Buying private label food supplements from a manufacturer in another EU country

Status as of 20 October 2026. This guide is for businesses anywhere in the EU that want to buy finished food supplements under their own brand (private label) from a manufacturer in another member state. Where we give country examples, they come from Slovakia and Czechia.

Can you sell a supplement made in another EU country in your country

Yes, in principle. Goods lawfully marketed in one member state can move freely in the EU (Articles 34–36 of the Treaty on the Functioning of the European Union). The Food Supplements Directive also says that member states must not restrict trade in food supplements that comply with it for reasons of composition, presentation or labelling (Directive 2002/46/EC, Art. 11(1)).

The limit is that food supplement law is only partly harmonised. Where there are no EU rules, national rules still apply (Art. 11(2)). So the product has to fit the rules of each country where you sell it, not only the rules of the manufacturer’s country.

What is harmonised in the EU and what is national

The list of permitted vitamins and minerals, labelling and health claims are set at EU level. Maximum amounts, many plants and other substances, notification and the label language are largely national.

On maximum amounts, the European Commission states that no proposal has yet been presented because of the complexity of the issue and divergent views.

Example: N-acetylcysteine in Czechia

Czech Decree No. 58/2018 Coll. lists plants and substances that must not be used in food supplements (Annex 2). N-acetylcysteine is one of them. Annex 1 sets maximum daily amounts for selected plants and substances, for example 60 mg of Ginkgo extract or 100 mg of Rhodiola.

A formula sold lawfully in another member state may therefore not be suitable for the Czech market. Other countries have their own lists. Before you order, check the formula against the rules of every country where you plan to sell.

What mutual recognition does and does not do

Mutual recognition helps, but it does not remove national checks. Under Regulation (EU) 2019/515, an authority in your country may assess whether a product lawfully marketed in another member state can be sold there.

• You can support the assessment with a voluntary mutual recognition declaration (Art. 4).
• While the assessment runs, you can normally keep selling unless you receive a decision restricting market access (Art. 5(3)).
• The authority may suspend sales temporarily if the product poses a serious risk to health (Art. 6).
• Each member state has a Product Contact Point that gives free advice on mutual recognition.

Notification is handled country by country. Portugal and Greece, for example, state that a product must be notified even if it is already on the market in another member state, and the Slovak authority states that the obligation applies even if another operator has already notified the same product.

Who is responsible for the product

The business under whose name or brand the supplement is sold. For private label, that is usually you.

Under Regulation (EU) No 1169/2011, Art. 8(1), the food business operator responsible for food information is the operator under whose name or business name the food is marketed. As the brand owner you are responsible for the label, for claims and advertising, and usually for notification in your country. The manufacturer is responsible for the product matching the agreed formula and specification.

Two more obligations apply to you as a food business operator:

• Registration. Every food business operator must notify the competent authority of each establishment under its control so that it can be registered (Regulation (EC) No 852/2004, Art. 6(2)). How a brand without its own warehouse registers differs by country; Slovakia, for example, requires registration even without a warehouse or shop. Ask your local authority.
• Traceability. You must be able to identify who supplied you and to whom you supplied the products (Regulation (EC) No 178/2002, Art. 18). Record the lot numbers you receive and sell.

Do you have to notify the product in your country

In most EU countries, yes: before or at the latest when you first place the product on that market. When we checked on 19 October 2026, 21 of the 27 member states required it for each product. A notification in the manufacturer’s country does not cover yours.

What you submit is usually the label or the label text in the national language, sometimes with a form and a fee. Our guide Food supplement notification in the EU explains the procedure and has an overview by country.

Which language must the label be in

Mandatory food information must appear in a language easily understood by consumers in the member state where the food is marketed. Each member state may require one or more of the official EU languages (Regulation (EU) No 1169/2011, Art. 15(1) and (2)). In practice, use the official language or languages of each country where you sell.

• Several languages are allowed (Art. 15(3)). One multilingual label can serve several markets if every required language contains all mandatory particulars.
• Minimum font size still applies: an x-height of at least 1.2 mm, or 0.9 mm if the largest surface of the pack is less than 80 cm² (Art. 13 and Annex IV). This limits how many languages fit on a small pack.
• Online sales: mandatory information must be available before the purchase is concluded (Art. 14), in the language of the market you sell to.

What the label must contain is explained in Food supplement label requirements, and the rules for claims in Health claims on food supplements.

How VAT works when you buy from another EU country

If you give the supplier a valid VAT number from another member state, the supply is generally VAT-exempt for the supplier, and you account for VAT in your own country.

• Supplier’s side. A supply of goods transported to another member state is exempt when the customer is a business identified for VAT in a member state other than the one where transport begins and has given the supplier this VAT number (Directive 2006/112/EC, Art. 138(1)). The supplier reports the supply in its recapitulative statement (Art. 138(1a)), and the invoice refers to the exemption (Art. 226(11)).
• Your side. Your purchase is an intra-Community acquisition taxed in your country (Art. 2(1)(b)). You declare it in your own VAT return under national rules, which is often called reverse charge.
• Check the VAT number in the Commission’s VIES service before ordering.
• No valid VAT number yet? Then the supplier usually charges VAT at the rate of its own country.

There are exceptions and national details. If you are unsure, ask your tax adviser before the first order.

Delivery and shipment documents

Keep the invoice and the proof of transport, and check whether your country requires you to notify incoming food consignments in advance.

• Proof of transport. For the VAT exemption, the supplier needs evidence that the goods were transported to another member state, such as a signed CMR consignment note or courier documents (Article 45a of Implementing Regulation (EU) No 282/2011, inserted by Regulation (EU) 2018/1912).
• Collection or your own carrier. If you transport the goods yourself, you give the supplier a written statement that you transported them, naming the member state of destination, by the tenth day of the month following the supply (Art. 45a(1)(b)).
• Advance notice of consignments. Some countries require the recipient to report food consignments from other member states. In Czechia, a recipient of food supplements at the place of destination (for example a warehouse or shop) must report the consignment to the Czech Agriculture and Food Inspection Authority (SZPI) at least 24 hours before it arrives (Decree No. 172/2015 Coll.). Ask your authority whether a similar rule applies to you.
• Lot number and date. Check on receipt that each unit carries a lot number and a best-before date, and record them for traceability.

Practical checklist

• Decide in which countries you will sell.
• Check the formula against each country’s rules on plants, other substances and maximum amounts, and check the EU novel food status.
• Register your food business with the competent authority in your country.
• Prepare the label with all mandatory particulars in the language or languages of each market, with claims only from the EU list.
• Notify the product in each country that requires it, before or at the latest when you place it on the market.
• Give the supplier your VAT number and check that the invoice refers to the VAT exemption.
• Agree the delivery address, the shipping method and who arranges transport.
• Report the consignment in advance if your country requires it.
• Keep the invoice, the proof of transport, the approved label and the notification receipt.

If you are starting from scratch, the guide How to start a supplement brand puts these steps in order. Protecting your brand name is covered in Trademark for a supplement brand, and the difference between private and white label in Private label vs white label.

How we can help

We supply private label food supplements, made in the EU (Slovakia), from 25 units per product. Prices are public, in euros per unit, excluding VAT; see the price list and the product catalogue.

• Before you order: tell us where you plan to sell and we will advise you on the formula and the national rules.
• Label: for each product you receive label texts in selected languages, a 1:1 size template and a manual for your designer. Printing and applying your label is optional, at €0.30 per unit; without it, we supply the products unlabelled. See labels.
• Notification: we’ll advise you on the notification and prepare the documents.
• Dispatch: finished products with your label are usually dispatched within 3–5 working days of receiving your label artwork, if the product is in stock.
• Delivery: we deliver across the EU. Shipping costs are always confirmed before payment. Details are in the delivery and payment terms.
• VAT: supplies to businesses with a valid EU VAT number in another member state are generally VAT-exempt (reverse charge); we state this on the invoice.

Send us your questions through the enquiry form.