Basic product labeling
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HOW TO LABEL PRODUCTS CORRECTLY?!
The topic of product labeling is quite complex and raises many questions for many manufacturers and importers of electronics and radio equipment:
• Why label products?
• What should the label contain?
• Is it necessary to label the products or is it sufficient to label the packaging?
• How and where to apply the marking?
• Do I need to apply the EAC mark?
• What are we waiting for labeling in the future?
Indeed, if we take several samples of homogeneous products from different manufacturers, it will become obvious the ambiguity and diversity of approaches to labeling, both the product itself and the packaging. Therefore, to answer all the above questions, you should refer to the practice of the regulatory authorities and the requirements of regulatory requirements, but first you need to answer the most fundamental question about the purpose of labeling products.
Why label products?
Obviously, when exercising state control, the official must make sure that the products comply with the information specified about them in the documents for the goods, since this will depend on the correctness of the application of certain measures of state regulation. Therefore, we can make an unambiguous conclusion that the labeling of products primarily serves to identify them, and its correctness will largely depend on how informative the labeling is.
What should the label contain?
If we consider the practice of the customs authorities, it should be noted that the main information about the product itself is contained in the 31 column of the customs declaration, so it is not difficult to conclude that the following information should be indicated on the product:
- name, designation or type of product;
- article, type, series, make and or model;
- basic properties, parameters and (or) characteristics;
- trademark, if available;
- product manufacturer;
- the country of production (origin) of the product.
The requirements for this volume of information are also established by the provisions of the technical regulations . At the same time, the labeling of some products may have additional information. So, for example, on laptops, monitors and other similar products, information about serial numbers is indicated, smartphones have IMEI numbers, etc.
It is important to note that if the import of goods requires the provision of any permits (license, certificate/declaration of conformity, notification), it is important that the information specified in the permits correspond to the information of the label. Non-compliance may result in fines and possible confiscation of the goods.
Do I need to label the products or is it enough to label the packaging?
The requirements of the technical regulations provide for marking both on the packaging and the products themselves . At the same time, if it is not possible to apply the above information to the product, this information should be indicated in the operating documentation attached to the product.
It should be emphasized that the operating documents for the product, in addition to the information from the label, must contain the following information •
* the purpose of the product;
• product parameters and specifications;
* terms and conditions of operation, installation, storage, transportation, sale and disposal of the product;
• measures to be taken when a product malfunction is detected;
* the name and location of the manufacturer (the person authorized by the manufacturer), the importer, as well as their contact details;
* the month and year of manufacture of the product and (or) the place of application of this information, or the method of determining the year of manufacture.
The operational documentation must be made out on paper, which may also be accompanied by a set on electronic media. At the same time, in relation to non-household electrical and radio electronics products, it is allowed to issue a set of operational documentation only on an electronic medium.
How and where to apply the marking?
As for the requirements for identification and readability of the marking itself, it must be applied in an accessible place for inspection, be easily distinguishable and readable with the naked eye. At the same time, the marking itself can be applied in any way that allows you to ensure the clarity and clarity of the image for the period of the product's service life.
In the Russian Federation, marking and drawing up operational documents are carried out in Russian.The use of a foreign language is allowed only in relation to details, units of measurement, trademarks, proper names, localities and other names.
Do I need to apply the EAC sign?
In accordance with the current legislation, products that are subject to confirmation of compliance with the requirements of the technical regulations applied in the territory of the EAEU, and have passed all the assessment procedures established by the technical regulations, must be marked with a single "EAC" address mark . Moreover, the marking with a single circulation mark is applied to the products themselves and the documents attached to them before the products are put into circulation on the EAEU market.
It is important to emphasize that it is not allowed to mark products with the EAC mark, the compliance of which with the requirements of technical regulations is not confirmed. Liability for this action for legal entities in accordance with Article 14.46 of the Code of Administrative Offences of the Russian Federation (Administrative Code of the Russian Federation), provides for the imposition of a fine of 100 to 300 thousand rubles, and if as a result of the above actions, in particular, harm to the life or health of citizens, or property, the fine for legal entities can be from 700 thousand to 1 million rubles.
It should also be noted that many importers often face situations when foreign suppliers refuse to apply the EAC mark on the product for various reasons. It should be noted here that the legislation provides for the possibility of marking already on the territory of the Russian Federation, as part of the customs procedure of a customs warehouse or conditional release of products, in the absence of EAC marking on imported products .
What does the future hold for labeling?
Speaking about labeling, it is impossible not to mention that in the Russian Federation, the practice of mandatory labeling of goods by means of identification is currently gaining momentum in order to ensure the receipt of prompt and reliable information about the movement of goods within the framework of the economic activities of organizations . The introduction of this practice is considered as a tool to counteract the turnover of counterfeit and falsified products and is largely determined by the policy to combat illegal trafficking of industrial products, build a "healthy" competitive environment and improve tax discipline .
The implementation of the system of traceability of goods when they move through the commodity distribution network is provided through an information control system based on the unified national marking system "Honest Sign". Identification of each unit of the product is carried out by assigning a unique digital code DATA MATRIX, scanning which you can get all the information about the product.
Currently, mandatory identification marking is applied to clothing, shoes, medicines, perfumes, tobacco products and some other goods, the turnover of which, according to the government, is most associated with counterfeiting and falsification . From the point of view of electronics, mandatory identification marking currently applies only to cameras, flashlights and flash lamps, but a unified national marking system should cover all industries in accordance with the government's strategy to combat illegal trafficking in industrial products in Russia, so in the future we should expect an expansion of the list of products subject to mandatory identification marking.
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The topic of product labeling is quite complex and raises many questions for many manufacturers and importers of electronics and radio equipment:
• Why label products?
• What should the label contain?
• Is it necessary to label the products or is it sufficient to label the packaging?
• How and where to apply the marking?
• Do I need to apply the EAC mark?
• What are we waiting for labeling in the future?
Indeed, if we take several samples of homogeneous products from different manufacturers, it will become obvious the ambiguity and diversity of approaches to labeling, both the product itself and the packaging. Therefore, to answer all the above questions, you should refer to the practice of the regulatory authorities and the requirements of regulatory requirements, but first you need to answer the most fundamental question about the purpose of labeling products.
Why label products?
Obviously, when exercising state control, the official must make sure that the products comply with the information specified about them in the documents for the goods, since this will depend on the correctness of the application of certain measures of state regulation. Therefore, we can make an unambiguous conclusion that the labeling of products primarily serves to identify them, and its correctness will largely depend on how informative the labeling is.
What should the label contain?
If we consider the practice of the customs authorities, it should be noted that the main information about the product itself is contained in the 31 column of the customs declaration, so it is not difficult to conclude that the following information should be indicated on the product:
- name, designation or type of product;
- article, type, series, make and or model;
- basic properties, parameters and (or) characteristics;
- trademark, if available;
- product manufacturer;
- the country of production (origin) of the product.
The requirements for this volume of information are also established by the provisions of the technical regulations . At the same time, the labeling of some products may have additional information. So, for example, on laptops, monitors and other similar products, information about serial numbers is indicated, smartphones have IMEI numbers, etc.
It is important to note that if the import of goods requires the provision of any permits (license, certificate/declaration of conformity, notification), it is important that the information specified in the permits correspond to the information of the label. Non-compliance may result in fines and possible confiscation of the goods.
Do I need to label the products or is it enough to label the packaging?
The requirements of the technical regulations provide for marking both on the packaging and the products themselves . At the same time, if it is not possible to apply the above information to the product, this information should be indicated in the operating documentation attached to the product.
It should be emphasized that the operating documents for the product, in addition to the information from the label, must contain the following information •
* the purpose of the product;
• product parameters and specifications;
* terms and conditions of operation, installation, storage, transportation, sale and disposal of the product;
• measures to be taken when a product malfunction is detected;
* the name and location of the manufacturer (the person authorized by the manufacturer), the importer, as well as their contact details;
* the month and year of manufacture of the product and (or) the place of application of this information, or the method of determining the year of manufacture.
The operational documentation must be made out on paper, which may also be accompanied by a set on electronic media. At the same time, in relation to non-household electrical and radio electronics products, it is allowed to issue a set of operational documentation only on an electronic medium.
How and where to apply the marking?
As for the requirements for identification and readability of the marking itself, it must be applied in an accessible place for inspection, be easily distinguishable and readable with the naked eye. At the same time, the marking itself can be applied in any way that allows you to ensure the clarity and clarity of the image for the period of the product's service life.
In the Russian Federation, marking and drawing up operational documents are carried out in Russian.The use of a foreign language is allowed only in relation to details, units of measurement, trademarks, proper names, localities and other names.
Do I need to apply the EAC sign?
In accordance with the current legislation, products that are subject to confirmation of compliance with the requirements of the technical regulations applied in the territory of the EAEU, and have passed all the assessment procedures established by the technical regulations, must be marked with a single "EAC" address mark . Moreover, the marking with a single circulation mark is applied to the products themselves and the documents attached to them before the products are put into circulation on the EAEU market.
It is important to emphasize that it is not allowed to mark products with the EAC mark, the compliance of which with the requirements of technical regulations is not confirmed. Liability for this action for legal entities in accordance with Article 14.46 of the Code of Administrative Offences of the Russian Federation (Administrative Code of the Russian Federation), provides for the imposition of a fine of 100 to 300 thousand rubles, and if as a result of the above actions, in particular, harm to the life or health of citizens, or property, the fine for legal entities can be from 700 thousand to 1 million rubles.
It should also be noted that many importers often face situations when foreign suppliers refuse to apply the EAC mark on the product for various reasons. It should be noted here that the legislation provides for the possibility of marking already on the territory of the Russian Federation, as part of the customs procedure of a customs warehouse or conditional release of products, in the absence of EAC marking on imported products .
What does the future hold for labeling?
Speaking about labeling, it is impossible not to mention that in the Russian Federation, the practice of mandatory labeling of goods by means of identification is currently gaining momentum in order to ensure the receipt of prompt and reliable information about the movement of goods within the framework of the economic activities of organizations . The introduction of this practice is considered as a tool to counteract the turnover of counterfeit and falsified products and is largely determined by the policy to combat illegal trafficking of industrial products, build a "healthy" competitive environment and improve tax discipline .
The implementation of the system of traceability of goods when they move through the commodity distribution network is provided through an information control system based on the unified national marking system "Honest Sign". Identification of each unit of the product is carried out by assigning a unique digital code DATA MATRIX, scanning which you can get all the information about the product.
Currently, mandatory identification marking is applied to clothing, shoes, medicines, perfumes, tobacco products and some other goods, the turnover of which, according to the government, is most associated with counterfeiting and falsification . From the point of view of electronics, mandatory identification marking currently applies only to cameras, flashlights and flash lamps, but a unified national marking system should cover all industries in accordance with the government's strategy to combat illegal trafficking in industrial products in Russia, so in the future we should expect an expansion of the list of products subject to mandatory identification marking.
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