Product information, user instructions and warnings
Product information, user instructions and warnings
User instructions will guide the consumer in how to use the consumer product safely and as intended by its manufacturer. However, risks in consumer products must be eliminated primarily by product design, as the instructions for use are only a secondary means of reducing risks.
Instructions and warnings relevant to safety must be provided consistently and in the order in which the consumer is supposed to act. User instructions must be provided to the consumer in paper format, but they can additionally be provided in electronic format.
Instructions and warnings can lead consumers to realise that the consumer product is not suitable for everyone. For example, products that appeal to children but are not intended for them should be labelled with a warning to keep the product out of the reach of children. Furthermore, products that are not suitable for children must not be designed to appeal to children.
The manufacturer makes the user instructions for the consumer product. The importer and distributor check the user instructions, and that they contain clear and understandable instructions relevant to safety in Finnish and Swedish. The information can also be provided by means of commonly known symbols, provided that the use of such symbols does not impair safety. If the instructive and warning symbols may be strange for consumers, you must also include text.
Providing information and labelling
The information concerning general consumer goods is regulated by the Consumer Safety Act (920/2011) and the information decree (613/2004). Other legislation may impose additional requirements for the information related to consumer goods, and the provision of information on products subject to specific legislation may be specified in that specific legislation.
Before purchasing a product, the consumer must be able to assess whether the product can be used safely and is suitable for the use for which they need it. The consumer therefore needs information about the product.
Information you must provide for consumer goods:
- name of the manufacturer, commissioner or importer
- current trade name according to commercial practice
- a generic name such as “ruler” or “handsaw”. If it is obvious what the consumer product is, you do not need to provide the name according to commercial practice. For example, an unpackaged ruler is clearly a ruler by visual examination.
- The trade name must not convey a false impression of the consumer product to the consumer. For example, you should not name a dish that is unsuitable for heating food as a baking dish, because it gives the wrong impression to the consumer about the dish being suitable for heating.
- You cannot use the commercial name to circumvent the requirements of specific legislation by calling a product something it is not. For example, a decorative lantern should not be called a storm lantern.
- The description of the product’s characteristics in its commercial name may also affect which legislation applies to the product. For example, a reflective beanie must meet the requirements for personal protective equipment, because the product name indicates that it is also a reflector.
In addition to the above, the consumer product must be accompanied by the relevant information for its safe use. The operator must assess what information the consumer needs to use the product safely. The information decree contains a non-exhaustive example list of information which, depending on the product, may be relevant for safety and the prevention of risks:
- information on the composition of the consumer product
- information on the content amount
- The amount of content may be useful information for safety reasons when assessing whether there is enough first-aid or emergency equipment, for example.
- the production lot identifier or other information necessary to identify or trace the consumer product if required
- There may be errors in the manufacture of the product, in which case the lot identifier will distinguish the non-compliant lot from other lots.
- instructions concerning the assembly, installation and other similar aspects for the consumer product and a mention in case the assembly, installation or other similar work requires sufficient qualifications or other professional skills
- Example: When placing a hot tub heated by burning wood, you must pay attention to fire safety.
- instructions for the use and storage of consumer goods
- Example: Protect from light.
- warning labels and instructions for any necessary personal protective equipment for the safe use of the consumer product
- The warning labels must be clearly distinguishable from other information such as assembly instructions or marketing materials.
- For example, the consumer must be instructed to wear hearing protectors where appropriate.
- instructions for the maintenance, washing, cleaning and care of the consumer product
- instructions for the removal and disposal of consumer goods
- Example: Recycle as plastic.
- information about any dangers related to the use and disposal of the product.
- Example: Do not dispose of by burning.
It is not enough to display this only on the store shelf or in the online store. The consumer must also be advised to keep the information necessary for preventing the risk that the product poses if the information is not on the consumer product.
The information must be on the consumer product or on the packaging if it cannot be read without opening the packaging. The information can be provided on a separate note attached to the consumer product if
- the package is too small to provide information
- the package is unsuitable for the provision of information
- there is no package.
In the case of very small bulk goods, it may be sufficient that consumers can see the information in the immediate vicinity of the goods at the point of sale, and that the information is provided to the consumer on a separate note at the time of purchase.
The information must be clearly provided with the product in Finnish and Swedish, as required by the Language Act (423/2003). The consumer must be able to read the information easily and without the aid of any tools. The font size and type and the colour differences in the background affect the clarity of the text. The more important the information is in terms of safety, the more visible and clear it must be.
The information provided must not mislead the consumer into using the product in a way for which it is not appropriate. For example, unfounded protection claims on face masks can be a risk to the user if the mask does not reach the performance level required for personal protective equipment.
Products in an online store are subject to the same information requirements as other consumer products. In the online store, the information must be provided before ordering, and it must be presented in connection with the consumer product. General consumer goods from outside the EU are subject to the same labelling requirements as those produced within the EU. Information must also be provided on second-hand and free-of-charge consumer goods such as promotional gifts and giveaways.
You do not necessarily need to indicate the country of origin of the general consumer product, but consumers are often interested in this. For more information about consumer rights, visit the website of the Finnish Competition and Consumer Authority www.kkv.fi.
The CE marking may be affixed only if required by EU law. Consumer products covered only by general consumer safety legislation cannot bear the CE marking.
For more information about the CE marking, please go to the Tukes website, and for more information about legislation regarding specific product groups that require CE marking, see the Commission’s website.
In addition to the name of the manufacturer, the party for whom the product was manufactured or importer, it is strongly recommended that the lot number on the consumer product or another means of identifying the product and its production lot be included.
Errors that cause a serious risk can occur during the production and because of that the consumer goods needs to be withdrawn from the market or even recalled from the consumers. In such a situation, it is useful if the product or its packaging carries some traceability information to distinguish it from other similar products. In this case, depending on the hazard, the measures can be limited to a specific production lot. If a defective lot cannot be distinguished from other lots, the measures may need to be extended to all produced lots.