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Each tier of label language rules costs more than the last
Whether a label needs translating is usually treated as a small decision. Lined up by what it costs to get wrong, the rules fall into five tiers of quite different character, from no legal requirement at all to a local language that has to outshine every other. This walks them one by one, and names the document behind each.
The same goods, a different threshold
In export conversations, whether the label needs translating tends to get filed as a small thing: find a translator, print a sticker, put it on. Line the requirements up by destination market, though, and they fall into tiers of quite different character. What separates them is not how hard they are, but what it costs to get them wrong.
These tiers are about compulsion, not consumer preference. A brand is free to speak whichever language it likes; what the legally required label information must say, and whether English alone will do, is settled by hard rules in each market. Each tier below is costlier than the one before.
The loosest tier: no legal language requirement
The loosest tier is a destination market with no legal language requirement on product labels, where the choice of language is left to the brand's judgement. Here an exporter's language cost is close to zero, because the original packaging ships as it is.
One caveat belongs here. This is a negative category, and saying a country has no requirement is hard to evidence, because what you have to prove is the absence of a rule. So no market is named in this tier. What can be said is that the tier is shrinking: over the past decade more markets have written label language into law, not fewer.
Technical files and instructions are two different things
One tier in, the compulsion covers only part of the product paperwork, and this is the tier most often described too loosely. The real dividing line is between technical documentation on one side and instructions and safety information on the other.
Take the EU's ATEX Directive 2014/34/EU. The directive requires manufacturers to draw up technical documentation, and nowhere prescribes a language for it. For instructions and safety information, the wording is different: the product must be accompanied by instructions and safety information in a language easily understood by end-users, as determined by the Member State. The word English does not appear anywhere in the directive.
So the saving at this tier is bounded. Material that goes to regulators and professional customers usually carries no language requirement and can be saved on; instructions, safety information and warnings, which end users actually see, are not in that group, and the decision on language sits with each Member State. Treating the two as one job is the usual error here.
One aside: this tier is often illustrated with the claim that technical documentation and declarations of conformity may be in English. Against the ATEX text, that claim does not hold. The directive neither says English is acceptable nor leaves instructions and safety information to the manufacturer's choice.
The destination language has to be there
One tier further in, the rule turns on an or: the destination language alone is acceptable, and English alongside it is acceptable, but at least one of them has to be the destination language. For an exporter that or amounts to a must.
South Korea: food labelling must be in Korean. Chinese characters or foreign languages may appear alongside, but not in a larger size than the Korean; imported foods may use a Korean sticker, provided it does not cover key information such as nutrition on the original packaging, and the exporting country and manufacturer may be shown in their own language on that sticker.
Japan: food sold in Japan must be labelled in Japanese, as the Consumer Affairs Agency states. The legal consequence of non-compliance is Article 5 of the Food Labelling Act, under which operators may not sell food that is not labelled in accordance with the food labelling standards. One clarification matters here: the Japanese-language requirement comes from the agency's official rule, not from a provision of the labelling standards themselves, whose text contains no such wording.
Saudi Arabia: labelling and adjoining explanatory statements must be in Arabic, and where another language is used it must sit alongside the Arabic, with the content identical to the Arabic.
United States: statutory label information must be in English, with the checkable anchor being the food labelling rule at 21 CFR 101.15. The claim needs narrowing, though: there is no single US label language rule covering all products, and each product class has its own. So before asking whether the US needs English, establish which class of product is in question.
Brazil: Article 31 of the Consumer Protection Code requires information on products or services to be provided in Portuguese, and to be correct, clear, precise and prominent.
Switzerland: mandatory information on prepackaged food must be in at least one federal official language, which means any one of German, French or Italian will do.
The trade meaning of this tier is that language compliance is a fixed cost with no room to negotiate. The usual fix is an overlay label, and overlays carry one hard constraint: they must not cover key information on the original packaging. That constraint is often discovered only after the goods are in a destination warehouse.
Where two languages are required at once
One tier tighter, the rule changes from or to and: several languages must all be present, and the cost moves up with them.
Belgium: mandatory particulars must be at least in the language or languages of the linguistic region in which the products are placed on the market. In practice that means French at a minimum in the French-speaking region, Dutch in the Dutch-speaking region, both in bilingual Brussels, and German in the German-speaking region. Selling only within one linguistic region means only that region's language is needed.
Finland: mandatory labelling on food sold in Finland must be in the country's official languages, Finnish and Swedish. The authority has answered the obvious follow-up question directly: English alone is not enough.
Switzerland is often listed in this tier, and the ordinance says otherwise. The Swiss ordinance on foodstuffs and consumer products requires at least one federal official language, not all three, and the exemption for selling within a single language region does not appear in the federal ordinance at all, because requiring at least one already permits German alone or French alone. This is the correction most worth remembering from this article: a claim that circulates widely in the trade does not match the text.
The strategy follows plainly. If you cannot confirm where the goods will finally be sold, produce versions in every language the market requires. If you bet on one language region instead, think through what channel leakage means, because the moment stock crosses into another language area, the label is non-compliant.
The local language has to lead
The last tier is stricter than must be present: the destination language has to lead, in both visual prominence and accessibility. Quebec in Canada is the most extreme rule of this kind.
Under Article 51 of the Charter of the French Language, any marking on the product, its container or its packaging, and on documents or objects accompanying the product including instructions and warranty certificates, must be in French. French may be paired with one or more translations, but no marking in another language may be more prominent than the French, nor accessible on more favourable conditions. That second half is the part people miss: it governs availability, not just apparent size.
Trademarks may be exempt, but with a condition. Where a trademark has no corresponding French version in the Canadian trademarks register, it may be drawn up, even partly, in a language other than French; but if the trademark contains a generic term or a description of the product, that part must appear in French on the product or on a medium permanently attached to it. The regulation also requires that the French version be available under conditions of accessibility and quality no less favourable than the version in the other language.
What this tier means is that overlaying a French label does not solve it. If the English information on the original packaging stands out more than the French by position, size or colour, or if a consumer has to turn the pack over to find the French, it is non-compliant. The packaging may need redesigning, rather than a sticker over the old box.
Lined up by cost
Read across all five tiers, the compliance cost at each one looks roughly like this:
| Tier | Requirement | Typical cost | Markets |
|---|---|---|---|
| Open | No legal requirement | Very low | A few markets, unnamed, for the reason given above |
| Technical files | Usually no language prescribed; instructions and safety information excluded | Low, but nothing saved on instructions | EU product law, such as ATEX |
| Destination language required | The destination language must appear, at least one | Medium: translation plus overlay labels | Korea, Japan, Saudi Arabia, US, Brazil, Switzerland |
| Several languages | Two or more required at once | High: multiple label versions | Belgium, Finland |
| Local language leads | It must outrank other languages in prominence and accessibility | Very high: packaging may be redone | Quebec |
Three lines cover the table: whether English will do is a cost question, whether the local language is needed is an access question, and whether the local language stands out enough is a design question. They land at different points in the purchasing process, and the one that lands latest, redoing the packaging, changes tooling and plate costs rather than the price of a sticker.
What to ask before you order
Label language comes down to a concrete question: can this supplier produce the label to the language rules of our target market. That tests supplier capability, and it can be asked in concrete terms. Have they shipped to this market recently and kept samples; who produces the label artwork and text, and who owns it; if an overlay is needed, can they guarantee it covers neither the product name nor the shelf life; and have they produced multilingual packaging before, and how do they prevent channel leakage.
Add the most useful question of the lot: ask them to find the wording of the target market's language requirement and point to the provision it comes from. A supplier that can do that usually already knows which version of the packaging will fail, and one that answers only that this is how they have always done it carries a risk that sits less in the label than in how well they know the destination market.
To work through these in order, start with the free verification checklist. This article covers the language on the label; one toy, ten markets covers the standards the product itself must pass, and the two often block a shipment together. To see how certifications and export markets are recorded in a report, look at a report sample, or get in touch.
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