The label changes with the country. And you check it before printing the batch.
A labelling mistake found in the artwork file costs half an hour's work. The same mistake found on twenty thousand printed labels costs a reprint, and found on goods already labelled it costs someone peeling off stickers in the warehouse.
What follows applies to food products. Two products also have their own body of rules, to be read alongside this page rather than 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 European Union, the list changes too. The United States recognises nine major allergens; Annex II of the EU regulation lists fourteen. Celery, mustard, sulphites, lupin and molluscs are mandatory in Europe and absent from the US list. The way you declare them changes as well.
The check comes before printing, and before quoting. The same regulation sets a minimum font height, so compliance depends on decisions made 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 small food producers 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 this site's market guides have checked against the sources, and three empty columns for what you've checked for your product, when and against which source. Where no check has been done, the cell says “to be checked” and doesn't paper over the gap. The second sheet has the six questions to ask the buyer, ready to send, with space for the answers.
| File | Contents | Link |
|---|---|---|
| Label by countryExcel, two sheets | Nine requirements for seven markets with the checking columns, plus the six questions for the buyer to fill in. |
The files are free. There's no form in the way, we don't ask for an email address, and we don't get notified when anyone downloads them. The second question for the buyer, who places the product on the market, is the most valuable one, and the table shows why: it decides who is responsible for packaging in Germany and France.
The EU 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 every Member State. It doesn't mean an 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's a second article nobody reads, which decides whether your sticker is a solution or a problem. Article 13 says mandatory information must be 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 the product goes on sale is common practice. A sticker that covers mandatory information underneath isn't.
Article 13 also sets a minimum font size: an x-height of at least 1.2 millimetres, reduced to 0.9 millimetres on packaging whose largest surface is under 80 square centimetres. It's a typographic rule, and you either follow it or break it at the moment someone decides the layout, not afterwards.
Germany: the language is the easy part
Germany needs German on the label, and everyone knows that part. The part that catches people out is about the packaging, and it doesn't appear on any label.
Germany requires the business that first places packaging on its market to register in the LUCID packaging register and join a collection scheme. Who has that obligation depends on how you sell, and that's where the confusion lies: if you sell to an importer or distributor based in Germany, they place the goods on the market, so the obligation is theirs; if you sell directly to consumers, typically through your own website, the obligation is yours.
For direct sales to consumers there's a change with a precise date: from 12 August 2026, foreign businesses with no base in Germany that sell directly to consumers must appoint an authorised representative based in Germany and name them in the register.
Registering in the register itself, though, remains a personal obligation: the representative takes on the other duties, but not that one. Without a valid registration, your products can't be sold in Germany.
Source: Zentrale Stelle Verpackungsregister, the authority that runs the register.
France: two separate schemes, and a question public sources don't settle
France follows similar logic: extended producer responsibility for packaging and the rules on sorting information fall on the business that places the product on the French market. With two extra complications worth knowing before you quote.
First: household and commercial packaging follow two separate schemes, with different obligations and different contacts. Mixing them up means asking the right question of the wrong body.
Second, and we say so openly: public sources don't give a clear answer on exactly who is responsible when the supplier is abroad. We've tried to pin it down twice and it won't pin down, so we won't pretend to here. Anyone who tells you otherwise with confidence, on this specific point, is oversimplifying.
But the practical consequence is the same as for Germany: who, formally, is placing the goods on that country's market? Put it in writing in the agreement with the buyer before the first shipment, along with who takes care of the packaging obligations. A commercial agreement says who pays, not always who is legally responsible.
United States: the allergen list changes, and so does the format
Exporting to the United States is a bigger step, because it isn't a matter of translating a European label. The two allergen lists don't match, and neither does the way you declare them.
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 EU regulation lists fourteen, including celery, mustard, sulphur dioxide and sulphites, lupin and molluscs: five items that don't exist on the US list.
The format 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 allows two alternatives: in brackets next to the ingredient name, or in a “Contains” statement straight after the ingredients list.
On top of this come obligations that apply to the business before the product: any foreign facility that manufactures, processes, packs or holds food bound for the United States must be registered with the FDA and designate a US Agent, and every shipment needs a Prior Notice filed before arrival.
Two products have a US page all of their own: exporting wine to the United States, with the COLA and FDA renewal, and exporting olive oil to the United States, with the FSVP and the nutrition labelling exemption.
| Market | What changes on the label | Who is responsible |
|---|---|---|
| European Unionanother Member State | The same mandatory items, in the language of the country of sale (Art. 15). Allergens emphasised in the ingredients list (Art. 21). Font x-height of at least 1.2 mm. |
The producer, who must supply a compliant label or allow it to be adapted before sale. |
| Germanyselling to a distributor | Label in German. Registration in the LUCID packaging register and membership of a collection scheme. |
The German distributor, because they are the first to place the goods on the market. |
| Germanyselling direct to consumers | Label in German. LUCID registration and, from 12 August 2026, an authorised representative based in Germany. |
The Italian producer. Registration remains personal even after a representative is appointed. |
| France | Label in French. Extended producer responsibility for packaging, with separate schemes for household and commercial packaging. |
The business placing the product on the French market. With a foreign supplier, public sources don't give a clear answer, so agree it in writing. |
| United States | Nine major allergens instead of fourteen, declared in brackets or with a “Contains” statement. Facility registration, US Agent, Prior Notice. |
The producer, for registration and the US Agent. Checks on the foreign supplier fall on the importer, who will ask you for the paperwork. |
Why the check comes before printing
The rules above have one thing in common: they all apply to decisions made beforehand. The language decides the text, the allergens decide how the ingredients list is structured, the font size decides the layout. These are artwork decisions, 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, Brazil's front-of-pack labelling, product registration in the Emirates. Six markets have a guide each, starting with Switzerland and the United Kingdom.
Hence the scale of costs, which is the only serious reason to reverse the usual order: a mistake found in the file costs a revision, found on printed labels it costs reprinting the whole run, found on goods already labelled it costs relabelling by hand, and found by the buyer it costs a held consignment and a conversation that's no longer about the product.
The sequence that holds has three steps in this order, and the first one 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 most valuable, and it's also the one buyers rarely expect. The answer decides who is responsible for packaging obligations in Germany, France and half of Europe, and it should be set down in black and white along with the rest of your export price list terms, not left to a verbal understanding.
When the labels number twelve
With one product and one market, you can check the label by hand, and check it properly. It breaks down with four products for three countries: twelve versions, each with its own language, its own ingredients list, its own allergen block, and each one needing an update whenever a recipe changes.
At that point the risk stops being compliance and becomes drift: the German version updated in June and the French one stuck at March, with an ingredient that has changed in the meantime. It's the same thing that happens to the spec sheet when three versions are circulating, except that here the document is printed on twenty thousand units.
The repetitive work here is preparing the language versions from a single approved version: that's where assisted drafting of multilingual versions saves real hours. With the rule set out in Ethics, which matters more here than anywhere: the system prepares and flags, but no label text goes to print until a person has read and approved it, and for a new market that person works from the relevant authority's sources, not from memory.
The figures cited here all come from legal texts or authorities, and you can check them at the links: 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 below 80 cm²) from Article 13, and the 12 August 2026 date from the German authority that runs the packaging register.
No statistics on relabelling costs appear on this page. The scale of costs 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 found.
On France, we don't have an answer, and we say so, rather than offering a plausible one. The sources we consulted give opposite readings on who is responsible for packaging obligations when the supplier is abroad, and the two schemes (household and commercial) make the question even less straightforward. It stays open until we find an official 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 EU, the list of mandatory items is the same everywhere, so the job is translation, not redesign. A sticker applied before the product goes on sale is allowed, as long as it doesn't cover other mandatory information.
Outside the EU, translation isn't enough, because the content changes. For the United States, the list of allergens to declare is different, with the FDA adding sesame as the ninth major allergen, and so is the format of the nutrition panel. Drafting in the market's language can be prepared in draft, which is what the multilingual drafting system does; checking that country's mandatory fields remains a compliance check to do against the relevant authority's sources before printing.
Who is responsible for packaging obligations when I sell to a foreign distributor?
The business that first places the goods on that country's market. In Germany, if you sell to an importer or distributor based there, the obligation to register in LUCID is theirs. If you sell directly to consumers, the obligation is yours, and from 12 August 2026 you also need an authorised representative based in Germany.
Registering in the register remains a personal obligation either way. And a commercial agreement says who pays, not always who is legally responsible: put the question in writing before the first shipment.
What changes on a food label for the United States?
The list and the format. The FDA recognises nine major allergens (milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans, and sesame since 1 January 2023). Annex II of the EU regulation lists fourteen: celery, mustard, sulphites, lupin and molluscs aren't on the US list.
In Europe the allergen is emphasised within the ingredients list; in the United States it's declared in brackets or with a “Contains” statement after the list. On top of that come FDA facility registration, a US Agent and Prior Notice for every shipment.
Can I use a sticker instead of reprinting the label?
Within the European Union it's common practice, as long as the sticker is applied before the product goes on sale and complies with Article 13: mandatory information “shall not in any way be hidden, obscured, detracted from or interrupted” by anything else. In practice, the sticker mustn't cover mandatory information underneath.
The same article sets the minimum font height: an x-height of 1.2 mm, reduced to 0.9 mm below 80 cm² of surface. It's a print constraint, and it's why it pays to check first.
When should the label be checked for a new market?
Before printing, 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 that country's relevant authority's sources; and only then send the file to the printer.
The scale of costs justifies the order: a file revision, against reprinting a whole run, against relabelling by hand, against a consignment held somewhere with the buyer waiting.
Notes on sources
- Regulation (EU) No 1169/2011: Article 13 (presentation of mandatory particulars, ban on hiding or obscuring them, minimum font height), Article 15 (language requirements), Article 21 (emphasising allergens), Annex II (the fourteen items). The Annex II count was made on the consolidated text, not a second-hand source.
- Zentrale Stelle Verpackungsregister, the German authority that runs the LUCID packaging register: the requirement for foreign businesses selling to consumers to appoint an authorised representative, 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. We tried to check twice, and public sources give opposite readings on who is responsible when the supplier is abroad; household and commercial packaging also follow separate schemes. When the source doesn't stand up, the claim isn't published.
- The block of questions in English is written to be copied, and doesn't reproduce any real client's correspondence.
One approved version per product, and the languages that flow from it.
Fourteen allergens in Europe, nine in the United States, and twelve versions to keep in line once your markets number three. At Itria we start from the outside and build tailored digital systems for exporters. For you, that means more enquiries, fewer losses and less manual work. Drop us a line about what's slowing you down. We'll make the first move: we'll look at what a buyer sees when they search for you, and tell you what we found. Even if we never end up working together.