The Label as a Legal Instrument: What Businesses Need to Know About Product Labelling in Georgia

In an era of heightened attention to transparency and consumer rights, a label is no longer merely a design element on packaging. Today, it is a legally significant information carrier that influences not only consumer choice but also the manufacturer’s liability.

In Georgia, labelling requirements are strictly regulated, particularly for companies in the real sector of the economy. For marketers, brand owners, and manufacturers, it is not enough to simply “follow the format” — the label must be integrated into the legal and marketing safety framework of the product.

What Is a Label from a Legal Perspective?

According to Georgian legislation, a label is any form of marking applied to a product’s packaging — printed, written, or graphic — including the use of trademarks, trade names, or other visual identifiers.

A label is regarded as a mandatory component of packaging and is governed by several regulatory acts. Its purpose is to provide consumers with complete, accurate, and accessible information about a product, essential for its safe and informed use.

What Information Must Be Included on the Label?

Labelling must include the following:

• Product name
• Composition — a list of ingredients or components in descending order by weight or volume (mandatory for food, cosmetics, chemicals, etc.)
• Manufacturer/importer information — name, address, contact details
• Allergen information and substances causing hypersensitivity
• Net weight
• Production date, batch number, expiration date or minimum durability date
• Nutritional information (if applicable)
• Instructions for use and storage conditions
• Safety warnings (including hazard symbols for chemicals, pharmaceuticals, and other potentially hazardous goods)
• Alcohol content, if above 1.2% by volume

Language of Labelling and Clarity of Information

All products sold in Georgia must include a label in the Georgian language. Additionally, information may be provided:

• in one of the official EU languages;
• in multiple languages, provided the Georgian version is mandatory.

Information must not mislead the consumer regarding the composition, properties, origin, quality, or safety of the product.

Which Products Are Subject to Stricter Regulation?

Labelling requirements vary depending on the product category:

• Food products
• Beverages (including alcohol)
• Household chemicals
• Cosmetics
• Pharmaceuticals
• Products with hazardous properties
• Genetically modified organisms (GMOs)

International Standards to Consider

Many companies engaged in export or B2B sectors also follow international regulations, such as:

• ISO 22000 — food safety standard (includes labelling requirements)
• Codex Alimentarius (FAO/WHO) — global food safety standards
• EU Regulation No. 1169/2011 — European rules on food labelling: composition, allergens, nutritional value, shelf life

Liability for Non-Compliance: From Fines to Criminal Charges

There are three levels of liability for labelling violations: administrative, civil, and criminal.

Administrative Liability

1. Fines:
   • 200 GEL for small businesses (annual turnover up to 200,000 GEL)
   • 400 GEL for other businesses
   • 600 GEL for repeat offences within a year
2. Genetically Modified Products:
   • 5,000 GEL for the first offence
   • 10,000 GEL for repeat violations

Additional penalties may include:

• Withdrawal of products from the market
• Suspension of business operations

Civil Liability

• Claims for damages — e.g. in case of an allergic reaction or misleading information
• Right to return goods and receive a refund for violation of consumer rights

Criminal Liability

In cases of fraud or intentional deception, possible sanctions include:

• Criminal fines
• Imprisonment

What This Means for Businesses

For marketers and brand managers, the label is not just a legal obligation — it is a pillar of brand reputation and consumer trust. A properly designed and legally compliant label:

• Reduces the risk of fines and product bans
• Facilitates transparent market communication
• Demonstrates the brand’s commitment to playing by the rules

Legal Support: What Experts Can Do

If your product is entering the market or you are uncertain about the accuracy of current packaging, it is worth conducting a labelling audit. Lawyers and consultants specialising in product regulation in Georgia can help:

• Verify compliance with requirements
• Adjust labelling formats
• Prepare for ISO 22000 certification

A label is a bridge between the brand and the consumer — and in today’s world, it must be not only attractive but legally sound. If you have questions, the legal team at REVERA Georgia is ready to assist you.

Author: Nino Zautashvili 

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