Approve an EU-bound bulk tea label only after the buyer fixes the package's legal role, destination countries, responsible operator, product master and language set, then reconciles the signed artwork version with the printed pack and shipment documents. A supplier can print buyer marks, but the importer or brand owner should not release printing from an English mock-up or assume that a bulk sack follows the same information route as a consumer pouch.
Classify the pack before writing the label
Start with the exact unit being sold and who will receive it. Regulation (EU) No 1169/2011 primarily governs food information for foods intended for final consumers and mass caterers. Its Article 8 also controls information as food moves between businesses.
- Consumer prepack: a sealed pouch, carton or tin presented as such to the final consumer normally needs the applicable Article 9 particulars on the package or attached label, subject to the Regulation's exceptions and any food-specific or national rules.
- Prepacked food moving before retail: in the Article 8(7) situations, mandatory particulars may be on the prepack or qualifying commercial documents, but the external packaging must still show the food name, date marking, special storage/use conditions and responsible operator.
- Food not intended for final consumers or mass caterers: Article 8(8) requires the supplying business to give the receiving business enough information to meet its own obligations. This is an information-transfer duty, not permission to send an anonymous sack.
- Non-retail container as a trade model: Codex CXS 346-2021 expects the food name, lot identification, date/storage information where needed, non-retail identification and a business name/address on the container, with other traceable information supplied in documents or electronically. Codex is a voluntary international reference unless applicable law or contract adopts it.
Keep the requirement layers explicit. EU and Member State law is binding within scope. A voluntary standard such as Codex CXS 346 supports a common control model. A trade reference such as a grade code or barcode identifies an item but does not prove legal accuracy. A buyer specification defines the desired label fields and evidence. The contract allocates artwork supply, approval, printing, change notice, inspection and remedy; it cannot remove a legal duty.
Build one label-control sheet per market and pack
| Control field | Approval evidence | Release question |
|---|---|---|
| Market and pack role | Destination Member State(s), sales channel, final consumer/mass caterer/B2B status and pack hierarchy | Which rules apply to this physical unit? |
| Product identity | Legal or customary food name, tea type, grade/style, composition and intended use | Does the wording describe the actual product without misleading? |
| Mandatory copy | Applicable Article 9/10 particulars, exceptions, food-specific rules and justified national additions | Is every required field present in the correct place? |
| Language set | Market-approved language list, controlled translation and local regulatory review | Can consumers or business recipients understand the required information? |
| Traceability | Supplier item, buyer SKU, lot-code syntax, date format and document cross-reference | Can the printed unit be linked to the lot and master data? |
| Presentation | Artwork dimensions, x-height check where applicable, contrast, visibility and indelibility | Will folds, seals, labels or graphics hide required text? |
| Claims and symbols | Evidence owner, permitted wording, certification authorization and barcode/GTIN decision | Is every voluntary element supported and current? |
| Version and approval | Artwork ID, revision, effective lot/date, approvers, printer proof and obsolete-stock disposition | Is this the only version authorized for production? |
Use an eight-step artwork approval method
- Name the legal and operational owners. Record the EU food business operator responsible under Article 8, the brand owner, importer, translator, regulatory reviewer, supplier artwork contact and printer. Decide who may approve content versus colour or print quality. A supplier's signature should not be mistaken for the importer's legal review.
- Freeze the product master. Lock the tea identity, composition, net quantity, pack count, intended use, shelf-life basis, storage conditions, origin position, lot syntax and responsible-operator details. For flavoured or blended tea, use the site's ingredient declaration checklist; for an origin or grade claim, use the authenticity verification plan. Artwork cannot resolve an unsettled formula.
- Create a requirement matrix, not a universal EU label. Review Regulation 1169/2011, food-specific Union acts and each destination's permitted national measures. Article 9 lists the general consumer-pack particulars, but exceptions matter. For example, Article 19 can exempt certain single-ingredient foods from an ingredient list, and Annex V includes specified teas and infusions in its nutrition-declaration exemptions under stated conditions. Do not extend an exception to a flavoured, sweetened or otherwise different product without checking the exact text.
- Translate from one controlled source. Article 15 requires mandatory consumer information in a language easily understood where the food is marketed, and Member States may require one or more official EU languages. Translate the approved legal copy, not a screenshot. Have a qualified reviewer compare names, ingredients, allergens where applicable, dates, storage instructions, quantities and claims back to the source. Record who reviewed each language and when.
- Separate copy approval from layout approval. First approve a text-only copy deck. Then place that exact revision into artwork. For consumer packs, verify conspicuous placement, legibility, indelibility, required same-field-of-vision elements and the Article 13 x-height rule: generally at least 1.2 mm, or 0.9 mm where the largest surface is under 80 cm². Measure the final printed size, not a zoomed PDF.
- Run a change-impact decision. Compare every revision with the approved predecessor. Formula, allergen, legal name, net content, responsible operator, origin, certification, language, date coding and pack hierarchy changes may trigger new copy, regulatory review, customer notification, barcode action or stock segregation. GS1's voluntary GTIN Management Standard requires a new GTIN for specified changes such as a declared net-content change; law and trading-partner rules take precedence.
- Approve a physical print proof. The sign-off pack should include the artwork PDF hash or locked file, dieline, colours, materials, variable-data areas, barcode verification where used and a printed proof at actual scale. Check folds, seams, adhesive, abrasion, date/lot print contrast and whether the label remains attached through normal handling. Link packaging suitability to the food-contact packaging specification and performance test plan.
- Release the shipment by three-way match. At packing, compare the current approved artwork to a first-off printed unit. At pre-shipment inspection, match product/SKU, lot, date, net quantity, language, unit count and marks to the purchase specification, packing list and lot records. Use pass only for an exact current-version match; hold/clarify for a correctable discrepancy; and stop for wrong market, formula, allergen, claim, operator, lot or obsolete artwork.
Common buyer mistakes
- Calling every shipping sack a consumer prepack, or assuming every B2B pack is outside food-information law.
- Using an English master in a market that requires another language without a documented local check.
- Letting translators rewrite legal meaning or convert dates and decimal punctuation inconsistently.
- Copying a nutrition or ingredient exemption from pure tea onto a different formulation.
- Treating a grade, barcode, organic logo or origin graphic as self-validating evidence.
- Approving a PDF on screen without measuring the final print, contrast and obscured areas.
- Changing net content or formula while retaining obsolete artwork, SKU data or GTIN.
- Sending the printer an editable file without a revision ID, hash or named approver.
- Checking one sample pack while the shipment contains mixed languages, lots or artwork revisions.
- Correcting the label but leaving the invoice, packing list, specification or online listing inconsistent.
Practical conclusion
The usable sequence is classify the pack - assign responsibility - freeze product data - map legal copy - validate languages - approve layout - control the version - match the shipment. Maintain one signed label-control sheet per SKU, market and pack level, plus an obsolete-artwork register. Before custom printing, send the tea, destination, pack format, net quantity, buyer mark and controlled artwork brief; the buyer and qualified advisers should make the destination-law decision before production is released.
Sources checked 7 September 2026: the in-force Regulation (EU) No 1169/2011, consolidated 1 April 2025, especially Articles 7-9, 12-15, 19, 26 and 36-39 and Annex V; the European Commission pages on mandatory food information and language and presentation; Codex CXS 346-2021 on non-retail food containers; and the voluntary GS1 GTIN Management Standard, release 1.1 (September 2023). Check current Union, Member State and customer requirements for the actual tea and pack before approval.
