Labels are an extremely important communication tool. When I talk today about labelling, I don’t mean the “simple-sticking-a-piece-of-paper-or-plastic-to-a-packaging”. For my article today labelling for me encompasses all the information, which has to be shown (printed) on a packaging. Information, partly due to rules and regulations, partly to particular consumer requests and partly of course to the unforgettable graphics to please marketing.
I want to highlight the problems of label technology as a communication tool and in relation to recent developments in interactivity.
In the past marketing decided about the fancy-grade of the packaging graphics. In these days and much more so in the future the main, if not all, part of the information will be decided by regulations and the hunger of the consumer for more detailed information about the product, its composition and origin as well as its packaging.
And while we aren’t even at the end of all the information requests to be put on a label, we worsen the situation by making the packaging smaller and smaller and skipping the secondary packaging if possible.
Minimizing the size of packaging or foregoing the secondary packaging has its advantages, but consequently we face a much smaller printable area for consumer information.
And then we haven’t even spoken about Braille, the elderly with a restricted eye-view, an olfactory scratch-and-sniff label, temperature sensing labels, interactive packaging with animation and talking, 2D barcode, QR and AR code, RFID tagging, let alone anti-counterfeiting.
Where do we put all that increasing quantity of information?
The large bulk of the contemporary developments and innovations only offer solutions in the margin of the problem.
The only proper answer to solve this problem seems to be the implementation of connectivity or interactivity, whatever you want to call it, to ensure all the information is available to the consumer.
Interactivity between the consumer and the manufacturer by connectivity might be the solution, but as with every proper solution the implementation creates new problems to be solved.
When you want to step into the world of the serious interactivity in packaging, you have to look at two recent developments related to this area first. The first of the two is the position of the FDA in the USA, but I grant you that the position of the EU will not be any different. The FDA has taken the position that information provided on web sites is considered “labelling” of a given product if the product’s label contains a link to or direct the consumer to the site. That means the packager is responsible for the information on the site on the same basis as if it were on the package label. I come back about the consequences in a minute.
The second development is a sinister one. The “Investigatory Powers Bill” proposed by the UK would allow children’s smart toys to be used for spying by British law enforcement. It’s not difficult to see that the next step is the use of interactive packaging present in all and every household.
I will start with the sinister one and follow-up on the FDA position. After this I will give you some interesting examples of useful interactivity.
Sorry, as the first part of this article is a bit dull. But government regulation is important to act upon and follow, although I promise I will try to enliven the text a bit with some sarcastic comments regarding the UK.
The Investigatory Powers Bill
Sometimes you get the impression that it’s not the hackers (see my article: “Dangerous Idiocy In Packaging Interactivity”) we have to fear for interfering in the development of interactivity in packaging, but the unbridled hunger of government agencies for meddling in the privacy of its citizens.
Anyway, the government of the UK, still living in its dream world of being a world power, always have been (in)famous for its spying, despite the blundering and amateurism of its agencies in this field and not coming much further than being seen worldwide as the lap dog of their American cousins.
But whatever the case the consumer packaged goods companies have to face this intrusion, as members of the UK government believe connected toys could come in handy for spying. They introduced the draft “Investigatory Powers Bill” that would allow security and intelligence agencies to interfere with electronic equipment in order to obtain communication data from a device, i.e. toys. This would mean that government agencies could lawfully take over children’s playthings to monitor suspects.
With the Investigatory Powers Bill, the UK government proposes to make possible the ability to break end-to-end encryption implemented by private companies for their services.
It’s not difficult to see that this law will rapidly expand to other items on the market (keep in mind the unbridled hunger) and as such you can expect it for interactive packaging. What’s more attractive than household cleaners standing on the kitchen counter for weeks. Or better still imagine some packages lying around while you have a nice make-out session with your girlfriend or husband. On top of that, keep the blundering of the law enforcement agencies in mind and you can imagine that hackers will have a field day.
After this blatant show of impotency of the spies in our midst, let’s move to some serious items.
The legal perspective of interactive packaging
Packaged goods companies which consider implementing interactive connectivity on their packages, have to be careful when designing the information on the label as well as of the extra information they intend to provide via a connection to their website. From a legal perspective, it is important to note that the US Food & Drug Administration has taken the position that information about foods and beverages provided on websites is considered “labelling” of a given product if the product’s label contains a link to or direction of consumers to the site. That means the packager is responsible for the information on the site on the same basis as if it were on the label of the packaging, so that all statements need to be truthful and not misleading and any claims need to comply with FDA’s legal and regulatory requirements for, for example, health claims or nutrient content claims. The US Department of Agriculture takes a similar approach regarding meat and poultry labelling.
With this latest statement I have reached the point of showing my readers some interesting new developments in interactivity in packaging. In my next article we will discuss the “SmartLabel program”, an initiative of the Grocery Manufacturers Association, and a way to extend the content of a product’s label using an electronic link. After that we will see the Thinfilm-Constantia pressure sensitive labels on beverages, the Ardagh-FiliGrade interactive print on packaging and as last the Guala/NXP creation of interactive bottle closures.