Labelling, claims and in-house printed materials

Plain-language summary

Labels must be legal in the country of sale, every claim must be provable, and anyone printing their own labels needs artwork and print controls.

What the clause is really asking

A safe product with the wrong label is still a recall. The clause requires finished products to be labelled to the statutory and regulatory requirements of the country where they will be sold — allergen and customer requirements included — and, where product is unlabelled, that the information needed for safe use still reaches the customer. Any claim on the pack (allergen, nutritional, method of production, chain of custody, raw-material status) must be validated and then verified, with traceability and mass balance to prove the claim holds. If you print labels or printed materials yourself, you need artwork management and print control: master approval, change control including obsolete artwork, approval of each print run, error detection during the run, segregation of variants, and accounting for unused printed product.

What auditors look for

Auditors take an export product and check the label against that country's rules, not yours. They pick a claim — 'gluten free', 'organic', 'RSPO' — and ask for the validation and the mass-balance reconciliation. On an in-house print line they ask for the master, the run approval and what happened to the leftover labels.

Typical evidence

Label legality review per country of sale; claim validation and verification records incl. mass balance; artwork master approvals; print-run sign-offs; artwork change control and obsolete-artwork disposal records; unused-label reconciliation

How to comply — recommendations

Keep a label register per market with the regulatory review date. Treat every claim as a control: define what proves it, how often, and who reconciles the mass balance. On the print line, make the master sample physical and signed, and count labels out and back — the reconciliation is what stops a mixed-variant recall.

Common nonconformities

Labels checked against home-country rules only; claims with no validation or mass balance; no master sample or run approval on in-house printing; unused or obsolete labels not accounted for

Resources for this clause

• ArticleFSSC 22000 Version 7 explained: what changed, the dates that matter, and how to prepare for the upgrade audit
• Free downloadFSSC 22000 V7 Gap ChecklistEvery change from FSSC 22000 Version 6 to Version 7 as a tracked project — V6 audits end on 30 April 2027, and this is the file that gets a site to its upgrade audit with the evidence ready.
• Free masterclass · ~18 minFSSC 22000 V7 MasterclassV6 audits end 30 April 2027. Every V7 change clause by clause — the new ISO 22002 family, allergen testing, culture evidence, fraud/defence competence, food loss & waste targets — and a 90-day plan.