FCCPC Directs Immediate Withdrawal of Improperly Labelled Consumer Goods: What Businesses Must Do Now

The Federal Competition and Consumer Protection Commission (“FCCPC”) has directed manufacturers, importers, distributors and retailers to immediately review their inventories and withdraw from sale consumer goods that do not comply with applicable product-labelling requirements.

The directive, issued on 19 August 2026, follows the Commission’s reported discovery of consumer goods bearing incomplete, misleading or deceptive information during market-surveillance, inspection and quality-assurance activities.

The FCCPC identified several areas of concern, including the absence or misrepresentation of production dates, expiry or best-before dates, batch numbers, manufacturer details, ingredient lists, allergen information, country of origin and other mandatory information.

The Commission warned that businesses continuing to distribute or sell noncompliant products risk regulatory enforcement. It also indicated that nationwide surveillance and enforcement would be intensified in collaboration with the Standards Organisation of Nigeria (“SON”), the National Agency for Food and Drug Administration and Control (“NAFDAC”) and other relevant regulators.

What has changed?

The FCCPC’s directive does not introduce an entirely new product-labelling regime. Rather, it signals an immediate and potentially more coordinated enforcement of existing obligations under the Federal Competition and Consumer Protection Act 2018 (“FCCPA”) and applicable standards administered by sector regulators.

The directive was issued pursuant to sections 17(p), 17(w), 17(x), 114, 116, 123 and 125 of the FCCPA.

Among other requirements:

a) Information provided to consumers must be presented in plain and understandable language.

b) A business must not knowingly apply a misleading trade description to goods.

c) A business must not supply, offer to supply or display goods where it knows, reasonably could determine, or has reason to suspect that the trade description is misleading or has been altered.

d) Producers, importers, distributors, retailers and traders must not make false, incorrect, misleading or deceptive representations about goods.

e) Misleading representations may expose a business to damages and monetary restitution.

The FCCPA also requires manufacturers, importers and distributors to label or describe goods in a manner that makes them traceable to the relevant manufacturer, importer or distributor.

The FCCPC’s directive requires businesses to act immediately. No general compliance or transition period was announced.

Which businesses are affected?

The directive expressly applies across the consumer-goods supply chain, including:

a) Manufacturers and contract manufacturers;

b) Importers and authorised representatives of foreign manufacturers;

c) Distributors and wholesalers;

d) Physical and online retailers;

e) Private-label and white-label product businesses; and

f) E-commerce platforms, depending on their role in offering or supplying the affected products.

The sectors most likely to be affected include food and beverages, cosmetics and personal-care products, pharmaceuticals and health products, household products, chemicals, electrical products, packaged consumer goods and imported merchandise.

However, not every labelling item identified by the FCCPC applies uniformly to every product. The precise information required will depend on the product category and the relevant NAFDAC, SON or other sector-specific standard.

Accordingly, businesses should avoid treating the FCCPC’s list as either exhaustive or universally applicable. Compliance must be assessed product by product.

Retailers and distributors also have compliance exposure

A significant aspect of the directive is that responsibility is not placed solely on manufacturers. Importers, distributors and retailers have been directed to review their inventories and withdraw noncompliant products from sale. A retailer may therefore face regulatory exposure even where the defective or incomplete label originated with the manufacturer or overseas supplier.

Businesses further down the supply chain should not rely exclusively on a supplier’s general assurance that a product is compliant. They should be able to demonstrate that reasonable verification procedures were undertaken before the product was offered for sale.

Retailers and distributors should also examine whether their contracts permit them to quarantine or return noncompliant products and recover the associated withdrawal, storage, relabelling and disposal costs.

Withdrawal from sale is not necessarily the same as a consumer recall

The FCCPC has directed businesses to withdraw noncompliant products from sale.

On its face, the directive does not impose a general recall of every affected product that has already been purchased by consumers. However, a wider recall, consumer notification or regulator-reporting obligation may arise where the labelling defect conceals or creates a health or safety risk, or where another applicable law or sector regulator requires a recall.

Businesses should therefore classify identified defects according to risk:

1. Administrative defects: Minor omissions that do not mislead consumers or affect safety, but still breach an applicable standard.

2. Material information defects: Missing or inaccurate information that may affect a consumer’s purchasing decision.

3. Safety-related defects: Missing expiry dates, allergen warnings, usage instructions, hazard warnings or other information capable of exposing consumers to harm.

Safety-related defects should be escalated immediately for legal and regulatory assessment.

Immediate compliance steps

Affected businesses should consider the following actions.

1. Suspend affected sales and distribution

Businesses should suspend the dispatch, display and sale of products reasonably suspected to be noncompliant while an assessment is conducted. Online retailers should consider temporarily delisting affected products.

2. Conduct a product-by-product labelling audit

Each product or stock-keeping unit should be reviewed against:

a) The FCCPA;

b) Applicable NAFDAC requirements;

c) Applicable SON standards;

d) Product-specific regulations and codes;

e) Import and customs documentation; and

f) Representations made on packaging, inserts, advertisements and online product listings.

The review should cover both the presence and accuracy of required information.

3. Quarantine and document noncompliant inventory

Potentially affected stock should be isolated and clearly marked to prevent accidental redistribution. Businesses should record the relevant product names, batch numbers, quantities, warehouse or retail locations, suppliers and distribution history.

4. Determine the appropriate corrective action

Depending on the nature of the defect and applicable regulatory requirements, corrective action may include:

a) Relabelling or over-labelling;

b) Returning products to the manufacturer or importer;

c) Removing the products from sale;

d) Destroying affected stock;

e) Notifying distributors, retailers or regulators; or

f) Implementing a formal product recall.

Products should not be returned to the market until their compliance has been verified.

5. Preserve evidence of compliance

Businesses should maintain a clear record of the audit, affected inventory, internal decisions, supplier communications, corrective measures and any regulatory engagement. These records may be important if the FCCPC, NAFDAC, SON or another regulator conducts an inspection.

6. Review supply and distribution contracts

Manufacturing, import, supply, private-label and distribution agreements should clearly address:

a) Responsibility for regulatory approvals and labelling compliance;

b) Warranties concerning the accuracy and completeness of product information;

c) Notification of regulatory defects;

d) Product withdrawal and recall procedures;

e) Batch traceability and record keeping;

f) Audit and inspection rights;

g) Indemnities for regulatory breaches and consumer claims;

h) Allocation of withdrawal, relabelling, storage and destruction costs; and

i) Termination or suspension rights following material noncompliance.

Where existing contracts are silent or inadequate, businesses should consider amendments or supplemental product-compliance protocols.

Broader significance for consumer-goods businesses

The directive demonstrates that product-labelling compliance is not merely a production or packaging issue. It is a supply-chain governance responsibility involving regulatory, commercial, operational and reputational risk.

Businesses should build labelling verification into product development, import clearance, supplier onboarding, inventory acceptance and retail-listing processes.

Compliance should be confirmed before products enter the Nigerian market—not only after a regulator raises a concern.

Companies dealing in imported products should pay particular attention to labels prepared principally for foreign markets. Compliance with the requirements of another jurisdiction does not automatically establish compliance with Nigerian standards.

Essentially, manufacturers, importers, distributors and retailers should treat the FCCPC’s directive as requiring immediate action. Businesses with extensive product portfolios should prioritise higher-risk categories but should ultimately complete a documented review of every consumer product offered for sale. A timely audit can reduce the risk of enforcement, consumer claims, supply-chain disputes, avoidable withdrawal costs and reputational damage.

JMJ Partners advises manufacturers, importers, distributors, retailers and other consumer-facing businesses on product-labelling compliance, regulatory investigations, supply-chain risk allocation, product withdrawal and recall procedures, and the review of manufacturing, importation and distribution contracts.

For advice or assistance with a product-labelling compliance review, please contact JMJ Partners.

Source:

FCCPC, “Mandatory Labelling of Manufactured Goods for Consumer Information,” 19 August 2026; Federal Competition and Consumer Protection Act 2018.

This publication provides general information and does not constitute legal advice. Specific legal advice should be obtained in relation to particular products, circumstances and regulatory requirements.