ETRC engages to highlight the unique nature of our retail channel and the challenges arising from the increasing demands for the provision of information to consumers.

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Challenges for the duty free and travel retail channel

In Europe and elsewhere in the world, we are now seeing a considerable increase in regional and national product specific legislation being introduced that were developed for application in domestic markets but have significant practical implications for our channel because of the unique conditions under which it operates. These conditions include the multiplicity of languages used by staff and customers, the location of a product’s place of consumption, security requirements and the nature of the supply chain. 

The strict application of EU and national legislation, which were negotiated without the specificities of the our sector in mind, restricts the ability of manufacturers to access this important market. Indeed, such stringent rules act as significant barriers to entry for new products, particularly for SMEs and local producers, inevitably restricting consumer choice even further.

ETRC advocates strongly that regulators consider adapting the application of existing EU and national legislation to the duty free and travel retail channel to take account retrospectively of the international marketplace that is being served, and of the nature and place of final consumption of the goods retailed. In the event of new legislation being put forward, this should at all times include specific rules tailored to the needs of the travel retail channel.

The FIC Regulation

As of 13 December 2014, Regulation (EU) No 1169/2011 of 25 October 2011 on the provision of food information to consumers (the “FIC Regulation”) replaces EU legislations on food labelling and the provision of nutrition information with a single regulation.

The FIC Regulation also specifies that the labelling of food products should be in a language easily understood by the consumers of the Member State where a food is marketed.


While ETRC worked with the EU institutions during the adoption process of the FIC Regulation to seek support for a specific language regime for food supplies in the duty free and travel retail sector – where ‘gifting’ is a primary motivation for purchasing, this proposal was ultimately rejected, and any reference to language exemptions was removed.

In 2020 the European Commission announced that it would carry out an impact assessment related to a proposal for a revision of the FIC Regulation in the areas of front-of-pack nutrition labelling, nutrient profiles, origin labelling, date marking and labelling of alcoholic beverages (list of ingredients and nutrition declaration) to follow-up on the announcements made in the Farm-to-Fork Strategy and Europe’s Beating Cancer Plan. ETRC and its members have been monitoring and contributing to the consultation process. 

For more information on the legislation, please visit the dedicated website of the European Commission.

Informing consumers in the duty-free and travel retail channel in the digital age

This duty-free and travel retail channel is made up of a global customer base of internationally diverse travellers, where the consumer may or may not even speak the language of the airport they are travelling through or airline or maritime vessel they are travelling on. Furthermore, many of the confectionery products supplied to this channel are travel retail gifting and/or travel retail exclusives, packaged specifically for this global retail channel and not available on domestic markets.

ETRC fully supports the principle that consumers should have access to relevant and meaningful information on the products they wish to purchase and consume. ETRC has been working for many years to find a pragmatic solution to providing consumers with product information in a way that meets both the requirements of the regulators and the specificities of our unique consumer, the international traveller.

ETRC argues that digital labelling through which mandatory information can be provided in a consumer-friendly format is the optimum solution to comply fully with regulatory requirements, while enabling our channel to continue to thrive and propose iconic products targeting an international audience.

ETRC Digital Labelling Platform: The creation of 'Duty Free Label'

In 2018, ETRC contracted for the development of a pilot project to create a digital platform for information to consumers in duty free and travel retail, across three core categories: Food & confectionery; Alcohol beverages; and Perfumes & Cosmetics. For the pilot, the consumer front-end was designed as a responsive website, and product information was accessible in several languages via a barcode on the packaging scanned by the consumer using a smartphone, scanner facilities in-store and on-line, ensuring that the information was available to all consumers at any time. 

Product information is provided directed by the suppliers as the responsible business operators, focusing on regulatory information, displayed on the consumer interface in a standardised format with clear landmarks across all product categories so that consumers can easily find the information they are looking for. 

The pilot project lasted from 2018 until 2019, and involved consumer research in a live airport environment, presentations in various meetings with policymakers and industry fora, workshops with ETRC members and continual improvements and enhancements of the technology solution. At the ETRC 2019 AGM, the decision was made to continue and move the project forward. The full press statement can be found here

Building on this first success, the ETRC Digital Labelling platform moved into its second phase involving a two-year project with 15+ suppliers with the objective to build a fully functional platform, concluding with the creation of a website ‘Duty Free Label’. Duty Free Label provides product information in multiple languages, which can be accessed when the barcode on the packaging is scanned via a smartphone or in-store scanners.

As part of this project, ETRC also conducted an online consumer survey of over 1000+ EU consumers who tested the usability of the platform. The survey provided overwhelmingly positive results, with 88% of respondents being satisfied with the platform, 85% of travellers considering the platform to be easy to use, and 74% considering themselves to be more likely to use digital labels compared to before the COVID-19 pandemic. For a copy of the consumer results, please contact us via email. 

10 years after the adoption of the “FIC Regulation” which foresaw that “Food information rules should be able to adapt to a rapidly changing social, economic and technological environment” (recital 51), ETRC believe our project and similar initiatives provide an opportunity to implement efficient and relevant solutions for the digital age. 

ETRC urges policy-makers to enact legislation to formally allow for product information to be provided by means other than on the package or on the label to better inform consumers in the digital age.