“Made in Germany” on a supplement tells you where the last substantial manufacturing step happened. It does not tell you where the ingredients came from, and it does not mean a stricter set of rules applied to that product than to one made in Poland, Portugal or Ireland. “EU certified” is even thinner: there is no EU certificate for food supplements, and no authority approves one before it goes on sale. This article explains what the words are legally allowed to mean, what the law actually requires of every supplement factory in the EU, and the five things you can check yourself.
The short answer
Three separate things get blurred into one impression of quality:
- Origin is a customs concept. A product originates where it underwent its “last, substantial, economically-justified processing or working” (Regulation (EU) No 952/2013, Article 60(2)). Ingredients can come from anywhere.
- Compliance is a legal floor that applies to every food business in the EU: a registered establishment, a permanent HACCP procedure, traceability of every input, and information that is not misleading.
- Certification is private and voluntary. No public body issues an “EU certified” mark for supplements. The schemes that do exist certify a factory site, not your jar.
A country name on a pack speaks to the first of those three. It is not a shortcut for the other two.
The floor every EU supplement factory stands on
Whatever the flag on the box, an EU food business carries the same core duties.
The site has to be known to the authorities
Every food business operator must notify the competent authority of each establishment it controls that carries out any stage of production, processing or distribution of food, so that the establishment is registered, and must keep that information up to date (Regulation (EC) No 852/2004, Article 6(2)).
There has to be a HACCP system
Operators must “put in place, implement and maintain a permanent procedure or procedures based on the HACCP principles” (Regulation (EC) No 852/2004, Article 5(1)). Those principles are spelled out in Article 5(2): identify the hazards, identify the critical control points, set critical limits, monitor them, define corrective actions, verify that the system works, and keep records proportionate to the business. The procedure must be reviewed whenever the product or process changes.
Every input has to be traceable
Operators must be able to identify anyone who supplied them with a food or with any substance intended to be incorporated into a food, and must have systems to identify the businesses they supplied in turn, with that information available to the authorities on demand (Regulation (EC) No 178/2002, Article 18(2) and 18(3)).
This is the part that is genuinely reassuring, and it is also the part that “Made in Germany” adds nothing to. A registered site with a HACCP plan and one-step-back, one-step-forward traceability is the baseline in every member state.
What “made in” legally means
Origin has a definition, and it is not intuitive. Goods wholly obtained in one country originate there. Goods whose production involves more than one country “shall be deemed to originate in the country or territory where they underwent their last, substantial, economically-justified processing or working, in an undertaking equipped for that purpose, resulting in the manufacture of a new product or representing an important stage of manufacture” (Regulation (EU) No 952/2013, Article 60).
Read that again with a supplement in mind. Mineral salts, amino acids and vitamin forms are global commodities. A magnesium compound synthesised in Asia, blended and encapsulated in Europe, is a product whose ingredients are Asian and whose last processing step is European. The label sentence and the supply chain answer two different questions.
Whether a specific step clears the Article 60(2) bar is a customs assessment, not a marketing decision. Simple repacking of a finished product is a weak case; a genuine manufacturing stage is a strong one. The honest reading for a buyer is narrow: a country name describes the end of the chain, never the whole of it.
When a country has to appear on the label at all
For most supplements it does not. Indicating country of origin or place of provenance is mandatory “where failure to indicate this might mislead the consumer as to the true country of origin or place of provenance of the food, in particular if the information accompanying the food or the label as a whole would otherwise imply that the food has a different country of origin” (Regulation (EU) No 1169/2011, Article 26(2)(a)).
So origin is usually voluntary, and it becomes compulsory precisely when the rest of the pack is doing the implying. Flags, national colours, a German-language front panel and a Düsseldorf address together can create an origin impression that then has to be corrected or confirmed.
There is a second duty that follows from volunteering it. Where the origin of a food is given and it is not the same as that of its primary ingredient, the label must also give the primary ingredient's origin or state that it differs (Article 26(3)). A brand that prints a country is taking on obligations, not decorating a box.
Underneath all of this sits Article 7(1)(a): food information must not be misleading as to the nature, composition, country of origin, place of provenance or method of manufacture of the food. That single sentence is the reason vague origin wording is a legal risk and not a clever workaround.
A German address is not an origin claim
Every pack names a company. That name has a specific legal function: the food business operator responsible for the food information is the operator under whose name the food is marketed, or, where that operator is not established in the relevant territory, the importer (Regulation (EU) No 1169/2011, Article 8(1)); that operator must ensure the information is present and accurate (Article 8(2)).
In other words, the address answers “who is accountable and where do I complain”. It does not answer “where was this made”. A German company can market a product manufactured elsewhere entirely lawfully. What it cannot do is let the pack imply otherwise, because that is where Articles 7 and 26(2)(a) bite.
“EU certified” is not a certificate
Food supplements are foods, not medicines, and there is no pre-market authorisation for them. Directive 2002/46/EC harmonises the rules; the only registration-type duty it allows member states to impose is notification: a member state “may require the manufacturer or the person placing the product on the market in their territory to notify the competent authority of that placing on the market by forwarding it a model of the label used for the product” (Article 10).
Germany uses that option. Under the Nahrungsergänzungsmittelverordnung, whoever places a food supplement on the market as manufacturer or importer must notify the Bundesamt für Verbraucherschutz und Lebensmittelsicherheit at the latest at first placing on the market, submitting a model of the label used (NemV § 5(1)), and the BVL forwards the notification to the ministry and the state food-control authorities (§ 5(3)).
Notice what notification is: a label lands in a file. Nobody tested the product, nobody approved the formula, and nothing was issued that a brand could truthfully call an EU certificate. Any pack or product page promising “EU approved” or “EU certified” is using words with no legal referent.
Supplements are not made under pharmaceutical GMP
The letters GMP carry a lot of weight, mostly borrowed. In EU law, the detailed good manufacturing practice guidelines collected in EudraLex Volume 4 apply to medicinal products for human and veterinary use. There is no equivalent binding EU GMP code for food supplements: the binding manufacturing law for them is food hygiene law, which is Regulation (EC) No 852/2004 and its HACCP requirement.
Stricter manufacturing standards for food do exist, and they are private, voluntary and paid for by the manufacturer. FSSC 22000 is one of the widely used schemes; others operate the same way. That is not a criticism. A well-run scheme audit is meaningful. It just means a “GMP certified” or “certified facility” claim is a private-scheme claim, not a state guarantee, and it should come with the details that make it checkable: which scheme, which site, which certificate number, which scope, valid until when. A certificate covers a factory during an audit window. It says nothing about the jar in your hand, which is what a batch certificate of analysis is for.
Who actually checks, and how often
Official controls are real, and they are risk-based rather than exhaustive. Competent authorities “shall perform official controls on all operators regularly, on a risk basis and with appropriate frequency”, taking account of identified risks, any information indicating that consumers might be misled about matters including country of origin or method of manufacture, the operator's past record, and the reliability of the operator's own controls, including private quality assurance schemes (Regulation (EU) 2017/625, Article 9(1)).
Two honest consequences follow. Nobody inspects every batch of every supplement. And a credible private certification can reduce how much attention an authority spends on a site, which is one practical reason those schemes exist.
Five things you can verify in five minutes
- Find the responsible operator. The company name and address on the pack is who is legally answerable for the information on it (Article 8(1)). If there is no EU address, the product is being placed on the market by someone you cannot easily reach.
- Read the verb, not the country. “Made in”, “Produced in”, “Packed in”, “Bottled in”, “Lab-tested in” and “Designed in” are six different claims. Only the first two say anything about manufacturing.
- Ask where the raw material came from. For commodity nutrients this is a fair question with a specific answer. A brand that cannot say where its magnesium compound or its vitamin form is sourced does not know its own supply chain.
- Ask for the certificate, not the badge. Scheme name, site address, certificate number, scope and expiry date. A badge without those five fields is a graphic.
- Ask for the batch paperwork. The lot number on your pack is the key: what was tested, by which laboratory, against which specification. This is the only document that is about your product rather than about a building. Our guide to reading a certificate of analysis covers what a good one contains, and our piece on which label words are legally defined covers the rest of the front panel.
How this applies to our own labels
We do not print “Made in Germany”, and this article is not a way of implying it. What our pages actually say, and what each phrase is worth:
- “Lab-tested in Germany” on our Magnesium 7-in-1 and other product pages is a statement about where testing happens. It is not a manufacturing-origin claim and should not be read as one.
- “Independently lab-tested” says the testing is not done by the party selling you the product. Its honest limit is that we do not publish per-batch certificates, so from the outside it is a promise rather than a document. If you want the paperwork for the jar you own, send us your lot number at info@notfortomorrow.com.
- “EU shipped 2 to 4 days” is logistics. It describes where the parcel leaves from, nothing else.
- Vontix GmbH, Düsseldorf is the responsible food business operator under Article 8(1). It is an accountability address, not a factory address.
The honest gap is worth naming: this article does not tell you where each of our products is manufactured, because we are not going to publish a country here that we have not documented for you properly. Ask us with a product name and we will answer specifically. Applying our own five-minute test to ourselves, we pass on points one, two and four, and we currently fail point five for anyone who has not emailed us. That is a real gap and we would rather write it down than dress it up. If you want the wider legal picture of what a supplement is and is not allowed to be, our article on the difference between a food supplement and a medicine covers the classification side.
Frequently asked questions
Is “Made in Germany” better than “Made in the EU”?
Not as a legal matter. The binding requirements, registration of the establishment, HACCP, traceability and non-misleading information, are EU-wide. What differs between member states is which national authority runs the controls and how it prioritises them under Regulation (EU) 2017/625, Article 9. Treat a country name as information about the last processing step, not as a quality ranking.
Does “Made in Germany” mean the ingredients are German?
No. Origin follows the last substantial processing (Regulation (EU) No 952/2013, Article 60(2)), so a pack can carry a country name while its nutrients were synthesised or extracted somewhere else entirely. If ingredient origin matters to you, ask about the ingredient rather than reading the front of the box.
Is there an EU approval or EU certificate for food supplements?
No. There is no pre-market authorisation. Member states may require notification with a model label under Directive 2002/46/EC, Article 10, which Germany implements in NemV § 5. Notification records that a product exists; it does not test, approve or certify it.
What does “GMP certified” mean on a supplement?
Usually that the manufacturing site holds a private scheme certificate, or a certificate issued under a non-EU framework. The EU GMP rules in EudraLex Volume 4 are for medicinal products. For a food supplement, ask which scheme, which site and which certificate number, then check that the scope covers the product type you are buying.
Does a German company address mean the product was made in Germany?
No. The address identifies the operator responsible for the food information (Regulation (EU) No 1169/2011, Article 8(1)). It can lawfully sit on a product manufactured elsewhere. What the law does not allow is a pack whose overall impression implies an origin the product does not have, which is when origin labelling becomes mandatory under Article 26(2)(a).
If a brand only fills capsules in Germany, can it still say “Made in Germany”?
That depends on whether the step counts as the last substantial, economically justified processing resulting in a new product or an important stage of manufacture (Article 60(2)). Simple repacking is a weak case, a genuine manufacturing stage is a strong one, and the assessment is made product by product. As a buyer you cannot settle it from the outside, which is why the useful question is about the ingredient and the batch paperwork rather than the phrase.
The bottom line
A country name on a supplement is a narrow factual statement about the end of a supply chain, made under customs rules, and it is legally optional in most cases. “EU certified” is not a category. What the EU actually guarantees is a floor: a registered establishment, a permanent HACCP system, traceability in both directions, information that is not misleading, and risk-based official controls. Everything above that floor is either a private certificate about a factory or a batch document about your jar. Ask for those two things by name and the marketing words stop mattering.
Sources
- Regulation (EU) No 952/2013 (Union Customs Code), Article 60: Acquisition of origin, European Parliament and Council, 2013.
- Regulation (EC) No 852/2004 on the hygiene of foodstuffs, Article 5: Hazard analysis and critical control points, European Parliament and Council, 2004.
- Regulation (EC) No 852/2004, Article 6: Official controls, registration and approval, European Parliament and Council, 2004.
- Regulation (EC) No 178/2002 (General Food Law), Article 18: Traceability, European Parliament and Council, 2002.
- Regulation (EU) No 1169/2011 on food information to consumers, Article 7: Fair information practices, European Parliament and Council, 2011.
- Regulation (EU) No 1169/2011, Article 8: Responsibilities, European Parliament and Council, 2011.
- Regulation (EU) No 1169/2011, Article 26: Country of origin or place of provenance, European Parliament and Council, 2011.
- Directive 2002/46/EC on food supplements, Article 10: notification of placing on the market, European Parliament and Council, 2002.
- Nahrungsergänzungsmittelverordnung (NemV) § 5: Anzeige, Bundesministerium der Justiz, Germany.
- Regulation (EU) 2017/625 on official controls, Article 9: General rules on official controls, European Parliament and Council, 2017.
- Food supplements, European Commission, Directorate-General for Health and Food Safety.
- EudraLex Volume 4: EU guidelines for good manufacturing practice for medicinal products for human and veterinary use, European Commission.
- FSSC 22000 food safety certification scheme, Foundation FSSC.
A note on the legal links: the EUR-Lex website returns an empty response to automated requests, so the EU instruments above are linked through the legislation.gov.uk mirror, which reproduces the text of each article. Each instrument is named in full so you can look it up on EUR-Lex directly. Where that mirror shows post-2020 United Kingdom amendments, only the unamended substance of the cited provisions has been used here.
Written by the NOTFORTOMORROW Editorial Team. This article explains labelling and food law and is not legal advice.
