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Labeling of the box instead of the individual units

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Posted 23 February 2023 - 08:44 AM



We produce a certain food in cups of +-150g. These cups are "ready for retail". Normally we label these individual cups with a cardboard sleeve, that has all the required product information (= required labeling).


A new client, from another country within the European Union, is interested in our product. But they don't want to receive the cups with the sleeve, they want to label the cups themselves with their own sleeve with their own label.


All production data sheets with required information are delivered to this company, so they have all the necessary product information to produce the sleeves.


Is it ok for us to deliver the cups to the client with only the expiry date and batch number printed on the cups? And to pack these cups together in a cardboard box. The cardboard box will have an outer label with the following product information: product name, storage instructions, expiry date, batch number, allergens, our company name and adress).


Is this sufficient enough on our part?


Thank you!



Sayed M Naim Khalid

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Posted 23 February 2023 - 02:13 PM

Consider functions of labels: 

- provide nutritional information

- Provide food safety information (allergen)

- Provide info on the brand

- Provide info for traceability


Let's assume you sell your products (12 in 1 box) to a retailer. That retailer is then selling to Indvidual customers. The customer will need to buy one 1 out of 12. That customer needs all the info from health to knowing your brand, allergen related info and if needed to track a product. 


If you are a small producer. I would certainly buy sticky stickers (self-adhesive Printable stickers) on which you can print. Make one label and print it. It may add a cost of few cents to the final product, but you will be in compliance with labeling regulations. In addition, I would use every unit of the product as a promotional tool to advertise my brand and company. So why not take benefit of the opportunity? Free advertising. 


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Posted 23 February 2023 - 04:34 PM


As you will not be supplying the end user (final customer) with the product, the rules for food information do not apply. Your customer will be the final seller and take the responsibility for final legal labelling, but you have a responsibility to provide sufficient information for them to do this, the information you are supplying on the box seems to be enough.


Dont over complicate things




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Posted 24 February 2023 - 07:15 AM

but you have a responsibility to provide sufficient information for them to do this, the information you are supplying on the box seems to be enough.


Dont over complicate things



@Peter. The information on the box is only sufficient in combination with the product specification as the final product needs an ingredient declaration and not just an allergen list.


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Posted 25 March 2023 - 01:34 PM

I would say yes as you are not selling direct to a consumer. As long as they get batch info and a spec, it seems fine


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Posted 28 March 2023 - 05:25 AM

Yes you can do this (just have traceability info on units and carton label) as the responsibility falls with your customer, who will supply the end consumer. 

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