Spain Proposes New Accessible Labeling Rules for Cosmetic Products

SG 185/25

Spain introduces a Royal Decree requiring accessible labeling for cosmetics, foods and hazardous substances to better serve vulnerable consumers.

Promoted by the Ministry of Social Rights, Consumer Affairs and Agenda 2030, the draft Royal Decree mandates accessibility features on product labeling, including Braille, tactile markers, QR codes and clear Spanish-language text, for cosmetics, foods (including those containing allergens) and hazardous substances placed on the Spanish market to better serve vulnerable consumers, particularly those with visual impairments. Coverage includes most consumer products sold in Spain, excluding bulk or industrial/professional items, and applies across the entire supply chain with manufacturers, importers and distributors jointly responsible for compliance and for reporting violations.

Labels must include key data, such as product identity, composition, batch and expiry details, usage instructions, warnings, contact information and allergen declarations with additional formats encouraged. The decree aligns with Spain’s constitutional obligations under the UN Convention on the Rights of Persons with Disabilities and amendments to consumer protection legislation. It also contributes to broader European Union objectives related to packaging and waste reduction.

1. Compliance timeline:
   • Draft notification: June 20, 2025
   • Expected adoption: December 2025 subject to final approval
   • Transition period: up to two years following adoption with full compliance likely required by late 2027. The obligations will be immediate, except for products already labeled, which will have up to six months to adapt
   • Public consultation: open until November 2025
2. Key obligations for businesses:
   1. Scope: applies to all cosmetics sold in Spain (except bulk or industrial/professional-use products)
   2. Accessible labeling requirements:
      1. Braille
      2. Tactile markers: for hazard identification
      3. Digital formats: QR codes linking to accessible product information
      4. Clear Spanish text: essential details
   3. Mandatory information on labels:
      1. Product name and identity
      2. Composition and allergens
      3. Batch number and expiry date
      4. Usage instructions and warnings
      5. Manufacturer/importer contact details
      6. Mandatory and/or recycling symbols
   4. Responsibility across supply chain:
      1. Manufacturers, importers and distributors must ensure compliance
      2. Obligation to report violations
   5. Legal basis: aligns with UN Convention on Rights of Persons with Disabilities and Spanish consumer protection law

This framework represents a significant shift in how consumer product labeling is designed and implemented. Beyond regulatory compliance, accessible labelling reinforces the cosmetics sector's commitment to inclusion, ethical responsibility and improved consumer trust.

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