SG 049/26
Spain drafts Royal Decree mandating accessible labeling on cosmetics, foods and hazardous substances to better serve vulnerable consumers.
Promoted by the Ministry of Social Rights, Consumer Affairs and Agenda 2030, Spain’s draft Royal Decree on accessible labeling introduces a comprehensive framework to ensure that consumer products sold in the country can be understood and used safely by all individuals, particularly those who are visually impaired or otherwise vulnerable.
Who is impacted?
The decree covers a wide range of goods, including cosmetics, food products – especially those containing allergens – and hazardous substances, as well as most consumer items marketed in Spain. It does not apply to bulk products or those intended solely for industrial or professional use. Compliance is required across the entire supply chain, meaning manufacturers, importers and distributors must guarantee that products meet the new accessibility standards. They must also report any detected non-compliance.
What does the regulation require?
The decree establishes detailed requirements for accessible labeling:
- Accessible physical labeling – mandatory Braille on packaging and tactile markers to identify hazards
- Clear Spanish-language text for all essential information
- Digital accessibility tools, such as QR codes that link to accessible product information, as a complement to physical labels
- Specific mandatory content on labels, including:
- Product name and identity
- Composition and allergens
- Batch number and expiry details
- Instructions for use
- Warnings
- Manufacturer or importer contact information
- Obligatory symbols (e.g. recycling, hazard icons)
These measures support Spain’s commitments under the UN Convention on the Rights of Persons with Disabilities and harmonize national consumer protection rules with broader EU packaging and waste regulations.
When does it apply?
The Royal Decree is currently in draft form but it is progressing through a revised approval process:
- Late 2025 – the European Commission issued a reasoned opinion warning that the original proposal could create technical barriers to trade, requiring the Spanish government to revise the text and reopen the process
- March 16 – April 12, 2026 – a new public consultation was launched, confirming that the government is reworking the proposal to address EU concerns while maintaining strong accessibility requirements
- Minister of Social Rights has announced the revised draft will be issued shortly
- Government now expects the regulatory text to advance in the second half of 2026, following review by national authorities and the European Commission
No final approval or implementation date has yet been set.
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