documents. Such documents may include circuit diagrams, component lists, design drawings and risk assessments.

It is important to underline that this article does not include information above the two points above.

Product Labeling Requirements

Can I trust my manufacturer in Asia to ensure compliance with all applicable Labeling Requirements in my market?

Absolutely not. Most manufacturers in China, and elsewhere in Asia, are not aware of overseas labeling requirements.

Manufacturers are not supposed to provide you with free legal advice. Instead, they expect you to provide them with “ready made” labeling files.

Thus, it is always, and without exception, up to the importer to ensure that the labels contain the required information.

This is also an issue with “wholesale products” (i.e., ready made items), as such products are not made specifically with US, EU or other labeling requirements in mind.

Hence, “Made for China” products tend to be non-compliant with foreign labeling requirements.

How do I communicate the Labeling Requirements to the supplier?

First, you need to research which labeling requirements apply to your products, and design the labels accordingly.

For example, if you are an apparel designer, you need provide the supplier with ‘ready made’ care and brand labels.

In addition, the supplier must also know the following:

  • Label dimensions
  • Label material / print type
  • Label color/s (i.e., pantones)

Which file format should I use for the labels?

Normally, manufacturers work with .eps and .ai (Adobe Illustrator) files.

You may also provide the supplier with drawings that show the exact position of the labels.

Don’t count on the supplier to check the font, spelling or other issues. What you send to them is what they’ll print.

What can happen if our products are incorrectly labeled?

Incorrectly labeled products cannot be legally placed on the market. For example, the US customs have the right to return cargo that are not labeled with the country of origin.

In the EU, products that fall within the scope of certain directives, must carry the CE mark – and in some cases other compliance labels.

Companies that sell non-compliant products may face heavy fines, depending on the number of and severity of the violations.

Labeling Requirements in the United States

Country of Origin

Most products sold in the United States must carry a Country of Origin label. If your products are manufactured in China, you may label your product as following:

  • Made in China
  • Made in PRC

The country of origin must be clearly visible to the customer – either on the product itself, its packaging, or both.
You may not, for any reason, attempt to hide the country of origin.

There are certain exceptions though. For example, Watches can be labeled according to the origin of the movement.

Thus, a Watch that is manufactured and assembled in China may still be labeled as “Japanese Movement” (without a trace of “Made in China), if the movement is Japanese. Well, that is probably the result of successful lobbying efforts.

Products that don’t have a country of origin label cannot be sold in the US, and the customs authorities may even return the goods back to where it came.

CA Prop 65

California Proposition 65 restricts more than 800 substances. Compliance is only mandatory if you sell to consumers in California, or if your company is based there.

There are two ways to comply with CA Prop 65:

a. Ensure that your product is compliant. This can be achieved by submitting the product to a product laboratory.

b. Affix a “warning label”:

WARNING: This product contains chemicals known to the State of California to cause cancer and birth defects or other reproductive harm.

Well, that one will surely not make your product fly off the shelf.

Apparel and textiles labelling

Clothing and textiles must be labeled according to FTC labeling requirements. This includes the following:

  • Fiber composition
  • Care labels
  • Sizes


CPSIA is a framework regulation for toys and children’s products. All products that fall within the scope of CPSIA must carry a “tracking label”. The tracking label shall, at a minimum, include the following:

  • Product name
  • Batch ID
  • Importer information
  • Contact details

You may also need to attach user instructions and warning labels.


The FCC mark signals compliance with FCC Part 15 Subpart B, which regulates virtually all electronic products.

There are various types of FCC labels that apply to certain types of electronic products.


UL (Underwriter Laboratories) develops standards primarily for electronics products. UL compliance is not mandatory, but the UL compliance mark is seen as a sign of quality.

Labeling Requirements in the European Union

CE Mark

The CE mark signals compliance with one or more EU directives, such as the following:

  • Low Voltage Directive
  • RoHS
  • EMC Directive
  • EN 71 Toy Safety Directive
  • Machinery Directive

Thus, the CE mark is found on all sorts of products, all which are seemingly unrelated. Examples include Watches, bicycles, laptops and finger paint.

These products are so different that they are regulated by entirely different sets of safety standards.

Products that are not covered by any “CE marking directive” shall not carry the CE mark. Such products include apparel, and other textiles.


The WEEE mark is mandatory on electronic products, and signals separate storage for electronics waste.

Apparel and textiles labelling

Clothing sold in the European Union must carry care instructions and fiber composition (i.e., 98% cotton, 2% spandex), in the language of the target market. So far, there is no mandatory sizing system.

Labeling Requirements in the United Kingdom

At the time of writing, the United Kingdom is still part of the European Union.

That may, however, change in a few years.

Yet, it is unlikely that the United Kingdom will stop implementing EU labeling requirements. UK importers, and businesses selling to the UK, don’t need to worry about future changes.

Despite complaints about the EU trying to over regulate everything (yes, there is some truth in that), many countries far beyond the EU implement their directives. For example, Korea, China and India has implemented RoHS.

Many other markets, such as Singapore, even accept products that are compliant with EU regulations.

Labeling Requirements in Australia and New Zealand

Many products imported to Australia and New Zealand are required to comply with certain product safety standards. These regulations also cover labeling requirements. As of today, the following products are regulated by one or more product safety standards:

Toys & Children’s products

Toys for children to and including 3 years, Toys and finger paints containing lead or other substances, Toys containing magnets, Inflatable toys, Projectile toys, Prams and strollers, Nightwear for children, Cots, Bunk beds, Balloon blowing kits, Baby walkers, Baby dummies, Baby bath aids, Aquatic toys.

Sports & Outdoor

Soccer goals, Portable swimming pools, Exercise cycles, Basketball rings and backboards, Treadmills.

Textiles & Accessories

Sunglasses, Luggage straps, Clothing & Textiles (Care labeling).

Vehicles, accessories, parts & tools

Vehicle ramps, Recovery straps for vehicles, MC helmets, Jacks, Bicycle helmets, Bicycles (pedal bicycles), Motor Vehicles (Child restraints).

Home & Furniture

Bean bags, Blinds, curtains and window fittings.


Hot water bottles, Fire extinguishers, Cosmetics, Disposable cigarette lighters.

Labeling Requirements in Canada

Canadian importers must keep track of a few different legal acts, regulating consumer product labels:

  • Consumer Packaging and Labeling Act
  • Textile Labeling Act

Here are few labeling requirements for imported products:

a. The label must contain the identity of the prepackaged product in terms of its function or generic name.

b. The label must contain the principal place of business and identity of the manufacturer or dealer.

c. The label must contain the information about the quality, age, size, quantity, nature, material content, geographic origin, performance, composition, where applicable.

d. The label must provide accurate information about the quantity of the product packaged in the container.

Do you need help to ensure compliance with all mandatory safety standards?

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a. An overview of product safety standards in the United States, Europe, Australia & more

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    10 Responses to “Product Labeling Regulations in the US, EU and Australia”

    1. Mark C December 28, 2014 at 2:10 pm #

      Hi Fredrik

      Thinking of having wristwatch OEM from China.

      Can you tell me that the labeling and shipping compliance regulations are for wristwatches shipped from China to the United States that are OEM with our brand name from an existing watch design the manufacturer already carries?

      (To be clear, this is not our unique design, but a watch design they (manufacturer) already carry in stock as part of their product line – they just put our logo on the watchface and the case-back and assemble them.)

      I would assume an MOQ of say, 300-500 so it would likely go seafreight? Do wristwatches need RoHS compliance, or do they already have them inherently?

      Also, we’d like to be able to carry the words ‘Swiss Made’ on the product face and caseback, so Swiss Movement is a must, you mention this is not a high extra cost compared to other movements?

      thanks for a good informative site!

      MC in United States

    2. Robert Chung November 20, 2017 at 7:47 am #


      Just wondering if this still holds true. If our watches have Swiss Movements but are assembled in China, we do not have to state Made in China anywhere? (Watch/Packaging, etc.)

      Can someone confirm this please? Would it be sufficient to just write Swiss Movement on the caseback?

    3. Jack August 13, 2018 at 4:01 am #

      what is the upgrade regulations in use can you shear? seems this is old, such as CA 65 warning label.

      • Ivan Malloci August 14, 2018 at 8:15 am #

        Hello Jack,

        I think you still need warning labels, for CA Prop 65!

    4. Freddie October 24, 2018 at 12:34 pm #

      When exporting sunglasses to the US from the EU (products made in China) is it enough to print CH on the temple? Or does it have to read “made in…” as in: made in CH/made in China/made in R.O.C)?

      Thanks in advance.


    5. Freddy January 11, 2019 at 1:47 am #

      I believe you are wrong about the Made in PRC being allowed by US Customs. Several rulings have said it is not acceptable.

    6. Thierry January 14, 2019 at 12:02 am #

      Thanks for your great article.
      I am creating a running apparel brand. My tees are manufactured in China. In the inner label I would like to print « Made with ❤️ In China » do you think It’s ok?
      I live in Canada.

      • Fredrik Gronkvist January 20, 2019 at 7:55 pm #

        Hello Thierry,

        I have no idea to be honest… but it sounds a bit risky. It’s also a stretch to state that a product has been made with love in China (I have never seen a group of workers that expressed any form of love in the assembly halls)

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