"Made in" rules for the EU: what counts and what does not
There are no harmonised EU rules on when a product can carry a "Made in" claim. The rules come from customs law, national regulations, court rulings and the Unfair Commercial Practices Directive — and they do not always agree. Here is what applies.
"Made in Germany." "Made in Italy." "Made in France." These claims carry significant commercial value in the EU — consumers associate them with quality, craftsmanship, and reliability. But there are no harmonised EU rules on when a product can carry a "Made in" claim. The rules come from customs law, national regulations, court rulings, and the Unfair Commercial Practices Directive, and they do not always agree.
This guide explains what "Made in" means in EU law, when you can use it, when you cannot, and how to avoid claims that could be challenged as misleading.
There is no single EU "Made in" law
This is the starting point that surprises most sellers. Unlike the United States (which has FTC rules on "Made in USA"), the EU has no single regulation that defines when a product can carry a "Made in [EU country]" label.
Instead, the concept is governed by:
Customs origin rules — the Union Customs Code (Regulation (EU) 952/2013) determines non-preferential origin based on where the product underwent its last substantial transformation. This is a customs concept, not a consumer-labelling rule, but courts and authorities often reference it as the benchmark.
The Unfair Commercial Practices Directive — Directive 2005/29/EC (as amended by EmpCo) prohibits misleading consumers about the geographical origin of a product. A "Made in" claim that does not reflect the actual origin of manufacture is a misleading commercial practice.
National laws — some Member States have national rules or case law on origin claims. Italy, for example, has Law 350/2003 which makes it an offence to stamp "Made in Italy" on goods not substantially made in Italy. France has similar protections around "Fabriqué en France."
Sector-specific rules — certain product categories (food, wine, agricultural products) have specific EU origin labelling rules that supersede general principles.
What "last substantial transformation" means
The customs concept of origin — last substantial transformation — is the most commonly applied test for "Made in" claims. Under this test, the country of origin is where the product last underwent processing that was:
- substantial — not merely minor finishing, packing, labelling, or assembly of pre-made components;
- economically justified — not performed solely to obtain a particular origin;
- resulting in a new product — or representing an important stage of manufacture.
Examples
| Process | Origin claim | Valid? |
|---|---|---|
| Raw materials from Country A, fully manufactured in Country B | Made in B | ✅ Yes |
| Fabric woven in Country A, garment cut and sewn in Country B | Made in B | ✅ Yes — cutting and sewing is substantial transformation for textiles |
| Components manufactured in Country A, assembled in Country B | Made in B | ⚠️ Depends — simple assembly may not qualify; complex assembly with testing and calibration likely qualifies |
| Product fully manufactured in Country A, packaged and labelled in Country B | Made in B | ❌ No — packaging and labelling is not substantial transformation |
| Product manufactured in Country A, only quality-checked in Country B | Made in B | ❌ No — quality inspection is not transformation |
| Product manufactured in Country A, minor finishing (polishing, painting) in Country B | Made in B | ❌ Likely no — minor finishing is usually not substantial |
The grey area is assembly. Simple screwing-together of pre-made parts is generally not substantial transformation. Complex assembly that involves skilled labour, multiple stages, and integration testing may qualify. The answer depends on the product category, the complexity of the assembly, and (in disputed cases) customs or court interpretation.
"Made in EU" vs "Made in [specific country]"
There is a difference between claiming "Made in the EU" and "Made in France."
"Made in the EU" — this claim is less commercially loaded but also less regulated. There is no specific EU rule governing it. The product should genuinely have been manufactured within the EU (last substantial transformation in an EU Member State) for this to be defensible.
"Made in [specific country]" — this is a stronger claim with more scrutiny. National authorities and courts in the named country may apply their own standards. Italian authorities, for example, have prosecuted brands for falsely labelling products as "Made in Italy" when manufacturing was substantially performed elsewhere.
"Designed in" and "Assembled in"
These are not origin claims. They are descriptions of specific activities that occurred in specific places. They are generally permissible as long as they are accurate and do not mislead.
"Designed in Sweden" — permissible if the design work genuinely occurred in Sweden. Does not imply Swedish manufacture.
"Assembled in Germany" — permissible if assembly genuinely occurred in Germany. This is a weaker claim than "Made in Germany" and is appropriate when assembly happens in Germany but manufacturing of components happens elsewhere.
"Crafted in Portugal" — this implies a higher level of manufacturing involvement than "assembled." Use it only if the substantial manufacturing — not just finishing — occurred in Portugal.
The risk comes from using these phrases in a way that creates a misleading overall impression. "Designed in Italy" on a prominently Italian-branded product, without any mention of actual manufacturing origin, could be seen as implying Italian manufacture.
What EmpCo changes
The Empowering Consumers Directive (EU 2024/825), applicable from 27 September 2026, does not specifically address "Made in" claims. However, it strengthens the prohibition on misleading commercial practices — including misleading omissions. If a product's branding, packaging, or listing creates an impression of a particular origin and the actual origin is different, failing to disclose the real origin could be challenged as a misleading omission under the amended Unfair Commercial Practices Directive.
This means: the standard for what constitutes a misleading origin impression is tightening, even if "Made in" labelling rules have not changed.
Practical guidance
If your product is fully made in one EU country
Use "Made in [country]" confidently. Ensure the last substantial transformation occurred in that country.
If your product is made from materials sourced globally but manufactured in one EU country
"Made in [country]" is generally defensible — origin is determined by where the last substantial transformation occurs, not where materials originate. You may optionally add "from imported materials" for transparency, but this is not required.
If your product is manufactured partly in one country and partly in another
Use "Made in [country]" only for the country where the last substantial transformation occurred. If the process is split across countries in a way that makes origin ambiguous, consider "Assembled in [country]" or avoid a "Made in" claim entirely.
If your product is manufactured outside the EU
Do not use "Made in [EU country]" under any circumstances. State the actual country of manufacture if required by the product category or marketplace, and do not use branding or packaging that implies EU origin.
If in doubt
State facts rather than making origin claims. "Manufactured in [country]," "Components from [country], assembled in [country]," or simply providing the manufacturer's address (which implicitly discloses the manufacturing country) are all defensible approaches that avoid the ambiguity of "Made in" claims.
How Regonance helps
Regonance scans product listings for origin-related compliance gaps — including missing country of origin, manufacturer location, and traceability data. When origin information is absent or potentially inconsistent with the product's presentation, the platform flags it.
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Compliance guidance based on published EU regulatory texts and customs origin principles. Does not constitute legal advice. National rules on "Made in" claims vary by Member State.
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Compliance guidance based on published EU regulatory texts. Not legal advice. Consult qualified counsel for your specific situation.