Origin Labelling, “Made in the EU” Claims and Fragmented Global Supply Chains

Titelangaben

Purnhagen, Kai:
Origin Labelling, “Made in the EU” Claims and Fragmented Global Supply Chains.
Ohne Angabe : Policy Department for Citizens, Equality and Culture: Directorate-General for Citizens' Rights, Justice and Institutional Affairs, 2026 . - (Briefing ) (PE 792.396)
ISBN 978-92-848-4208-7

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Abstract

Country-of-origin labelling has become an increasingly important component of consumer information,
marketing and regulatory compliance in the European Union (EU). However, the legal concept of origin
was developed primarily for customs purposes to determine the economic nationality of goods for tariffs,
trade defence and market access. It was not designed to communicate information about quality,
sustainability, labour standards or production conditions. Under the Union Customs Code, products are
generally assigned a single country of origin based on where they were wholly obtained or, where
production spans multiple countries, where they underwent their last substantial, economically justified
transformation.
The increasing fragmentation of global value chains has exposed the limitations of this approach. Modern
production is frequently distributed across several jurisdictions, with research, sourcing, manufacturing,
assembly and branding occurring in different countries, while EU law continues to attribute a single legal
origin. As customs concepts have progressively migrated into consumer protection, commercial
communication and sector-specific labelling legislation, legal origin, economic origin and consumers’
perception of origin increasingly diverge. Consequently, origin claims that are legally accurate under
customs law may nevertheless create a misleading impression about where a product was produced or
where most of its economic value was generated.
The briefing finds that the interaction between customs law, consumer protection rules and sector-
specific origin-labelling regimes, particularly in Food Law, creates structural ambiguities that reduce
legal certainty, complicate enforcement and enable strategically advantageous origin claims. Although
misleading or inconsistent origin representations have been identified across multiple sectors, the
available evidence remains fragmented, especially for non-food products, limiting a comprehensive
assessment of their prevalence across the internal market.
The current framework continues to support the functioning of the internal market by avoiding
mandatory national origin labelling with protectionist effects. Nevertheless, targeted reforms are
needed to clarify the relationship between customs origin and consumer-facing origin claims, strengthen
guidance on voluntary origin representations, improve coordination between enforcement authorities,
and enhance transparency where origin materially influences consumer decision-making.