14 March 2014
Joint position paper
Origin marking: a tool to strengthen product safety
through transparency and traceability
This joint position paper is issued in the context of the proposed legislative package comprising a draft regulation on consumer product safety (CPSR, COM(2013)0078), which includes a key provision on mandatory origin marking on consumer products manufactured or imported into the EU (Article 7) that our federations strongly support. We highly welcomed the positive outcome of the Internal Market and Consumer Protection Committee vote endorsing Article 7, and in view of the vote in the European Parliament’s plenary, we wish to stress the following points:
Support mandatory origin marking for consumer goods
Mandatory origin marking for consumer goods (Article 7) should be maintained in the CPSR as originally proposed by the European Commission on 13 February 2013.
Our associations strongly believe that introducing a mandatory indication of origin on consumer products prevents consumers’ safety concerns through sound transparency, and it will improve traceability and product safety to the benefit of consumers, industry and of the European economy as a whole.
We would like to highlight that the proposal should not exclude construction products meant to be sold directly to consumers such as ceramic and woodworking construction goods harmonised under CPR No. 305/2011, which are also intended for consumer use and hence should be subject of the Chapter I of the CPSR and of its Article 7, as originally proposed by the European Commission. This is why, we call MEPs for the sole rejection of Amendment 44 adopted by the IMCO committee.
2. Help consumers recognising product safety and making informed choices
The indication of origin marking helps consumers to recognise the health & afety and social & environmental standards as well as the level of product afety applied. Safety is not only about companies respecting standards, but also about consumers being informed.
Article 7 represents a very important step in the reinforcement of the European consumers’ freedom of choice. As stated by the rapporteur, MEP Christel Schaldemose, in her draft report: “the indication of origin of the product would make it easier for consumers to access information about the product chain, thereby increasing their level of awareness” and “their confidence towards the Single Market”
See amendment 31 of the rapporteur’s draft proposal (PE 513.309).
In the last decade there has been a growing demand by consumers to increase and improve information on a product, including where the goods have been manufactured, before deciding which one to buy. Indeed, according to a 2010 Eurobarometer’s survey, a significant percentage of consumers make their buying decisions on the basis of the origin of products. This has been confirmed by a Matrix Insights study from 2013, which shows that 65% of consumers are interested in the origin of the product.
Overall, a mandatory origin marking demonstrates principles of European excellence as well as the respect of the best manufacturing practices and safety standards.
3. Improve transparency and traceability
Indication of origin is key to improving the transparency and supporting the traceability of consumer products to the benefit of consumers. With origin marking, consumers are provided with reliable and transparent information about the product.
As stated by the European Commission, the indication of origin on all consumer goods circulating within the EU will “facilitate the task of market surveillance authorities in tracing the product back to the actual place of manufacture and enable contacts with the authorities of the countries of origin ... for appropriate follow up actions”
In most cases the sole indication of the manufacturer’s address as required by current legislation has proved to be insufficient or misleading in the individuation of the actual producer, and the manufacturer’s registered address did not always correspond with the place of manufacture.
Mandatory origin marking would lead supply chains towards higher degrees of standards and rules. Indeed, more transparency facilitates traceability controls for preventing safety issues for consumers, also by likely reducing the amount of corrective actions to be engaged.
4. Promote a level playing field at international level
Origin marking is very important in order to foster a level playing field for all producers at international level. For us, introducing origin marking in Europe is also a question of reciprocity in trade. As highlighted by the rapporteur, mandatory origin marking on consumer products would be fully compatible with the rules of the WTO as it would cover “all non-food products on the territory of the Union, whether imported or not”
thereby excluding any risk of discrimination.
Furthermore, mandatory origin marking schemes are widespread outside the EU. They exist in markets such as the USA, Japan and China. Manufacturers active in those markets already comply with strict mandatory origin marking requirements. Its introduction at EU level would simply put European companies and consumers on an equal footing vis-à-vis their foreign counterparts.
Benefits to consumers outweigh any potential costs and administrative burden
Additional costs for enterprises applying the indication of origin are negligible in comparison to benefits it will bring to all stakeholders. This is confirmed by the signatories of this document, including European federations, national federations and their member companies.
Origin is identified according to non-preferential rules, well known by manufacturers and importers, and no additional research needs to be done.
See recital 21 of the proposed regulation on consumer product safety COM(2013)0078.
See amendment 32 of the rapporteur’s draft proposal.
Consumers need to know the origin of the product destined for consumption and where possible the most relevant safety aspect of its composition. If required, the indication of the origin of the product will guide enforcement authorities to identify swiftly the unsafe parts of the finished consumer product. In this respect, the definition of consumer goods should be further clarified.
In addition, the introduction of an EU-wide origin marking scheme in Article 7 will reduce fragmentation in the internal market. In fact, a variety of labelling initiatives are already being promoted in several EU countries and indelible origin marking is already applied in several sectors.
For these reasons, we call on the Parliament to support the introduction of a mandatory origin marking as proposed by the European Commission and already endorsed by the EP IMCO Committee.
Signatories of the joint position paper:
CEC – The European Confederation of the Footwear Industry Jean-Pierre Renaudin, President
CEI-BOIS - the European Confederation of woodworking industries Philip Buisseret, Secretary General
CERAME-UNIE – The European Ceramic Industry Association Alain Delcourt, President
EFIC – European Furniture Industries Confederation Markus Wiesner, President
EUROCOTON - European Federation of Cotton and Allied Textiles Michèle Anselme, Secretary General
EBMA – European Bicycle Manufacturers Association Moreno Fioravanti, Secretary General
European luxury goods and creative industries organisations:
Circulo Fortuny Carlos Falco, President
Fondazione Altagamma Armando Branchini, Vice-Chairman
Meisterkreis Clemens Pflanz, Managing Director