Our case studies cover some of the products our Asia Import Platform customers have developed in recent years.
An all-in-one platform to help you take your go from idea to product manufacturing in China, Vietnam, or India. The platform is used by more than 2000 importers worldwide.
Sourcing ReportFrom $179
Looking for a manufacturer in China, Vietnam, India or Thailand? We can help you identify relevant manufacturers in China and Vietnam based on product scope, test reports, ISO 9001, ISO 14001, BSCI and other factors.Learn more
Supplier ScreeningFrom $279
Found a supplier online but not sure if they are legit? Our team can verify their business license, test reports, and company certificates to assess their status and risk level.Learn more
Free Case Study (PDF)
Suggestion: Watch the 20 minutes video tutorial before reading this article
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!
Most countries have legal requirements for how a product shall be labeled. A label can, for example, inform the customer about the following:
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.
We can help you manufacture products in China, Vietnam & India?
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.
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:
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.
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.
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 “Made in China”.
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.
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.
Clothing and textiles must be labeled according to FTC labeling requirements. This includes the following:
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:
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.
The CE mark signals compliance with one or more EU directives, such as the following:
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.
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.
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.
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 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.
Soccer goals, Portable swimming pools, Exercise cycles, Basketball rings and backboards, Treadmills.
Sunglasses, Luggage straps, Clothing & Textiles (Care labeling).
Vehicle ramps, Recovery straps for vehicles, MC helmets, Jacks, Bicycle helmets, Bicycles (pedal bicycles), Motor Vehicles (Child restraints).
Bean bags, Blinds, curtains and window fittings.
Hot water bottles, Fire extinguishers, Cosmetics, Disposable cigarette lighters.
Canadian importers must keep track of a few different legal acts, regulating consumer product labels:
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.
We can help you manufacture products in China, Vietnam & India?
Co-founder of Asiaimportal (HK) Limited and based in Hong Kong. He has been quoted in and contributed to Bloomberg, SCMP, Alibaba Insights, Globalsources.com, China Chief Executive, Quartz Magazine and more.
42 Responses to “Product Labeling Regulations in the US, EU and Australia”
I Found some useful information on this page. Thank you. My question is what percentage of manufacturing needs to occur in China to claim Made in China. We are US based company, but would like to take the advantage of Chinese markets which gives preference to medical devices manufactured in China. So besides setting up an office and registering our products in China, what else is required to claim “Made in China” label on the medical device.
I cannot comment on how China determines the country of origin. That is not our area of expertise.
Hi there thanks for sharing this article. Do you know if “made in India” for example will be accepted for import into the USA if it is stated on the barcode label?
My understanding is that the country of origin label must be permanent
i’m still having a hard time to find an european legislation about mandatory safety/warning labels that should be on sport equipment (in my case, skateboards and kick scooters).
We import our goods from China for several years now without any issues, but this month we had an issue in Poland, saying that some stickers were missing in the material (the blue stickers with the manual info and the security material like halmet).
can you please help me with this?
Yes, I think it is up to EU countries to decide for themselves whether national language labels are necessary, and I think Poland recently made this a requirement.
Hi, do you know if country of origin label is required to show on one-time use isolation gown made of Polyethylene for US market? If it is okay to show only on the polybag instead of the product itself? Thanks for your help.
I have not read any statement that it’s not required, but not sure if they would recall medical supplies for lacking a country of origin label at this time. I would still check with a licensed customs broker in the US.
We import fasteners from numerous countries in Asia. Depending on cost and availability of the item we may buy it from China, Taiwan or Thailand. We do repack the product to sell and we list all countries on the box or bag.
Can we list multiple countries on a package or label that states “Made in China, Taiwan or Thailand?” Or do we have to have a label per country for the origin of the product?
Unfortunately, I don’t have an answer to this question.
My colleagues have the notion that on something that was Made in China that is put in a box and a label put on the box here that we can say “Assembled In USA.” These products may be sold and shipped worldwide. I say that this may meet the FTC Standard but not the standard of NAFTA and our other trading partners.
No, I don’t think you can claim that the product is assembled in the USA by repacking or relabeling it.
I just discovered your website and thanks a lot for the useful information. I have a question about the content of the label. Must adhere to the product itself or is it just enough to show the info in the packaging? I am thinking about bringing travel pillows to the US, and I am wondering whether adding a composition label to the product, as it is already on the box.
Best and thanks in advance!
Not sure what kind of label you’re referring to. However, the label must be permanently affixed to the product.
Hi. I am importing carbon fiber rods from china. How can i label them?
Not sure you even need to label them.
1. Where will you import the carbon fiber rods?
2. What is their usage?
Hi Fredrick, We are looking to ship a brand new construction machine from the US to Australia. Do you know the requirements?
Hi Fredrik, Any idea on US labelling requirements for things like stationary? We are importing photo albums and I’m unsure if there needs to me more than just the ‘Made in China’ label?? Many thanks for your help.
Unfortunately, I don’t know either
I have an essential oil product which is used in the air freshener export to Europe.
I would like to know what regulation I have to follow when I’m making the product label.
One third party angency made a CLP label including CAS No, hazards, danger and precaution statements etc. But I assume that’s not the product label I need since I see the labels of essential oil on the europe market don’t include those items.
So I’m very confused about the proper label requirement in europe for essential oil.
Looking forward to your reply.
Thank you very much!
This probably goes under cosmetic product regulations. We have an article about that: https://www.chinaimportal.com/blog/importing-cosmetics-beauty-personal-care-products/
Thank you for your kindly advise.
However, the third party agency defined our product doesn’t belong to cosmetic product because it doesn’t contact with skin directly. The actual suggest use of the product is place 5-7 drops in the air freshener diffuser.
So we are still very confused…
I want to put Made In PRC on rubber mats.
They have a plastic shrink wrap, that stays on until they reach the final buyer.
Can I print PRC on a sticky plastic label, and attach that to the plastic wrap?
Perhaps the bar code label for Amazon?
I have to label the city and country of manufacturing for a CPSC requirement. Can I use the label “Made in Yiwu, China” to knock out both requirements with one label?
It’s correct that the tracking label must specify the manufacturing place. That said, I would keep them separate to avoid the risk that the customs, Amazon or the CPSC rejecting your label.
For example, you could specify it like this:
Manufacturing place: Yiwu, Zhejiang Province, China
Made in China
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.
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)
I believe you are wrong about the Made in PRC being allowed by US Customs. Several rulings have said it is not acceptable.
Yes, I believe you are right on that too.
Hello Freddy and Fredrink, based on this —> “Several rulings have said it is not acceptable.” —> where do you these rules that have said that it is not acceptable to use “Made in PRC”?
Thank you very much,
P.S. Thank you for such a great article! Keep up the great work!!
I have been looking around myself but can’t find anything. My only source is the comment on this page.
II. REJECTED ABBREVIATIONS
China, People’s Republic of
“PRC” is not an acceptable abbreviation for articles imported from the People’s
Republic of China.
SOURCE: HRL 727372, dated March 18, 1985. See also, HRL 730578, dated
July 10, 1987; HRL 560693, dated March 6, 1998.
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.
Note that CH is the country code for Switzerland, CN is the code for China and you need the made in part, not just the 2 digit code.
Cheryl is right. It must state “Made in China” and not only the country code
Hi there. Is it not sufficient to print ‘China’? Does it definitely need to say ‘Made In’ too?
No, I don’t think that’s sufficient.
what is the upgrade regulations in use can you shear? seems this is old, such as CA 65 warning label.
I think you still need warning labels, for CA Prop 65!
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?
Switzerland have their own rules that are a bit tricky. You can learn more here: https://en.wikipedia.org/wiki/Swiss_made
For Japanese watches, you can state “Made in Japan” if you use a Citizen movement, or Seiko.
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
Comments are closed.