What must be on the label of my product?

Name, address and warning belong on the label

The label (or packaging, or an attached document if the product itself is too small) must in most cases bear the name or brand of the manufacturer, a postal address at which it can be reached, a way to identify the product (type, batch or serial number) and the warnings or safety instructions that belong with the product. This obligation rests with the manufacturer, as described in Article 9 of Regulation (EU) 2023/988. And here lies the surprise that most entrepreneurs do not know: whoever sells a product under their own name or brand is themselves considered a manufacturer — even if the product is made elsewhere and only their own logo is placed on it, or if it is substantially modified. Whoever does this therefore bears the labelling obligation of Article 9, not the lighter role of distributor.

An importer bringing products from outside the EU onto the market checks whether that label is already there and is complete, and adds their own name and address to it (Article 11). A distributor — whoever simply resells a product from an EU manufacturer or importer without placing their own brand on it — does not have this obligation: they only check that the label is present, without having to compile it themselves. The language of the warnings follows the consumer, not the seller: in the Netherlands that is Dutch, in Germany German, and in Belgium Dutch, French or German depending on the language region — a web shop serving all of Belgium therefore in practice needs two language versions.

This follows from Articles 9 and 11 of the Regulation

The contents of the label and the role distribution behind it are set out in Article 9 (manufacturer) and Article 11 (importer) of Regulation (EU) 2023/988. Which language the warnings must have is established per Member State on the basis of the consumer language there.