The label changes with the country. And it is checked before printing the batch.
A labelling mistake found on the artwork file costs half an hour of work. The same mistake found on twenty thousand labels already printed costs the reprint, and found on goods already labelled it costs someone peeling stickers off in the warehouse.
What follows applies to food. Two products also have a body of rules of their own, to be read together with this page and not instead of it: the mandatory particulars for wine and the marketing standards for olive oil.
Within the European Union the language changes, not the list. Mandatory information is harmonised by Regulation (EU) No 1169/2011, but Article 15 requires it to appear in a language understood by consumers in the country where the product is sold. German for Germany, French for France.
Outside the Union the list changes too. The United States recognises nine major allergens, Annex II of the European regulation lists fourteen. Celery, mustard, sulphites, lupin and molluscs are mandatory in Europe and absent from the US list. The way they are declared changes too.
The check comes before printing, and before quoting. The same regulation sets a minimum font height, so compliance depends on decisions taken when the file goes to the printer. After that, every correction is paid for in the warehouse.
This piece is part of the guide to export operations for the small food producer and covers the sixth of its eight steps: adapting the label to the destination market.
The template, to download
One file, two sheets. The first is the table: nine requirements for seven markets, with what the market guides on this site have checked against the sources, and three empty columns to write what you have checked for your product, when and against which source. Where the check hasn't been done the cell says «to be checked», and doesn't fill the gap. The second sheet carries the six questions to the buyer, in English and Italian, with space for the answer.
| File | What it contains | Link |
|---|---|---|
| Label by countryExcel, two sheets | Nine requirements for seven markets with the check columns, and the six questions to the buyer to fill in. |
The files are free. There is no form in front of them, we don't ask for an address and we receive no notification when someone downloads them. The second question to the buyer, who places the product on the market, is the one worth most, and the table shows why: it decides who is responsible for packaging in Germany and France.
The European rule: the language of the country where you sell
Within the European Union, mandatory food information is harmonised by Regulation (EU) No 1169/2011. Harmonised means the list of mandatory items is the same in all Member States. It doesn't mean the Italian label works everywhere.
Article 15 is short and worth having in full: «mandatory food information shall appear in a language easily understood by the consumers of the Member States where a food is marketed», and within their own territory Member States «may stipulate that the particulars shall be given in one or more languages from among the official languages of the Union».
Then there is a second article nobody reads that decides whether your sticker is a solution or a problem. Article 13 establishes that mandatory information is marked in a conspicuous place, «easily visible, clearly legible and, where appropriate, indelible», and that it «shall not in any way be hidden, obscured, detracted from or interrupted by any other written or pictorial matter or any other intervening material».
A compliant sticker applied before placing on the market is common practice. A sticker that covers mandatory information underneath isn't.
The same Article 13 also sets the minimum font size: x-height equal to or greater than 1.2 millimetres, dropping to 0.9 millimetres on packages whose largest surface is under 80 square centimetres. It is a typographic rule, and it is respected or broken at the moment someone decides the layout, not afterwards.
Germany: the language is the easy part
Germany needs German on the label, and that is the part everyone knows. The part that surprises concerns packaging, and it appears on no label.
Germany requires whoever first places packaging on its market to register in the LUCID packaging register and join a collection scheme. Who is obliged depends on how you sell, and this is where the misunderstandings are: if you sell to an importer or distributor established in Germany, they place the goods on the market, so the obligation is theirs; if you sell directly to end consumers, typically from your website, the obligation is yours.
For direct sales to end consumers there is a change with a precise date: from 12 August 2026 foreign companies without a seat in Germany that sell directly to end consumers must appoint an authorised representative established in Germany and name them in the register.
Registration in the register, however, remains a personal obligation: the representative takes on the other obligations, not that one. Without a valid registration, the products may not be distributed in Germany.
Source: Zentrale Stelle Verpackungsregister, the authority that runs the register.
France: two separate schemes, and a question the public sources don't settle
In France similar logic applies: extended producer responsibility for packaging and the rules on sorting information fall on whoever places the product on the French market. With two further complications, worth knowing before quoting.
First: household packaging and professional packaging follow two separate schemes, with different obligations and contacts. Confusing them leads to asking the right thing of the wrong body.
The second we state openly: on who exactly is responsible when the supplier is foreign, the public sources don't give a single answer. We have tried to settle it twice and it doesn't settle, so we don't settle it here. Anyone telling you otherwise with confidence, on this specific point, is simplifying.
The practical consequence doesn't change, though, and it is the same as for Germany: who, formally, places the goods on that country's market? It should be put in writing in the agreement with the buyer before the first shipment, together with who takes on the packaging obligations. A commercial agreement says who pays, not always who is liable.
United States: the list of allergens changes, and so does the form
Towards the United States the leap is bigger, because it isn't a matter of translating a European label. The two allergen lists don't coincide, and neither does the way they are declared.
The FDA recognises nine major allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame, added from 1 January 2023 by the FASTER Act. Annex II of the European regulation lists fourteen, and includes celery, mustard, sulphur dioxide and sulphites, lupin and molluscs: five items that don't exist on the US list.
The form of the declaration changes too. In Europe Article 21 requires the name of the allergen to be «emphasised through a typeset that clearly distinguishes it from the rest of the list of ingredients, for example by means of the font, style or background colour». In the United States the FDA provides two alternative ways: in brackets next to the ingredient name, or in a «Contains» statement immediately after the ingredient list.
On top of this come obligations that concern the company before the product: a foreign facility that manufactures, processes, packs or holds food destined for the United States must be registered with the FDA and designate a US Agent, and for every shipment a Prior Notice must be submitted before arrival.
| Market | What changes on the label | Who is responsible |
|---|---|---|
| European Unionanother Member State | Same mandatory items, in the language of the country of sale (Art. 15). Allergens emphasised in the ingredient list (Art. 21). Characters with an x-height from 1.2 mm. |
The producer, who must supply a compliant label or allow it to be adapted before sale. |
| Germanysale to a distributor | Label in German. Registration in the LUCID packaging register and participation in a collection scheme. |
The German distributor, because they are the first to place the goods on the market. |
| Germanysale to the end consumer | Label in German. LUCID registration and, from 12 August 2026, an authorised representative established in Germany. |
The Italian producer. Registration remains personal even after the representative is appointed. |
| France | Label in French. Extended producer responsibility for packaging, with separate schemes for household and professional packaging. |
Whoever places the product on the French market. With a foreign supplier the public sources don't give a single answer, and it should be defined in writing. |
| United States | Nine major allergens instead of fourteen, declared in brackets or with the «Contains» statement. Facility registration, US Agent, Prior Notice. |
The producer for registration and US Agent. Checks on the foreign supplier fall on the importer, who will ask you for the documentation. |
Why the check comes before printing
The rules above have one thing in common: they all apply to decisions taken beforehand. The language decides the text, the allergens decide the structure of the list, the font size decides the layout. These are artwork choices, and the artwork goes to the printer only once.
Outside the European Union the same decisions change again, and change a lot: the mandatory UK address on the label, Brazilian front-of-pack labelling, product registration in the Emirates. Six markets have a guide each, starting with Switzerland and the United Kingdom.
Hence the cost ladder, which is the only serious reason to reverse the order of things: a mistake found on the file costs a revision, found on the printed labels it costs reprinting the whole run, found on products already labelled it costs relabelling by hand, and found by the buyer it costs the consignment held up and a conversation that is no longer about the product.
The sequence that holds up has three steps in this order, and the first isn't technical.
1. Which country will the goods be sold in, and through which channel (distributor, retail, direct to consumer)? 2. Who will be the entity placing the product on the market in that country? 3. Which language(s) do you need on the label, and do you require a country-specific ingredient wording? 4. Do you apply the label yourselves, or do you need the goods delivered already labelled? 5. Are there national requirements on packaging (recycling registration, waste sorting information) that fall on us? 6. Please confirm all of the above in writing before we send the artwork to print.
The second question is the one worth most, and it is also the only one buyers rarely expect. The answer decides who is responsible for packaging obligations in Germany, France and half of Europe, and it should be put in black and white together with the rest of the export price list terms, not left to a verbal understanding.
When the labels become twelve
With one product and one market the label is checked by hand, and checked well. The point where it breaks comes with four products for three countries: twelve versions, each with its own language, its own ingredient list, its own allergen block, and each needing an update when a recipe changes.
The risk, at that point, stops being compliance and becomes misalignment: the German version updated in June and the French one stuck in March, with an ingredient that has changed in the meantime. The same thing that happens to the technical sheet when three versions circulate, with the difference that here the document is printed on twenty thousand pieces.
The repetitive work here is preparing the language versions from a single approved version: it is the point where assisted preparation of multilingual drafts saves real hours. With the constraint written in Ethics, which weighs more here than anywhere: the system prepares and flags, but no label text goes to print without a person having read and approved it, and for a new market that person works from the competent authority's sources, not from memory.
The figures cited here all come from legal texts or authorities, and can be checked at the link: nine major allergens in the United States from the FDA, fourteen items in Annex II of Regulation (EU) No 1169/2011, the minimum font height of 1.2 mm (0.9 mm under 80 cm²) from Article 13, the date of 12 August 2026 from the German authority that runs the packaging register.
No statistics on relabelling costs appear on this page. The cost ladder described above is a logical progression, not a measurement: it depends on the print run, the type of label and where the goods are when the mistake is discovered.
On France we don't have an answer and we say so, instead of giving a plausible one. The sources consulted give opposite readings on who is responsible for packaging obligations when the supplier is foreign, and the two schemes (household and professional) make the question even less straightforward. It stays open until we find an institutional source that distinguishes the two cases.
Questions and answers
Is translating the Italian label enough to sell in Germany or France?
No. Article 15 of Regulation (EU) No 1169/2011 requires mandatory information to appear «in a language easily understood by the consumers of the Member States where a food is marketed». German for Germany, French for France.
Within the Union the list of mandatory items is the same everywhere, so the work is translation and not redesign. A sticker applied before placing on the market is allowed, provided it doesn't cover other mandatory information.
Outside the Union translation isn't enough, because the content changes. For the United States the list of allergens to declare changes, where the FDA added sesame as the ninth major allergen, and the form of the nutrition table changes. Drafting in the market's language is prepared as a draft, which is what the multilingual drafts system does; the check of that country's mandatory fields remains a compliance check to do against the competent authority's sources before sending to print.
Who is responsible for packaging obligations when I sell to a foreign distributor?
Whoever first places the goods on that country's market. In Germany, if you sell to an importer or distributor established there, the obligation to register in the LUCID register is theirs. If you sell directly to end consumers, the obligation is yours, and from 12 August 2026 you also need an authorised representative established in Germany.
Registration in the register remains a personal obligation in any case. And a commercial agreement says who pays, not always who is liable: the question should be put in writing before the first shipment.
What changes in a food label for the United States?
The list and the form. The FDA recognises nine major allergens (milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans, sesame from 1 January 2023). Annex II of the European regulation lists fourteen: celery, mustard, sulphites, lupin and molluscs aren't there in America.
In Europe the allergen is emphasised within the ingredient list; in the United States it is declared in brackets or with the «Contains» statement after the list. On top come facility registration with the FDA, US Agent and Prior Notice for every shipment.
Can I apply a sticker instead of reprinting the label?
Within the European Union it is common practice, provided the sticker is applied before placing on the market and complies with Article 13: mandatory information «shall not in any way be hidden, obscured, detracted from or interrupted» by other matter. In practice the sticker can't cover mandatory information underneath.
The same article sets the minimum font height: 1.2 mm of x-height, dropping to 0.9 mm under 80 cm² of surface. It is a printing constraint, and it is why it pays to check first.
When should the label be checked for a new market?
Before sending to print, and before quoting. Three steps in order: get the buyer to confirm in writing the destination country and sales channel; check language, allergens and requirements against the sources of that country's competent authority; and only then send the file to the printer.
The cost ladder justifies the order: a revision of the file, against reprinting a run, against relabelling by hand, against a consignment held up somewhere with the buyer waiting.
Notes on sources
- Regulation (EU) No 1169/2011: Article 13 (presentation of mandatory particulars, ban on hiding or obscuring, minimum font height), Article 15 (language requirements), Article 21 (emphasis of allergens), Annex II (the fourteen items). The count of Annex II was done on the consolidated text, not on a second-hand source.
- Zentrale Stelle Verpackungsregister, the German authority that runs the LUCID packaging register: authorised representative obligation for foreign companies selling to end consumers, from 12 August 2026.
- U.S. Food and Drug Administration, The FASTER Act: Sesame Is the Ninth Major Food Allergen: the nine major allergens, sesame from 1 January 2023, and the permitted ways of declaring it, including the «Contains» statement.
- U.S. Food and Drug Administration, Importing Food Products into the United States: foreign facility registration, US Agent, Prior Notice.
- On France this page states that it doesn't know. The check was attempted twice and the public sources give opposite readings on who is responsible when the supplier is foreign; household and professional packaging also follow distinct schemes. When the source doesn't hold up, the statement isn't published.
- The block of questions in English is built to be copied, and doesn't reproduce the correspondence of any real client.
One approved version per product, and the languages that follow from it.
Fourteen allergens in Europe, nine in the United States, and twelve versions to keep aligned when the markets become three. With Itria we start from the outside to build custom digital systems for exporters. For you that translates into more requests, fewer losses and less manual work. Write us a line about what weighs on you. We take the first step: what a buyer sees when they look you up, and what we found there. Even if we don't end up working together.