Which goods are “label-controlled goods”
Section 30 of the Consumer Protection Act B.E. 2522 (1979) makes two groups of goods label-controlled by operation of law.
- Goods produced for sale by a factory under the factory law
- Goods ordered or imported into the Kingdom for sale
In addition, the Label Committee may designate further categories of goods as label-controlled. The B.E. 2565 (2022) notification groups them into 8 categories: household appliances, personal items, paper and stationery, electrical appliances and equipment, vehicles and equipment, agricultural goods, construction materials, and others.
In short, if the goods are imported for sale or made by a factory, assume that they must carry a label under this law.
What the label must show
The Label Committee Notification on the Characteristics of Labels for Label-Controlled Goods (No. 3) B.E. 2565 (2022), in force since mid B.E. 2566 (2023), sets out the following items.
- The name of the type or kind of goods
- The name or trademark of the manufacturer, registered in Thailand
- The name or trademark of the person who ordered or imported the goods, registered in Thailand
- The country of manufacture, for imported goods
- The address of the manufacturer or importer
- Size, dimensions, quantity, volume or weight, as applicable
- Directions for use
- Advice on use or storage
- Warnings, prohibitions on use, or precautions
- The day, month and year of manufacture
- The day, month and year of expiry, or the best-before date, for goods with a shelf life
- The price, stated in Thai baht
Details that are often got wrong
- Warnings must be in a larger typeface than the general text and in a colour that contrasts with the label background.
- Dates are given in day, month, year order, using either the Buddhist Era or the Christian Era. If the exact date of manufacture cannot be stated, week and year, or month and year, may be used.
- Character size must be at least 2 millimetres, or 1.5 millimetres if the label area is less than 35 square centimetres.
- Price must be in Thai baht. Another currency may be shown in addition.
The text on the label must include Thai. A foreign language may appear alongside it. Some product types, such as plastic products, ride-on toys with wheels and personal computers, have specific notifications that require additional statements, so check whether your product has one.
Section 31 also sets the general rule that the statements on the label must be true and must not mislead in any material way about the goods.
Who is liable
Section 52 penalises anyone who sells label-controlled goods with no label, or with a label, or a display of the label, that is incorrect, where they know or ought to know of it.
| Offender | Penalty |
|---|---|
| An ordinary seller, including retail shops and online sellers who buy goods to resell | Imprisonment of up to six months, a fine of up to one hundred thousand baht, or both |
| A manufacturer, or a person who orders or imports goods for sale | Imprisonment of up to one year, a fine of up to two hundred thousand baht, or both |
Many older articles still cite a fine of fifty thousand baht. That figure does not match the current rate.
Retailers are not exempt. The offence applies only where they know or ought to know. A shop that takes in imported goods to sell should therefore check the label when it receives the goods and have the distributor warrant in the contract that the label is correct.
If the statements on a label are false or misleading intentionally, there is a separate offence under Section 47, punishable by imprisonment of up to six months, a fine of up to one hundred thousand baht, or both, with heavier penalties for repeat offences. Besides criminal penalties, the Label Committee can order the label to be corrected or sales to stop.
Selling online
An online seller who orders goods from abroad to sell is an importer under this law. They must attach a Thai label showing their own name and address before sending the goods to the customer, and they face the importer's penalties.
Points to know
- We have found no notification requiring every label item to be shown on the online shop page. The main duty is that the goods delivered to the buyer carry a correct label.
- Statements on the shop page, images and live-selling sessions are advertising. If they are false or misleading they may also be an offence under the consumer protection law, so the shop page should match the real label.
- The law on prices of goods and services requires the price to be displayed. Show the price clearly on the shop page as well.
If sales have grown to the point where you need to manage imports, tax and liability systematically, see When an online seller should move from an individual to a company
Products with their own labelling laws
Some product groups have specific laws with more detailed labelling rules, and require a licence or notification before sale. Check that specific law first, then see whether the Label Committee's notification exempts that product.
- Food and food supplements: the label must match what was approved. See Thai FDA registration for food, supplements and medical devices
- Cosmetics: the label must show the statements required by the cosmetics law and be in Thai. See Cosmetic notification: who should be the holder
- Goods subject to a mandatory TIS standard (มอก.): they must carry the standard mark and be made or imported by a licensed person. See Does your product need a TIS mark, and who is liable if it does not meet the standard
- Drugs, medical devices and hazardous substances: each has its own specific law.
Imported goods: how to set up your labelling
The duty under Section 52 arises on sale, so an importer should finish the Thai label before the goods leave the warehouse for the seller or buyer.
- Importer's name and address: the label must show the legal entity that actually imports the goods, not a brand name or shop name.
- Country of manufacture: it should match the import documents. A mismatch can become an issue if Customs audits after clearance.
- Thai stickers: a sticker placed over or added to the original must be firmly attached, easy to read, and must not cover the manufacturer's original warnings.
- Contract with the foreign manufacturer: require the manufacturer to supply correct information on ingredients, directions for use and warnings, and to be liable if the information is wrong.
- Contract with the distributor: state who prepares the label, who is liable if the label is wrong, and who is the importer under the law.
Checklist before putting goods on sale
- Check whether the goods are label-controlled or fall under a specific law such as food, cosmetics or a mandatory TIS standard.
- Check whether a specific labelling notification exists for that product type.
- Prepare a complete Thai label with all 12 items that apply to the goods.
- Check character size, warnings and date format.
- Use the name and address of the real importing legal entity, and a country of manufacture that matches the import documents.
- Make the online shop page and advertising match the label.
- Include a label warranty in the contracts with the manufacturer and distributor.
- Keep the original label files for each batch, with the date each began to be used.
