Do the rules also apply to packaging that has already been printed?

What counts is the commercial practice towards consumers, not the date of printing. Since no general sell-off period is currently provided for, existing stock carrying critical claims should be planned for in good time and layouts changed early. The assessment in an individual case should be reviewed legally.

A simple order of work helps: first check which claims on the existing artwork are actually affected, then replace the critical ones, and only then schedule the remaining stock. The free claim check covers the first step and assesses up to five claims against EmpCo and the Unfair Competition Act.

For goods already on the market on the application date, the Commission services name practical options: covering or correcting a claim with a sticker and adding supplementary information at the point of sale. The authorities in the CPC network expect reasonable and proportionate steps that can be evidenced, and are not expected to require destruction or recall in such transitional cases where that would cause disproportionate costs or unnecessary environmental harm.