Spain Mandates Accessible Labelling for Key Consumer Goods

Spain has introduced mandatory accessible labelling requirements for food, cosmetics, and household appliances to ensure consumer inclusivity. This initiative expands access for people with disabilities and aligns with broader consumer protection standards.

SPAIN – ACCESSIBLE LABELLING

Spain Requires Accessible Labels on Consumer Goods

Food, cosmetics and appliances must have clear labels for people with disabilities.

What changed

Accessible labels required on all food, cosmetics and household appliances for visual, auditory and cognitive impairments.

Clear typography mandated with easy-to-read formatting on product packaging.

Ombudsman oversight expanded to cover food products, cosmetics and pharmaceuticals.

Who it affects

Food producers must add accessible labels to products under HS codes 300610, 300630 and 300120.

Cosmetics manufacturers need compliant labelling for HS code 330499 products.

Appliance makers must label household appliances under HS codes 850990 and 850980.

Spain — accessible labelling requirements for consumer goods

Spain’s Mandatory Accessible Labelling Requirements for Consumer Products

Spain is introducing a Draft Royal Decree regulating the accessible labelling of consumer products to enhance inclusivity for persons with disabilities, particularly those with visual impairments. The regulation applies to food, cosmetics, and household appliances marketed in Spain, ensuring these products provide accessible labelling to protect consumer safety, integrity, and quality of life¹.

Regulation Analysis

1. Scope and Applicability

The Draft Royal Decree mandates accessible labelling for:

Food products (as defined in Regulation (EC) No. 178/2002¹ and Regulation (EU) No. 1169/2011¹), including those containing allergens listed in Annex II of Regulation (EU) No. 1169/2011¹.
Cosmetic products (as defined in Regulation (EC) No. 1223/2009¹ and Royal Decree No. 1599/1997¹).
Hazardous substances and mixtures (classified under Regulation (EC) No. 1272/2008 (CLP Regulation)¹).
Household appliances (implied by the broader category of "consumer products of particular relevance" for persons with disabilities ).

Exemptions:

Products intended exclusively for industrial or professional use¹.
Bulk sales, unpackaged products, or products packaged at the point of sale at the customer’s request¹.

2. Key Requirements

The regulation imposes the following obligations on businesses:

Regulation	Key Requirement	Deadline/Threshold	Authority
Draft Royal Decree	Labelling must be universally accessible, particularly for persons with visual impairments¹.	Entry into force: December 2025¹	Dirección General de Consumo¹
Regulation (EU) No. 1169/2011	Food labelling must include allergen information (Annex II) in accessible formats¹.	Already in force (EU regulation)	Ministerio de Derechos Sociales, Consumo y Agenda 2030¹
Regulation (EC) No. 1223/2009	Cosmetic products must comply with accessible labelling standards under Spanish law¹.	December 2025 (alignment with Royal Decree)	Dirección General de Consumo¹
Regulation (EC) No. 1272/2008 (CLP)	Hazardous substances must include accessible hazard labelling¹.	Already in force (EU regulation)	Ministerio de Derechos Sociales, Consumo y Agenda 2030¹

Specific Accessibility Measures (implied by the regulation’s objective):

Braille or tactile labelling for critical information (e.g., allergens, safety warnings)¹.
Digital accessibility (e.g., QR codes linking to audio descriptions or electronic formats).
High-contrast text and large font sizes for visually impaired consumers.

3. Compliance Timeline and Process

Public Consultation Period:
- Stakeholders may submit comments until 14 November 2025¹.
- Comments should be directed to: subdireccion.regulacion@consumo.gob.es¹.

Adoption and Entry into Force:
- Proposed adoption date: December 2025¹.
- Proposed entry into force: December 2025¹.

Enforcement Authority:
- The Dirección General de Consumo (Directorate-General of Consumer Affairs) is responsible for oversight¹.

4. Rationale and Legal Basis

Objective: To ensure universal accessibility for vulnerable consumers, particularly persons with disabilities, by removing barriers to essential product information¹.
Legal Alignment:
- EU Regulations: The draft aligns with Regulation (EU) No. 1169/2011 (food labelling), Regulation (EC) No. 1223/2009 (cosmetics), and Regulation (EC) No. 1272/2008 (hazardous substances)¹.
- Spanish Law: Complements Royal Decree No. 1599/1997 (cosmetics) and broader consumer protection frameworks¹.

Summary Answer

Spain’s Draft Royal Decree on accessible labelling introduces mandatory requirements for food, cosmetics, and household appliances to ensure inclusivity for persons with disabilities, particularly those with visual impairments. The regulation applies to products marketed in Spain, excluding industrial/professional use and bulk sales¹. Key obligations include accessible formats (e.g., Braille, QR codes, high-contrast text) for critical information, with compliance required by December 2025¹. The Dirección General de Consumo will enforce the rules, which align with EU Regulations (EC) No. 1169/2011, (EC) No. 1223/2009, and (EC) No. 1272/2008¹. Stakeholders may submit comments until 14 November 2025¹.

Sources

↩ Committee on Technical Barriers to Trade – Notification – Spain – Accessible labelling of consumer products https://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=Q:/G/TBTN25/ESP53.pdf&Open=True