In late September 2026, a coalition of organizations published a manifesto outlining recommendations for a digital transition. It advocates for a “one product, one EU Data Carrier” approach and calls for the implementation of a harmonized, flexible, and technology-neutral digital labeling system that would allow certain physical information to be replaced with information accessible online.
The authors of this manifesto are a coalition of European trade associations, including COSMED (Association of SMEs in the Cosmetics Industry), ERPA (European Cosmetics Responsible Person Association) and Cosmetics Europe.
They note that current regulations are fragmented: some laws allow for digital labeling, while others still require information to be provided on physical media. This situation complicates matters for companies, particularly SMEs, and hinders innovation.
Recommendations from Organizations
They are therefore calling on the European Commission to establish a common European framework based, in particular, on the following principles:
• One product, one EU data carrier: that is, a single digital carrier per product, consolidating information from various European regulations.
• Ensure interoperability: with structured data that is accessible and updatable by IT systems.
• Technology neutrality: to avoid imposing any specific technology (QR code, RFID, NFC, app, etc.).
• Avoid redundant statements around data carriers: digital information intended for consumers is explicit and sufficient to guide and explain to consumers the type of information they can expect.
• Digital labels facilitating translations and language neutrality: to easily manage multiple languages through digital means.
• Digitalise certain mandatory product information, to be defined sector by sector: particularly …
