Private label and factory location, the criteria to be followed

EU regulation 1169/11 prescribes to indicate the name or business name and address of the operator responsible for labeling purposes (Article 9.1.h). That means, 'the trader under whose name or business name the product is marketed or, if that trader is not established in the Union, the importer into the Union market'. (EU reg. 1169/11, article 8.1)

Is essential to this end, avoid creating confusion in the consumer and in the supervisory authorities, at the same time mentioning the name of the producer and of the distributor without making any distinction between the two figures. (1)

In the case of private-label, i.e. a product sold under the private label, it is therefore necessary to indicate its name or company name. The name or business name, please note, e not the brand.

The headquarters of the plant, in the meantime, it will soon be reintroduced among the mandatory information on the label of foods processed and marketed in Italy. (2). Except in cases where the establishment is already indicated by means of a specific health mark. The indication of the owner of the establishment will remain optional, as it has not been prescribed in the legislative decree being approved.

Dario Dongo


(1) That is to say that, where both figures are cited, pre-eminence - in the order of citations, and perhaps even graphics - must be attributed to that of the owner of the trademark that appears on the product
(2) Presumably, within 180 days from the entry into force of the legislative decree approved by the Council of Ministers on 15.9.17

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