Publikováno: 10. 4. 2006
DG Sanco has been discussing for a long time on labelling legislation, mainly regarding food labelling. After reflection, they are wondering whether or not to extend the revision of labelling legislation to cover non-food products .
The aim of the revision is to have an overall approach for labelling that would:
Provide consumers with necessary information to enable them to make safe, healthy and sustainable choices;
Create a pro-competitive market environment through using the power of labelling to sell products;
Be consistent, coherent and transparent;
Create a common framework and rules to eliminate barriers to the free circulation of goods.
The revision would take into account stakeholders' views on the effectiveness of labelling legislation, problems with implementation and look for suggestions on how to improve it. They are also looking at options to mandatory labelling, eventually through the use of self-regulation, codes of best practice, or providing information off-pack.
Some of the questions that the Commission pose are:
The benefits in simplifying and clarifying the structure and scope of existing legislation, both horizontal and vertical, bringing all aspects together;
Whether it is practical to consider food and non-food labelling together;
Whether there should be more or less prescription in labelling legislation;
If there is sufficient flexibility to allow industry to quickly adapt to changing consumer needs and demands;
The role of self- or co-regulation for labelling issues;
Whether to prefer a “framework” piece of legislation, with specific pieces of work carried on in parallel or individually;
Whether it would be possible to carry out a comprehensive approach, given that several pieces of legislation are managed by other DGs.
One of the issues to be taken into account will be the Unfair Commercial Practices Directive, in that it covers the misleading aspects of labelling.
While recognising that there are several areas, covered by labelling that are very different, among the common themes that DG Sanco would consider are:
The need to consider alternatives to legislation;
How to deal with SMEs (how to minimise costs);
The presentation of labels, ensuring that they are easy to read and understand;
The potential use of logos or symbols (overcoming problems of mul t i-lingual labels, but how to develop EU recognised logos in practice);
Achieving a balance between a prescriptive approach, which ensures consistency but can be too rigid and prevent innovation, and an approach that, through too much flexibility leads to loss of the internal market;
Coordinating the implementation of legislation, therefore minimising the effects of multiple labelling changes;
Ensuring the quality of any research undertaken;
Taking into consideration that there are many types of consumers and that a “one-size fits all” approach will not work;
The need to prioritise on what should be on the label and what could be offered elsewhere, i.e. off-pack (implications SMEs…)
While a large part of the document deals with food labelling, the following non-food issues are also covered:
Safety labelling and standards (considered by consumers as essential, but not easily recognised). Consumers have also said that they wish for more information on health (allergens in cosmetics, textiles and furniture fabrics), environment (effects on ozone layer of aerosols, recycling and biodegradability) and sustainability (production of fibres for textiles and wood for furniture);
Origin labelling for non-food products (possible proposal on a compulsory origin marking scheme for a number of sectors, taking into account views and interests of consumers and covering third countries);
Safety - general simplification
Global harmonisation of labelling of chemical products (in collaboration with Reach), covering consumer education, execution and presentation
Cosmetics - especially sun protection products, on health aspects and the use of allergens
Biocidal products (streamlining some aspects - sterilisation, hygiene..)
Labelling of allergens for furniture and textiles
Use of standards/guidelines
Increase of consumers knowledge
The Food Policy and Consumers Committee will prepare a reply to the consultation on labelling of food products (deadline 15th June). If you have any further comments on the non-food side, these would be a valuable addition.