5th November 2015
Joint Statement on the implementation of Directive 98/6/EC
AISE, ANEC and EuroCommerce serve 500 million consumers and respectively represent the
European detergent and maintenance products sector, European consumers in standardisation, and
the European retail and wholesale trade sector. Together, we have aligned on a common position in
respective to laundry products within the context of Directive 98/6/EC.
We collectively support the objective of the ‘Price Indication to Consumers’ (PIC) Directive to improve
consumer information and to enable them to more readily evaluate and compare the prices of
products and to make informed choices. However, our organisations believe that the directive has not
been appropriately implemented in some Member States, specifically as regards price indication for
laundry detergents products.
The ‘Price Indication to Consumers’ Directive obliges traders to indicate the ‘selling price’ (shelf price)
and the ‘price-per-unit’ on all the products sold to consumers. In order to do so, the legal text allows
traders to display the price ‘per unit of measure’ (e.g., for one kilogramme, one litre, etc.) or a different
single unit of quantity, which is “widely and customarily used in the member state concerned”.1
The Detergents Regulation (EC/648/2004) as amended by EU/259/2012 requires that the number of
‘wash loads’ must be clearly indicated on the pack of laundry detergents 2. With the entry into force of
this provision, it appears evident that ‘price-per-wash load’ constitutes the only appropriate unit of
measurement to truly allow useful comparison of prices and quantity across the various forms of
laundry products (i.e., powder, compact liquid, gel, tablets and capsules) 3. This also must mean that
this single unit of quantity (per-wash load) is de facto “widely and customarily used” in all EU Member
States, thus satisfying the requirement laid out in Article 2(b). of the PIC Directive.
Despite the fact that the Detergents Regulation recognises that ‘wash load’ is the valid unit of
measurement for laundry detergents and that the Price Indication to Consumers Directive recognises
that it is appropriate for Member States to allow appropriate ‘price-per-unit’ displays other than
price/kilogramme (or litre, etc.), ‘price-per-wash load’ is not uniformly accepted across the EU. Several
EU member states do not currently recognize it as a valid unit of measurement for laundry
detergents4.
Differences in implementation create confusion amongst retail companies which consequently have to
operate by different rules in different Member States. The lack of uniformed communication (e.g., ‘per
wash load’, ‘per service’, ‘per use’, ‘per dose’, etc.) also means that the wording and abbreviations
used even in the same Member State5 may be different and therefore confusing for consumers.
Our associations believe that in order to fulfil the purpose of the PIC Directive on consumer protection
and comparability of products through the provision of homogeneous and transparent information, it is
necessary for consumers to be provided in-store with the prices of the laundry detergents expressed
1
Directive 98/6/EC, Article 2(b)
EC No 648/2004, Article 11.4 and Section B of Annex VIII
3
The ‘price-per-wash load’ display is already used in several EU Member States such as Austria, Belgium, Czech Republic,
Denmark, Germany, Greece, Spain, Sweden, and the UK.
4
These include Estonia, Finland, France, Hungary, Lithuania, Luxembourg, Poland, Portugal and the Netherlands.
5
In Germany, WL (Waschladung) and WA (Waschanwendung) are used interchanbly, sometimes as abbreviations only, which
may confuse consumers.
2
per ‘wash load’. No other unit of measurement allows the comparison of different product types (i.e.,
powder, compact liquid, gel, tablets and capsules) and their respective concentration/compaction
levels. Thus a price/litre or kilogram is misleading in relation to the choice of laundry products.
We therefore call upon the European Commission to take action on Directive 98/6/EC so that ‘priceper-wash load’ is explicitly recognised for laundry detergents products within the context of Article 2(b)
and that the associated terminology used is standardised and aligned with the wording used in the
Detergents Regulation. This is necessary for the objective of the Directive to be achieved and to
ensure understanding and comparability of prices of laundry products for consumers.
We also request that EU Member States which have not already done so, recognise that ‘price-perwash load’ is a valid unit of measurement in the case of laundry detergents.
ANEC
A.I.S.E. represents the detergents and maintenance products industry
in Europe. Its affiliates include 9 direct member companies as well as
31 National Associations across Europe and beyond, covering more
than 900 companies ranging from small and medium-sized enterprises
to multinationals active in the consumer goods and professional
cleaning and maintenance products markets.
EuroCommerce
ERRT