Labeling Non-Conformity in EU Consumer Protection Enforcement: A Five-Country Assessment of How Market Surveillance Results Are Reported, with a Romanian County Case

This is the authors' abstract. We don't add key points for this paper.

Accurate product information underpins consumer choice and the circular economy instruments of the Green Deal, yet the comparability of the evidence that national authorities publish on labeling non-conformity has rarely been examined. This study assesses publicly reported enforcement results from five EU Member States covering three levels of economic development (Romania, Germany, Poland, Croatia and Bulgaria), with a county-level case for Alba County, Romania. Each reported figure was coded by the unit inspected, denominator, product category, and design of the enforcement action. The reported values (67%, 23.9%, 19.8%, approximately 8.6%, 26.4% and 7.7 acts per 100 inspections) measure at least four different indicators and mostly come from targeted actions; expressed on a common basis, they do not support a convergent cross-country rate. None of the five data sets reported all elements of a proposed minimum reporting set (scores 1.5–3.5 of 5). The main finding is therefore that national systems report labeling non-conformity in non-comparable formats. Alba County ranked fifth of 42 county-level units by number of sanctions in 2025, but in the absence of inspection counts, no inference about enforcement intensity can be drawn. The paper proposes the reporting set and a literature-informed matrix linking non-conformity types to detection methods, and discusses, as an implication, why reliable composition data matter for textile recycling.