Misleading labels, what is meant?

FPR imposes strict requirements on labels and requires specific information to be declared. However it also has a 'catch-all' requirement banning specific listings on your label. This is the so called 'anti-misleading' clause. Specifically in FPR Annex III Part 1 Article ( the regulation states that the information on the label: 

Annex III Part 1 Article 8: 

[...]
(a)
shall not mislead the user, for example by attributing to the product properties that it does not possess, or by suggesting that the product possesses unique characteristics which similar products also have;
(b)
shall relate to verifiable factors;
(c)
shall not make claims such as ‘sustainable’ or ‘environmentally friendly’ unless such claims refer to legislation, or clearly identified guidelines, standards or schemes, with which the EU fertilising product complies; and
(d)
shall not make claims by means of statements or visual representations that the EU fertilising product prevents or treats plant diseases or protects plants against harmful organisms.

Of course this is a very broad requirement and with the diversity of label designs it is impossible to know for sure what is and isnt misleading. Some examples however could be:

- Claiming the product is Co2 neutral with no evidence, or claiming any specific effect without proof this is concluded or follows by the nature of the product. 

- Claiming the product is suitable for EU organic farming, if you dont have any certification for organic farming.

- Claiming the product is biodegradable if it is not 

- Linking to a QR code on the label, and when you scan it a product page is shown where PPP effects are claimed. 

- Saying a PFC 1 product has a Biostimulating effect when it has not undergone the conformity assessment under PFC 6. 

Of course its impossible to cover everything, and so if you have questions do please reach out to us and we are happy to provide input!