EU considers unified product labelling rules amid concerns over single market fragmentation

Steven M. Baumer
Steven M. Baumer
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The European Parliament’s Internal Market and Consumer Protection Committee (IMCO) recently held a hearing to address the complications arising from varying national product labelling and recycling regulations across the European Union. According to analysis by the European Central Bank, internal barriers in the EU goods market are comparable to tariffs of approximately 65%. The session included input from the European Commission, EUROPEN—a packaging supply chain stakeholder group—and the Environmental Coalition on Standards.

A central issue discussed was how individual member states implementing their own labelling standards can disrupt the single market. This results in inconsistent requirements that make it challenging for businesses to use one label for all EU countries and can confuse consumers about proper use and disposal of products and packaging. The European Commission emphasized balancing consumer information needs with maintaining an effective single market. “From the Commission’s perspective, it wants to avoid member states taking an approach which ignores the cross border element. This is detrimental for companies who have to repackage/relabel/oversticker products and can be confusing for consumers.” The Commission also noted there is no evidence linking national labelling systems with higher recycling rates.

The 2025 Single Market Strategy identified differences in national rules on packaging, labelling, and waste as major contributors to market fragmentation. As a result, the Commission has taken enforcement actions against France, Belgium, and Spain regarding measures such as on-pack waste sorting instructions and Nutriscore labels, considering them disproportionate. Spain introduced a new packaging waste labelling system in January 2025 following new EU regulations, while France plans to continue using its Triman recycling logo until 2028; both are currently subject to infringement proceedings at the European level.

Concerns were raised that unilateral measures increase costs due to relabelling or repackaging requirements—an issue particularly burdensome for small- and medium-sized enterprises (SMEs). The Commission believes similar outcomes could be achieved through alternative methods like in-store information or marketing campaigns without hindering cross-border trade. Some sectors already benefit from harmonised rules, such as cosmetics, and new requirements under the Packaging and Packaging Waste Regulation (2025/40) will apply throughout packaging’s life cycle.

Participants supported common standards for product labelling information as a way to prevent non-compliant or low-quality products from dominating markets where less information is required. There was also recognition that it takes time for consumers to become familiar with symbols used for recycling purposes. While digital labels like QR codes were discussed positively, committee members agreed essential product details should remain physically present on items because not all consumers are likely—or able—to access digital information easily.

Looking ahead, changes are planned for textile product labelling rules in 2026. The current regulation focuses mainly on fibre composition but does not address other aspects such as origin or sustainability practices. The proposed revision aims for a single label requirement across textiles—including non-textile apparel—to reduce compliance costs and standardise information provided to consumers. Key areas of focus include clearer sustainability data (such as country of manufacture or presence of allergenic substances), visual accessibility through standardised symbols or codes, proportionality so that requirements do not unduly burden SMEs, and clarity in presentation.

The IMCO committee has also adopted proposals supporting a ‘digital by default’ approach for product compliance documentation—such as declarations of conformity—in most cases while retaining paper-based options where needed for safety reasons or accessibility concerns. Manufacturers must ensure that people without regular digital access can still request paper copies via accessible means like phone calls. Traders will be required to provide direct digital contact points (e.g., email addresses), but automated responses will not suffice.

Under these proposals, if harmonised standards are lacking or insufficient, the European Commission may temporarily adopt ‘common specifications’ as legally recognised alternatives until revised EU standards are established.

The next step involves a parliamentary vote expected in March before negotiations proceed with the European Commission.



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