TTIP will not lower consumer protection standards. Or so they say and so why should we assume otherwise? Well, because from time to time you come across over a detail in the haul of TTIP information which makes you question how such a guarantee can be given.
For instance, take the Commission’s factsheet on information and communication technologies (ICT) in TTIP. It mentions clearly that one of the objectives is to promote e-labelling to replace labels and stickers on packages.
Now, this might sound hyped, but such a move would constitute a clear and unacceptable lowering consumer information standards. Why?
Nice cost-saver for business, but a blow to consumer information
It is obvious that it is much cheaper for a company to use e-labelling methods than physical labels on packaging. Resorting to e-labelling would probably result in the kind of cost-reduction TTIP is trying to achieve. However, when labelling is to inform consumers – particularly in the areas such as food, chemicals or pharmaceuticals – on safe, healthy use of the product, e-labelling is not the way to go. For many reasons:
- Consumer information requirements are designed to help consumers make safe, healthy and overall well-informed choices. Therefore, this information must be as easily accessible to the consumer as possible.
- E-labelling requires electronic equipment that not all consumers want to have or can afford to have. Tools may malfunction, internet connections do not always work and mobile phone batteries let you down more often than not. This is far from the easy grasp on the shop shelf where the info is available at a glance.
- Shopping is not always the kind of relaxing experience you see in TV advertisements. If you have ever been in a supermarket with three children running from one shelf to the other, keeping a smartphone in your hand to read information might be too much. Or if you have taught a grandparent how to use a smartphone and run into difficulties, you will know the degree of difficulty involved in substituting e-labelling for print labelling. Or, if you need to check allergy information while cooking, do you really have enough hands available to manage an additional device?
- Having scanned a product a couple of times before, consumers might stop doing so after a while. But what if the composition of the product changes? In case of a physical label – e.g. saying “contains GMO” – a change would be immediately visible. They would go unnoticed when people stop scanning a known product.
Make no mistake, I am not against technology. E-labelling can be a useful additional tool for information, while there are plenty of apps which can assist decision making. (And there are connected grandmas and obedient kids.) Digitalisation is transforming the world for the better, as long as you manage it well and do not lose sight of what is trying to be achieved.
But when it comes to consumer information, digitalisation has to be handled with great care and a very in-depth assessment has to be carried out of the benefits and risks. Consumers are very different and special attention must go to the more vulnerable. I have serious doubt as to whether this has been done before the introduction of the concept of e-labelling in the TTIP talks.
Consumer advice needed?
What worries me most among these developments is the lack of understanding of consumer protection and needs within the TTIP talks.
There is a major disparity between stating vocally and publicly that TTIP will not lower standards and at the same time promoting publicly that e-labelling could be a tool to replace traditional labels.
This is even more worrying as e-labelling is being pushed by the US side as a way to replace on-pack, European GMO labels – one of the most sensitive issues in TTIP and certainly not one where consumers in the EU would like to give up the slightest inch of protection.
It is essential to understand that information requirements are an essential part of the consumer protection framework. The EU should think twice before rummaging in labelling requirement legislations. Because that would most certainly threaten the promise not to lower consumer standards.
Note: Léa Auffret, BEUC’s Trade policy officer contributed to the drafting of this blog post.