Daily Archives: March 31, 2015

Regulatory Damnation 36: Labelling

While the subject of labelling sounds harmless enough, it can still pose a nightmare for your supply chain. Products that are not properly labelled can be held up or seized at the border, seized for violation of state or federal labelling regulations from your warehouses or shelves, or result in massive fines and trade embargoes until the problem is corrected.

Labelling can be a nightmare, regardless of what industry you are in. In food and beverage, many jurisdictions require not only that all products contain nutritional information but also indicate whether or not the products are derived from GMO (Genetically Modified Organisms). In the tobacco industry, despite continuous threats of lawsuits from the tobacco companies (see this recent expose from the John Oliver show), countries are starting to impose plain packaging laws and third parties dictate what packaging can and can not contain. In electronics, some countries are considering imposing laws that force a company to indicate the expected lifespan of the product being produced and how long it will be supported (as this is very important to a consumer spending hundreds, or thousands, on a new electronic device with the belief that the manufacturer is going to support the hardware and software for at least a few years). And different countries require different units, warnings, languages, etc.

Not that any of this is necessarily a bad thing, but if multiple jurisdictions require different labelling requirements, it can be difficult to produce a label that satisfies all of the jurisdictions that operate under the same language. And if the company needs to produce a multi-lingual label that satisfies multiple jurisdictions in multiple countries, it can be a nightmare.

There are steps a company can take to make it easier.

First of all, the company can implement a Global Trade Management (GTM) solution that tracks all of the labelling requirements in each country the organization plans to sell products in.

The company can review each label or proposed update before it is sent to the packaging supplier to make sure it is in full compliance.

Finally, the company can set up alerts and each time a labelling requirement changes, and check that all labels are in compliance. If not, packaging production runs can be halted until an updated label design is prepared and approved. This will save the organization a lot of time, money, and headaches, and, as indicated above, prevent the organization from experiencing problems with customs, legislative authorities, and even retailers.

But, like every other endeavour that needs to be undertaken, this will require time, resources and money to get done.