Spain to Mandate Accessible Labelling for Cosmetics Under New Draft Royal Decree

On September 15, 2025, Spain notified the WTO of a draft Royal Decree introducing accessible labelling requirements for certain consumer products, including cosmetics, to enhance protection for vulnerable consumers, especially those with disabilities. The draft is open for public comment until November 14, 2025, and expected to be adopted in December 2025.¹

Scope and Objective

The draft Royal Decree introduces a framework for accessible labelling, referring to any statements, indications, marks, drawings, or symbols on product packaging or labels that allow persons with disabilities—particularly those with visual impairments—to clearly and easily obtain key information about a product's main characteristics. The framework applies to consumer products marketed in Spain that are vital to protecting the safety and well-being of persons with disabilities, including:

Cosmetic products
Hazardous substances and mixtures
Food products, including those containing allergenic ingredients or their derivatives

Products intended solely for industrial or professional use, as well as bulk items, unpackaged goods, or products packaged at the point of sale or on customer request, are excluded from the framework.

For all products within its scope, the draft Royal Decree sets out obligations across the supply chain. Manufacturers and, where applicable, their legal representatives shall ensure compliance when placing products on the market. Importers can only market products labelled according to the requirements, while distributors shall verify compliance before sale and promptly report any suspected non-compliance, along with corrective measures, to the authorities.

Compliance Requirements for Accessible Labelling

1. Information Required

Accessible labelling shall clearly present key product information that is also included on the standard label, with all mandatory statements appearing at least in Spanish unless exceptions apply. This includes:

1) Product name and brand name;

2) Name, address, and contact details of the responsible operating company (for food), or manufacturer (for other products);

3) Product category, composition, and intended use (if applicable);

4) Quality and quantity;

5) Date of production or supply, batch, and use or expiration date;

6) Usage instructions with guidance on disposal, warnings, and foreseeable hazards;

7) Customer service and support information;

8) Allergen or intolerance information, and nutritional information (if applicable).

For consumer products with a largest packaging surface of at least 10×1 cm, the product name shall be provided in Braille. Certain product categories may have additional Braille requirements, such as hazardous substances and food products containing allergenic ingredients.

2. Methods for Accessibility

Accessible labelling can use multiple methods to ensure universal access to product information. These include Braille, a quick response (QR) code or similar system, and elements that enhance cognitive accessibility or facilitate access to information and communication. Multiple methods can be applied simultaneously on the same product. Additionally, the following specific requirements shall be observed:

Required labelling items shall be provided at least through a reference or link to a QR code or similar system, scannable by mobile devices, linking to an accessible resource with product and safety details;
If the required items are not provided in Braille, the QR code or similar system shall include a tactile mark indicating its location. The mark shall take the form of a 90-degree angle composed of two raised lines (5–6 mm long, 1–2 mm thick, matching the height of the Braille used elsewhere on the packaging), with the code positioned inside the angle. The mark shall not overlap the code, and access shall not require identification, data processing, or any cost.

3. Packaging Considerations

For products with secondary or outer packaging, the accessible labelling obligations in Braille or other accessible formats apply only to the packaging in which the product is actually made available to consumers.

Implementation and Transition

Once adopted, this draft Royal Decree will take effect the day after its publication in Spain's Official State Gazette. Applicable consumer products that are already labelled but do not meet the new requirements can continue to be marketed for up to two years. After this period, if non-compliant packaging is used for previously manufactured products, the company shall add a sticker, inkjet marking, or equivalent system to ensure the required accessible labelling information is provided.