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Made in Italy, by law

What Article 16 of Law 166/2009 actually requires — and what it doesn't.

“Made in Italy” is one of the most valuable three-word phrases in fashion. It is also one of the most misunderstood. For a buyer commissioning leather goods, it helps to know that the phrase actually lives in two different legal worlds at once.

Customs origin vs. the protected claim

The first world is customs origin. Under EU non-preferential origin rules, a product’s country of origin is the place where it underwent its “last, substantial, economically justified transformation.” For a leather bag, that generally means the country where the bag was cut, assembled, and finished — not necessarily where the hide was raised or tanned.

The second world is the protected “100% Made in Italy” claim, governed in Italy by Article 16 of Law 166/2009 (which converted Decree-Law 135/2009).

What Article 16 says

In broad terms, Article 16 reserves wordings such as “100% Made in Italy”, “100% Italia”, “tutto italiano” and equivalent signs for products whose design, manufacturing, and packaging are carried out entirely in Italy, predominantly using materials worked in Italy. It also created sanctions for misleading origin claims — fraudulent “Italian sounding” marketing is taken seriously.

The practical takeaway: a plain “Made in Italy” label on a bag assembled in Italy is generally defensible under customs rules even if some components originate elsewhere. But the louder, absolute claims (“100% Made in Italy”) carry a higher legal bar.

What it means for your brand

  • Be precise. If your supply chain is genuinely Italian end-to-end, the strong claim is available to you. If it isn’t, use “Made in Italy” accurately rather than overclaiming.
  • Keep documentation. Origin claims should be supported by records — where the leather was tanned, where the bag was cut and assembled, where it was finished and packed.
  • Match your marketing to your manufacturing. The reputational and legal risk of an inflated claim almost always outweighs the marketing upside.

At FRAYDA, design, pattern-making, cutting, assembly, edge finishing, quality control, and packaging are all performed in Italy. That lets the brands we work with describe their products honestly — which, in the end, is the only kind of “Made in Italy” worth having.

This article is general information, not legal advice. For a specific product and market, confirm origin labelling with a qualified professional.

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