Product Labelling Requirements: Importer vs Exporter Responsibilities (2026 Guide)
If you plan to import or export products in 2026, getting product labelling right can save you up to 6 weeks in customs. This is one area you really can't afford to overlook.
Labels seem simple: a bit of text, a barcode, maybe a few icons. But in our experience at The Sourcing Co, they're the most common 'hidden' cause of supply chain friction. We recently saw a shipment held in customs for 3 months because the labels failed to meet a single information requirement. The result? A $50,000 fine and major financial hit.
Stories like this show why it's important to get labelling, testing and paperwork right from the beginning. That's the best way to keep your shipments moving and avoid costly proplems.
The good news is that once you know who is responsible for each part, labelling becomes much easier. Here's how to sort it out.
Why Product Labelling Matters More Than Ever (2026 Update)
Incorrect labelling is one of the most common reasons shipments are delayed, destroyed or sent bacl. Governments use product labels to ensure:
- Safety: The product meets local safety standards.
- Transparency: The origin is clear (no hiding where goods are made).
- Consumer Protection: Buyers have clear usage and care instructions.
- Traceability: The importer can be tracked down in case of a recall.
What's New For 2026?
This year, regulators are making two big changes. If you sell to the EU, be sure to pay attention:
The bottom line is that labelling isn't just a legal requirement now; it also helps build trust.
- Digital Product Passports (DPP): In the European Union, brands are increasingly required to use QR codes that link to a digital record detailing a product's composition, recyclability and origin. This is part of the Ecodesign for Sustainable Products Regulation (ESPR), which first affects electronics, textiles and batteries.
- Greenwashing Crackdowns: You can't just print 'Eco-friendly' on your packaging anymore. The EU's new Green Claims Directive says you need real proof on the label, like 'Made from 80% recycled polyester,' instead of vague marketing terms.
The bottom line is that labelling isn't just a legal requirement now; it also helps build trust.
Importer vs Exporter: Who is Actually Responsible For Labelling?
Importers and exporters have each their own responsibilities and their roles are different. Here's the easiest way to understand it:
Key Actions for Importers
As the importer, you are ultimately responsible. You need to check:
A Note on Drop Shipping
Drop shipping can be tricky, importers usually don't have much control over how suppliers label each package.
- Exporters provide accurate information.
- Importers ensure the information meets their country's legal requirements.
Key Actions for Importers
As the importer, you are ultimately responsible. You need to check:
- Language: Are the labels translated into the official language of the destination country? (e.g. French for Quebec, Canada)
- Symbols: Are mandatory safety symbols (like CE, UKCA or WEEE bins) present and the correct size?
- Address: Is the address of the 'Responsible Person' or entity in the destination country clearly printed?
A Note on Drop Shipping
Drop shipping can be tricky, importers usually don't have much control over how suppliers label each package.
- Risk: If a customer receives a product with Chinese labelling in a market that requires English/Spanish (like the US), you are liable.
- Solution: Get in touch with us to talk about third-party quality checks before your products ship. Finding these problems early can save you trouble later.
Exporter Responsibilities
Exporters (or manufacturers) are. responsible for creating the initial, accurate product information. Their duties include:
Accurate Product Details
They must provide exact details on materials and composition (e.g., 70% cotton and 30% polyester), technical specifications, electrical ratings and batch or lot numbers. They cannot misrepresent the product. If they say it's silk, it really must be silk.
Providing Required Testing or Certifications
Depending on the product, factories may need to provide:
Factories put labels on products, whether they're care labels, stickers or imprints. They need to follow your instructions about where to place the label, how durable it should be and the print size.
Notifying Buyers of Changes
If they change any component, material or process, they must notify the importer. Even a small change in material can make the label non-compliant.
Accurate Product Details
They must provide exact details on materials and composition (e.g., 70% cotton and 30% polyester), technical specifications, electrical ratings and batch or lot numbers. They cannot misrepresent the product. If they say it's silk, it really must be silk.
Providing Required Testing or Certifications
Depending on the product, factories may need to provide:
- CE documentation (for Europe)
- FCC test reports (for US electronics)
- Toy safety test results (EN71 or ASTM)
- Material content certificates
Factories put labels on products, whether they're care labels, stickers or imprints. They need to follow your instructions about where to place the label, how durable it should be and the print size.
Notifying Buyers of Changes
If they change any component, material or process, they must notify the importer. Even a small change in material can make the label non-compliant.
Importer Responsibilities
Warning: Importers take on most of the legal risk. If something goes wrong, regulators will come after you, not the factory overseas.
Ensuring the Label Meets Local Laws
Even if the exporter provides a label, you need to ensure it meets the rules for the destination country and product type. This means checking things such as units of measurement (Imperial or Metric) and country-of-origin requirements.
Providing the Final Label Artwork
Most compliant labels are created by the importer, not the factory. The factory prints the labels, but you are responsible for what they say.
Keeping Compliance Records
You need to keep a Technical File containing test reports, certificates, label approvals and artowrk proofs for at least 10 years in multiple locations.
Correcting Non-Compliant Labels
If customs finds an issue, the importer has to pay for relabelling, repairs or any fixes.
Pro tip: Always have a backup plan. If customs flags your labels, call them right away to get clear instructions. We've seen importers avoid six-week delays by setting up overnight relabelling services nearby.
Ensuring the Label Meets Local Laws
Even if the exporter provides a label, you need to ensure it meets the rules for the destination country and product type. This means checking things such as units of measurement (Imperial or Metric) and country-of-origin requirements.
Providing the Final Label Artwork
Most compliant labels are created by the importer, not the factory. The factory prints the labels, but you are responsible for what they say.
Keeping Compliance Records
You need to keep a Technical File containing test reports, certificates, label approvals and artowrk proofs for at least 10 years in multiple locations.
Correcting Non-Compliant Labels
If customs finds an issue, the importer has to pay for relabelling, repairs or any fixes.
Pro tip: Always have a backup plan. If customs flags your labels, call them right away to get clear instructions. We've seen importers avoid six-week delays by setting up overnight relabelling services nearby.
Region-by-Region Labelling Essentials
United States
- Country of origin: Mandatory (e.g., 'Made in China', 'Product of Vietnam').
- Textiles: Strict FTC textile labelling requirements.
- Safety: CPSC safety warnings (especially for children's products).
- Electronics: FCC ID and electrical ratings.
European Union
- CE Marking: Mandatory for toys, electronics, machinery and more.
- Traceability: Address of the EU Responsible Person.
- Language: Must be in the language(s) of the member state where sold.
- Waste: WEEE symbol (crossed-out trash bin) for electronics.
United Kingdom
- UKCA Mark: The UK's replacement for CE (though CE is still accepted for many goods indefinitely, as of recent updates, checking gov.uk guidance is vital).
- Address: Address of a UK Responsible Person.
Australia / Canada
- Canada: Bilingual labelling (English + French) is mandatory under the Consumer Packaging and Labelling Act
- Australia: Strict country of origin formatting (e.g., 'Made in Australia from 90% Australian ingredients').
Common Labelling Mistakes (That Delay Shipments)
Over the years, we've seen many preventable issues. Here are the top offenders:
- HS Code Mismatches: If the Hamronised System (HS) code on your invoice doesn't match the one on your label, it can lead to instant audits. Make sure they match exactly.
- Using 'Domestic' Labels for Export: A label that's fine in the US often won't work in Europe.
- Missing Country of Origin: You must clearly state 'China,' 'India' or 'Vietnam.' Hiding it or making it too small will cause you to fail compliance checks.
- CE Mark Without a Test Report: Customs will stop your shipment right away. You can't use the CE mark unless you have the technical file to prove it.
- No importer address: Many goods in the EU, the UK and the USA require a local importer's address. Regulators need this to contact you if there's a safety recall.
Best Labelling Practices for Importers & Sourcing Teams
If you remember just one part, make it this section.
- Always make your own label artwork. Factories aren't compliance experts, so they'll print whatever you give them. Use templates or hire a professional designer to ensure your labels meet all the required standards.
- Approve label mock-ups before production starts. Ask for a photo of the sample label, check the size and confirm the material type (woven, printed or sticker).
- Keep your compliance documents organised. Having a technical file ready will save you trouble if customs has questions.
- Check all requirements before you place an order, not after the production has started. This is a critical step in vetting your suppliers.
Quick 2026 Labelling Checklist
Here's a simple cheat sheet for most consumer products:
- Country of Origin
- Importer or Brand Address
- Product Name / Model Number
- Traceability Code
- Safety Warnings
- Relevant Certifications
- Material Composition
- Care Instructions (for textiles)
- Scannable Barcode
Get Product Labelling Right Every Time with The Sourcing Co
Labelling may not be the most exciting part of importing, but it's essential. If you get it wrong, your whole supply chain can stop. If you get it right, everything runs smoothly.
If you need help checking your labels, talking to a factory or dealing with complex regional rules, The Sourcing Co is here to help.
Because of our reach and network, we can get you access to suppliers and negotiate favourable terms far more quickly and cheaply than you could if you were trying to on your own.
Contact our sourcing experts today to make sure your next shipment is fully compliant.
If you need help checking your labels, talking to a factory or dealing with complex regional rules, The Sourcing Co is here to help.
Because of our reach and network, we can get you access to suppliers and negotiate favourable terms far more quickly and cheaply than you could if you were trying to on your own.
Contact our sourcing experts today to make sure your next shipment is fully compliant.
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