Everything a label must carry to be sold in Mexico, on which panel it goes, what can live in the QR instead of printed, and what it must never say. It is the reference used by the brands and contract manufacturers that produce goods to bring into Mexico through EUM — and the spec for the automatic label checker. Informational content; it does not constitute legal advice.
Before labeling: raw material, finished product, or ingredient?
This is the first mistake to avoid. A B2B input is not labeled the same as a shelf product, and confusing them has real consequences — it was the crux of a customs hold (a raw material treated as if it were a finished pharmaceutical product; see Import and customs). They are three distinct things with distinct rules:
Decision rule:
- Is it sold to another company to manufacture with it? → raw material (identification label, see detail). The rest of this page does not apply.
- Is it sold to the consumer in its final packaging? → finished product — follow this entire page.
- Is it a cannabinoid inside a finished product? → it is an ingredient; see The cannabinoid as an ingredient.
The rest of this page describes the label of the finished product (the consumer one). For the identification label of a raw material, go to raw material.
Label development flow (from definition to approved artwork)
- Product definition — category/class, name, flavor, cannabinoid profile, net content, number of pieces, serving size.
- Identification — SKU, batch number, internal ID.
- Laboratory analysis — Smart COA of the production batch (≤1% THC, ISO/IEC 17025 laboratory).
- QR + CVV generation — the QR links the SKU to the batch COA; the CVV provides per-piece authenticity.
- Design and compliance review — assemble the artwork with the elements below and run the approval checklist.
Mandatory elements of the physical label
Each row cites the class/standard that requires it; seal details live in NOM-051 Seals and the per-class specifics on each product class page.Legal designation — how to name the product
The designation describes what it is, in Spanish, without suggesting effects or medicinal use. Example of the pattern:Gomas masticables sabor cereza adicionadas con cannabinoides(category + presentation + flavor + “adicionadas con cannabinoides”) — it names the product’s food nature, not an effect.
Responsible party in Mexico (foreign brand / contract manufacturing)
When a brand is manufactured abroad and brought into Mexico, the label must declare the responsible party in national territory (importer/distributor) with an address. Example:Distribuido por EXTRACTOS EUM®, S.A.S. de C.V.This connects to import and customs (EUM as importer of record) and to regulatory traceability.
The cannabinoid as an ingredient
When a finished product incorporates a cannabinoid, that cannabinoid comes from a raw material (a distillate, an isolate) that has its own COA. On the finished product’s label, that cannabinoid is one more ingredient, and it is handled this way:- It is declared in the ingredient list in decreasing quantitative order by weight, along with the others (sweeteners, flavorings, etc.). The product’s designation reflects that it is added with cannabinoids (not an effect).
- It does not turn the product into a medicine or a raw material: it is a food (or cosmetic) with a declared ingredient. Its character is defined by the set of ingredients, not the isolated cannabinoid (the same essential character logic that applies at customs).
- Traceability of the ingredient back to its origin: the system links the raw material’s COA to the finished product’s COA (parent COA → source COAs relationship). Thus, from the Smart COA of the product the consumer holds, one can reach the analysis of the input it was made with — the chain “ingredient → its raw material → its batch analysis”. See Smart COA · ingredient traceability.
What goes printed vs what can live in the QR
The printed label must contain all the information the standard requires; the QR adds dynamic information, it does not replace it (unless a standard expressly allows the digital equivalent). The Smart COA QR is the natural place for:- Certificate of Analysis (COA) of the batch and laboratory results.
- Cannabinoid profile · total THC · CBD.
- Safety analysis: heavy metals, pesticides, residual solvents, microbiology.
- Laboratory, analysis date, batch, SKU.
- Authenticity verification (CVV).
Language
All packaging text goes in Spanish: product names and flavors, nutritional information, ingredients, storage, expiration, marketing texts, consumer information, QR instructions, and warnings.Prohibited claims (cross-cutting across all classes)
The product is presented as food, never as a pharmaceutical. Do not use:- Medical claims: pain / anxiety relief, sleep aid, anti-inflammatory, therapeutic language, medical references.
- Effect claims: “fast action”, “stronger effects”, “maximum potency”, “long lasting”, “better experience”.
- Pharmaceutical language: dose, dosage, treatment, prescription, “active dose”.
prohibitedClaims.
For cartridges/containers the language rule also applies (never
“vape/vaporizer/inhale/smoke”; describe as a container without suggesting a mode of use).
Differences by product category
The label skeleton is common; what changes is which seals the nutritional profile triggers and the legends/fields by class:- Gummies / candies / confectionery / chocolates: focus on sugars and calories seals → confectionery.
- Beverages / liquid supplements: thresholds per 100 mL; possible sweetener/caffeine legend → supplements, NOM-051 seals.
- Fats / foods: focus on saturated/trans fats and calories → food/fats.
- Cosmetics: no NOM-051 seals; INCI list in decreasing order, precautionary legends, NOM-141 → cosmetics.
- Cartridge / container: language rule + Smart COA → cartridge-container.
- Raw material (B2B): technical data sheet + COA per batch (not a shelf product) → raw material.
Approval checklist
Before sending the artwork to production:- Legal designation correct and in Spanish, prominent on the main panel
- Complete ingredients, in Spanish, in decreasing order; allergens declared
- Nutritional declaration in Mexican format
- Net content and number of pieces verified (no contradictory weights)
- Correct warning seals per the nutritional profile
- Sweetener/caffeine legend included if applicable
- Mandatory legend by class (e.g. “not a medicine”)
- Expiration date + storage instructions
- Responsible party in Mexico (distributor/importer) with address + country of origin
- Batch number and SKU
- QR tested and link to the COA verified (valid COA ≤1% THC)
- Barcode
- No medical / effect / pharmaceutical claims
- (Cartridge) no vape/inhalation language
- Final compliance review completed
See real examples
- Products with their label, QR, and live COA: EUM store — gummies, supplements, fats, cosmetics, cartridges.
- A real finished-product Smart COA (multi-cannabinoid): coa.extractoseum.com/coa/84971cae.
- Public authenticity verification (CVV): opens when scanning the piece’s QR; see Smart COA.
How the EUM system solves it
The SoTbackend/data/compliance/product_classes.json stores, per class, the seals, legends, mandatory
fields, and prohibited claims. Label Studio —EUM’s label designer— already generates the label:
design with dynamic templates (drag and drop), insertion of QR (Smart COA), CVV,
and barcode, and print jobs. The layer being integrated on top is the automatic compliance
verification: reading the class + the product’s nutritional declaration from this SoT, it (1) computes
which octagons/legends apply, (2) verifies all mandatory fields are present, (3) flags prohibited claims and
cartridge language. A single source feeds docs, Label Studio, and Ara (anti-#1).
Sources
- NOM-051-SCFI/SSA1-2010 (front-of-pack labeling, seals) — see NOM-051 Seals.
- NOM-141-SSA1/SCFI-2012 (cosmetics) · Art. 25 RCSPS (identification/traceability) · Art. 79 LGS Advertising Regulation (claims). Text at LeyesBiblio and DOF.