Global Guide to Shrinkflation

Are there dedicated regulations on shrinkflation in your jurisdiction?

No.

Are there any other measures against shrinkflation in your jurisdiction?

The Australian Government has stated that it will take action to fight shrinkflation by strengthening the Unit Pricing Code and raising penalties for breach of the Code. The Unit Pricing Code is a mandatory industry code for grocery retailers (both bricks and mortar and online) and sets out the rules for unit pricing. The Australian Government has indicated that it will be consulting on potential improvements to the Unit Pricing Code, such as:

• improving readability and visibility of unit pricing in stores;
• addressing inconsistent use of units of measure across supermarkets;
• whether to expand the scope of retailers covered by the Unit Pricing Code;
• more specific prominence and legibility requirements; and
• improving the use of unit pricing in cross-retailer price comparisons.

The Australian Competition and Consumer Commission (ACCC), Australia’s chief consumer law regulator, conducted an inquiry into supermarket practices in Australia. The ACCC Supermarket Inquiry Report (Report), published on 21 March 2025, highlights transparency issues around shrinkflation and presents regulatory recommendations. The Report defines shrinkflation as the practice of reducing the size or quantity of a product while maintaining the same price.

Greater transparency is needed

The ACCC considers that unit pricing is insufficient to notify of packaging changes, because many consumers:

• do not remember unit prices even for products which they purchase regularly; and
• will not compare unit prices every time they shop for products they purchase regularly, particularly if the price has not changed.

Regulatory Recommendations

To address transparency issues around shrinkflation, the Report recommends that supermarkets be required to publish notifications when package sizes change in a manner adverse to consumers; that is, by an increase in the unit price.

The Report suggests that these notifications should:

• include clear information on the previous price, package quantity or unit price of a product to identify that a change has occurred; and
• be published in proximity to the product ticket on shelves, and on website product pages, for a sufficient period to enable consumers to become aware of the unit price change.

This recommendation may be included in new sector-specific legislation or in the Unit Pricing Code.

Mode of notification

While the manner of notification would be a matter for public consultation, the ACCC suggests that it could include:

• a notice that the unit price of the product has been increased due to a change in package size; and
• information about the previous and current unit price.

The Report states that this information would, at a minimum, be required to:

• be published in proximity to the pricing ticket on shelves;
• include notifications on website product pages;
• be published for a set period (such as 1–2 months) which enables consumers to become aware of the unit pricechange; and
• be displayed prominently and legibly.

The Report recognised the importance of putting in safeguards in place to ensure that supermarkets cannot circumvent the rules by claiming that certain product or packaging changes result in the creation of an entirely new product (rather than an instance of shrinkflation).

The Report suggests that the onus should be placed on supermarkets, rather than solely on suppliers, to notify consumers, because:

• supermarkets are ultimately responsible for pricing and advertising prices to consumers; and
• notifications should be consistent within a store, so that consumers are aware of what to look for within a busy supermarket environment.

The ACCC considered that these notifications would not be overly burdensome, given the number of promotional tickets that are published by supermarkets on a weekly basis. The recommendations set out in the Report are now with the Australian Government for action.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction? 

The ACCC has commenced Federal Court proceedings against two leading Australian supermarkets for allegedly breaching the Australian Consumer Law by making misleading and deceptive pricing claims on products. Both proceedings remain ongoing.

Shrinkflation is not the focus of either proceeding, however the judgements are likely to impact how consumer products will be marketed to Australians in the future.

Is there any other important information on shrinkflation from your jurisdiction?

The Australian Government's current approach to addressing shrinkflation suggests that the practice itself is unlikely to be legally prohibited, and immediate focus will rather be directed at consumer awareness of unit pricing.

Contacts: Jessie Buchan and Gerry Bean

Are there dedicated regulations on shrinkflation in your jurisdiction?

No.

Are there any other measures against shrinkflation in your jurisdiction?

The Austrian Parliament has received several requests regarding shrinkflation and is continuously monitoring the situation.

The Consumer Protection Agency (Verein für Verbraucherinformation, VKI) and the Chamber of Labor (Arbeiterkammer, AK) have made several requests, such as:

• Legal regulation of shrinkflation
• Requirement for visible/transparent indication of net contents
• Clearer indication of the unit price (half of the product price)

These measures are still under discussion and have not yet been implemented.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

We are aware of two court cases involving shrinkflation in food packaging. In both cases, the Consumer Protection Agency (Verein für Verbraucherinformation, VKI) filed an injunction against the use of packaging that does not indicate the reduced contents. Both cases are still pending and there is no binding court decision yet.

The judgments in these two proceedings will set the standard for the further marketing of consumer products and are expected in the second half of 2025.

Is there any other important information on shrinkflation from your jurisdiction?

Shrinkflation has been raised by consumer advocacy groups in Austria. They argue that it can be considered a deceptive practice under existing unfair competition laws, which require transparency and honesty in product labeling.

While there is no legal regulation for shrinkflation in Austria, there is a legal prohibition of so-called “Deceptive Packaging” (Mogelpackung). Deceptive Packaging may give the misleading impression that it contains more than it actually does. In contrast, the size of the package itself is not misleading in the case of shrinkflation.

Contacts: Veronika Appl

Are there dedicated regulations on shrinkflation in your jurisdiction?

Currently, there is no legislation specifically targeting shrinkflation.

Recent legislative proposals to introduce specific labelling obligations in cases of shrinkflation and skimpflation (see below) were submitted by the French-speaking socialist party, but were ultimately rejected by the relevant committee in the Belgian Federal Parliament.

Given that the initiators of these legislative proposals have ended up in opposition and that the federal coalition agreement (that was reached in February 2025) makes no mention of shrinkflation or skimpflation, the proposals did not receive much support from the current governing majority. It is therefore unlikely that any dedicated regulations will be introduced in the near future.

Are there any other measures against shrinkflation in your jurisdiction?

Although the legislative proposals were rejected, they are noteworthy in that they reflected a growing awareness of, and concern about, this topic.

Submitted between January 2025 and April 2025, the different proposals aimed to amend the earlier legislative proposal of 23 September 2024. Among other things, the proposals included labelling obligations for large food retailers (classified under NACE code 47.11, with a sales area exceeding 400 square meters) in cases where the quantity of a product was reduced without a corresponding decrease in price (shrinkflation), or where ingredients were replaced or downgraded (skimpflation) without informing consumers. Under the proposed rules, such changes would have triggered a mandatory two-month labelling period to clearly inform consumers of the modifications.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

There is currently no published Belgian case law that deals specifically with shrinkflation or skimpflation under the framework of consumer protection legislation.

Is there any other important information on shrinkflation from your jurisdiction?

Even in the absence of dedicated legislation and published case law, shrinkflation may, depending on the circumstances, be considered a misleading commercial practice under the general rules prohibiting such unfair practices (Book VI of the Belgian Code of Economic Law). The topic also remains on the radar of Belgian consumer associations such as Testaankoop, so we do expect to see initiatives or actions in this area in the near future.

Contacts: Alexis Fierens, Jean-Michel Detry and Emma Stockman

Are there dedicated regulations on shrinkflation in your jurisdiction?

No.

Are there any other measures against shrinkflation in your jurisdiction

We are not aware of any current or planned legislative changes regarding shrinkflation in China.

However, while there are no direct measures against shrinkflation, relevant provisions regarding price labelling may be used to protect consumer rights.

According to the Price Law of the People’s Republic of China, operators are required to clearly label the price in accordance with the regulations of the government pricing authority. This includes indicating the name, origin, specifications, grade, pricing unit, price of the goods, or the items and charging standards of the services. Additionally, operators must adhere to the principle of good faith when conducting transactions with consumers.

According to the Provisions on Clearly Marking Prices and Prohibiting Price Frauds, operators are prohibited from engaging in price fraud behaviors, such as not marking or significantly weakening the marks of price conditions that are unfavorable to consumers or other operators.

Failure to comply with the obligations regarding price labelling could result in rectification orders, fines, etc.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

We are not aware of any legal cases regarding shrinkflation in China.

Is there any other important information on shrinkflation from your jurisdiction?

Although there are no national regulations or direct measures against shrinkflation, some local market regulatory authorities have issued notices to local operators in the catering industry, requiring them to avoid shrinkflation.

However, we are not aware of any cases where penalties were imposed for shrinkflation in accordance with such notices.

Contacts: Horace Lam and Windson Li

Are there dedicated regulations on shrinkflation in your jurisdiction?

No.

Are there any other measures against shrinkflation in your jurisdiction?

The issue of shrinkflation has not yet been legally addressed.

The Czech legislation deals with the issue of misleading consumers with the Consumer Protection Act, which specifies illegal practices conducted by manufacturers to persuade consumers into buying a product by providing a false information that induces a purchase.

Manufacturers are obliged to indicate the weight of the product on the label and shop owners must always display the unit price of products.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

Czech courts have not yet addressed the issue of shrinkflation.

Nevertheless, it is possible to file a complaint with the Czech Trade Inspection Authority regarding suspected unfair competition.

Is there any other important information on shrinkflation from your jurisdiction?

The Ministry of Industry has issued a consumer policy strategy for the years 2021 to 2030, which has as one of its objectives to strengthen control activities aimed at violating the legal provisions on the prohibition of unfair commercial practices.

Contacts: Tomáš Ščerba and Jan Metelka

Are there dedicated regulations on shrinkflation in your jurisdiction?

No.

Are there any other measures against shrinkflation in your jurisdiction?

No current or planned legislative changes.

Other measures against shrinkflation are section 3 of the Danish Marketing Practices Act (the general clause concerning good conduct), sections 5-6 of the Danish Marketing Practices Act regarding misleading marketing and the Danish rules on food labelling including mandatory requirements such as net quantity of the food.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

No.

Is there any other important information on shrinkflation from your jurisdiction?

Ongoing discussions in the press regarding companies marketing their products in case their products contain more content/food/volume than usual (for example 20% MORE). However, they do not market when the products contain less content/food/volume than usual.

Some products shrink because the product itself has become more efficient, eg detergents.

Contacts: Anette Moll Berg

Are there dedicated regulations on shrinkflation in your jurisdiction?

No.

Are there any other measures against shrinkflation in your jurisdiction?

While there are no specific regulations explicitly addressing this issue in the UAE, the Federal Law No. 15 of 2020 on Consumer Protection (Consumer Protection Law) protecting the following consumer rights may apply to this issue:

• The right to obtain correct information about the goods or services purchased;
• Prohibition against misleading advertisements in relation to the prices of goods or services.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

We are not aware of any relevant case or decision. It is also worth noting that the UAE is a civil law country and court judgements or punishment decisions by governmental authorities are generally not published.

Is there any other important information on shrinkflation from your jurisdiction?

The issue of shrinkflation has been recognised by consumers and widely reported in the news. However, at this stage, we are not aware of any developments on the judicial or legislative fronts to tackle this issue specifically, other than the general prohibition against misleading advertisements stipulated in the Consumer Protection Law.

Contacts: Saba Al-Sultani, Alicia Ma and Grace Pigott

Are there dedicated regulations on shrinkflation in your jurisdiction? 

No.

Are there any other measures against shrinkflation in your jurisdiction?

We are not aware of any legislative or other measures regarding shrinkflation that are in place or planned in Finland.

Please note that a Government Decree on Indicating the Price of a Consumer Product in Marketing (553/2013) which complements the relevant provisions concerning the price information stipulated in the Consumer Protection Act (38/1978) contains an obligation to indicate the selling price and unit price (unit price means the price including tax per unit of weight, volume, or length), in retail sales. The purpose of the rules is to make it easier to compare the prices of packages of different sizes. Thus ‘shrinkflation price’ also must comply with the above requirements.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

No. 

Is there any other important information on shrinkflation from your jurisdiction?

The Consumers’ Union of Finland (Kuluttajaliitto) is a non-governmental general consumer organisation. It completed an open consumer survey on shrinkflation during the period of 24 March 24 to 31 August 31, 2023. In total 735 observations of product shrinkflation was submitted to the Consumers’ Union. The Consumers’ Union considered that a potential gray area in marketing arises when reductions in product size are intentionally downplayed for undisclosed reasons. The Union was contemplating whether marketing might be deemed misleading if the package size, including its content, is diminished, about by one-fifth, without open communication to consumers, while marketing tactics persist unchanged. The survey findings have been submitted by the Consumers’ Union of Finland to the Finnish Competition and Consumer Authority (FCCA).

To our knowldge the FCCA has not taken further actions regarding the shrinkflation or at least there is no information of any such actions or investigation in public domain.

Contacts: Satu-Anneli Kauranen

Are there dedicated regulations on shrinkflation in your jurisdiction?

Yes.

A decree regarding shrinkflation was adopted on 16 April 2024 and modified by a decree adopted on 28 June 2024. The definitive version entered into force on 1 July 2024.

As per this decree, distributors must inform consumers of price increases resulting from reductions in the unit quantity of fast-moving consumer products sold.

Scope of application:

• Obligation applicable to distributors with a sales area of over 400 square meters;
• For fast-moving consumer products, as defined by Section L. 441-4 of the French Commercial Code, sold in constant quantities (weight, volume), but it does not apply to bulk products and pre-packaged products sold in variable quantities;
• In force as from 1 July 2024.

Information obligation:

• Mandatory wording on the packaging or on a visible label attached to or placed near the product
• Mandatory wording: “For this product, the quantity sold has increased/decreased from X to Y, and its price per (specify the unit of measurement concerned) has increased by ...% or ...EUR.”;
• Wording in the same font size as that used to indicate the unit price of the product, and in place for two months following its release for sale in reduced quantities.

Sanction:

• Administrative fine of up to EUR3,000 for a natural person and EUR15,000 for a legal entity;
• Injunction to cease the infringement; and
• Publication of the decision at the distributor’s expense.

The obligation only applies to distributors ie entity purchasing goods for resale in the same condition as received. However, from a practical point of view, it is up to distributors to ask their suppliers/producers, both French and foreign, to implement this system, and for suppliers/producers to inform their customers (ie distributors) in good faith about any “discreet” reduction in unit quantities of their products.

Are there any other measures against shrinkflation in your jurisdiction?

No planned legislative change.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

There is no specific case law in which shrinkflation was challenged since the decrees entered into force.

However, prior to the decrees’ issuance, shrinkflation was subject of two court cases opposing suppliers and distributors. Distributors communicated on shrinkflation practices of suppliers through signs placed near the supplier’s products sold in their stores. In one of the cases, the distributor was not sanctioned as the communication was based on substantiated information. In the second case, the distributor was sanctioned on the ground of unfair and misleading commercial practice.

Is there any other important information on shrinkflation from your jurisdiction?

The French Competition and Consumer Authority (Direction Générale de la Concurrence, la Consommation et la Répression des Fraudes – DGCCRF) published a FAQs on the enforcement of the decree.

Contacts: Gregory Tulquois and Mathias Kuhn

Are there dedicated regulations on shrinkflation in your jurisdiction?

No.

Are there any other measures against shrinkflation in your jurisdiction?

No.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

We are aware of two court cases regarding deceptive packaging and shrinkflation.

In 2024, German Federal Court of Justice (Bundesgerichtshof – BGH) ruled on the prohibition of deceptive packaging under Sec. 5 German Unfair Competition Act (Ruling dated 29 May 2024 – File-No. I ZR 43/23). The relevant points include the following:

• The accusation of deception of the consumer can be raised independently of the distribution channel and thus also in the case of distribution via online channels.
• Whether there is deception depends on the understanding that the respective packaging material evokes in the average consumer, who is reasonably well informed and reasonably circumspect and pays the attention appropriate to the situation. This understanding is further specified in the judgment.

In 2024, the Hamburg Regional Court also issued a more specific ruling on shrinkflation (ruling dated 13 February 2024 – File-No. 406 HKO 121/22). According to this decision, the reduction of the filling quantity in the same packaging and at the same price is unlawful under Sec. 5 of German Act on Unfair Competition. The judgment is not yet final and legally binding. The relevant points include the following:

• A conduct is deceptive if the product has previously been sold in packaging that is identical except for the fill quantity indication, unless a clearly visible explanatory note about the changed fill quantity was provided.
  
• The reference point is the circumspect average consumer, who is adequately aware of the situation.
• In the case of relevant product changes, the mere indication of the filling quantity is not sufficient, and the product must contain a clearly visible explanatory note. This note must be attached for an appropriate period of time (in this case: at least 3 months).

Is there any other important information on shrinkflation from your jurisdiction?

Hamburg Consumer Advice Centre publishes a continuously updated nationwide list of products with hidden price increases based on consumer complaints (so-called ‘Mogelpackungsliste’).

The Federation of German Consumer Organizations is demanding comprehensive measures to curb deceptive packaging, shrinkflation and skimpflation (a reduction in product quality due to the reduction of ingredients that add value or their partial replacement with cheaper alternatives, without reducing the retail price).

While there are no provisions that specifically address shrinkflation, the topic is touched upon by general provisions on packaging:

For so-called ‘deceptive packaging’, in which only the volume of the specific packaging material of the product suggests a product quantity that is not actually present, Sec. 43 para. 2 of the German Weighing and Measures Act (MessEG) can be used to describe the phenomenon. It prohibits the import, placing on the market or otherwise making available of pre-packaged products which, due to their design and filling, suggest a larger quantity of product than they actually contain. According to case law (based on the non-binding administrative guideline “Allgemeine Grundsätze für die Gestaltung von Fertigpackungen i. S. von § 17a Eichgesetz vom 31.1.1972”), a deception is usually assumed if the packaging is filled to less than 70%.

Under the German Price Indication Ordinance (Preisangabenverordnung), basic prices by weight, volume, length or area must always be indicated in the form price/quantity unit for goods or services provided by businesses to consumers.

In addition, according to German Packaging Act provides for a general requirement to limit the volume and mass of packaging to the minimum appropriate amount necessary to ensure the safety and hygiene of the product to be packaged and its acceptance by the consumer.

Contacts: Guido Kleve and Hauke Tammert

Are there dedicated regulations on shrinkflation in your jurisdiction?

No.

Are there any other measures against shrinkflation in your jurisdiction? 

The Consumer Council has advocated for greater transparency and consumer protection by requesting manufacturers and retailers to:

• clearly label any changes in product volume/weight; and

• display the cost per standard unit of measure.

However, such suggestions have no legal effect and failure to observe the Consumer Council’s recommendations will not result in legal ramifications.

We are not aware of any current planned legislative changes to address shrinkflation in Hong Kong.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

We are unaware of any publicized challenges on shrinkflation under consumer protection legislation in Hong Kong.

Having said that, the Consumer Council has published an article in late 2024 discussing a survey it has conducted highlighting the trend of shrinkflation observed in the retail market as well as setting out recommended actions for consumers to discern shrinkflation.

Is there any other important information on shrinkflation from your jurisdiction?

While there is no specific legislation for shrinkflation in Hong Kong, certain provisions of the Trade Descriptions Ordinance (TDO) may be relevant in protecting consumers from shrinkflation practices.

Particularly, the TDO provides that a trader commits the offence of misleading omission in case it fails to provide material information which causes the average consumer to make a transactional decision that he would not have made otherwise. For example, if a product is sold at the same price and uses the same packaging but contains less content than before, this may be considered an act of misleading omission if the consumer is not notified of the reduction of content in the good being purchased.

Contacts: Lauren Hurcombe and Venus Cheung

Are there dedicated regulations on shrinkflation in your jurisdiction?

Hungary has introduced a specific legal framework to address shrinkflation through Government Decree No. 1/2024., which – as of 1 February 2024 – obliges retailers to provide information to consumers regarding reductions in packaging unit for pre-packaged products.

The decree applies to those retailers whose annual turnover in the last audited financial year exceeded HUF 1 billion and requires them to inform consumers when a product’s packaging unit − particularly in weight or volume − has been reduced by the manufacturer compared to the standard packaging unit used between the “base period”, which is defined as between 1 January 2020 and 1 July 2023. The obligation also applies to products placed on the market between 1 July 2023 and 1 February 2024, if they were still distributed in February 2024 (whereby they had to provide the extra information as from 1 March 2024). 

The obligation to provide extra information to the consumers lasts for two months from the date the reduced-size product is introduced to the market.

The goal of the regulation is to mitigate food inflation by ensuring transparency, preventing misleading commercial practices, and enhancing consumer protection.

In order to enable the retailer to fulfill its above obligations under the decree, the decree also put certain obligations on the manufacturer of the product (or its first distributor / wholesaler in Hungary). Namely, they shall

• provide the retailer with information in writing (in the product documentation or otherwise) about the size-reduction and about the first occasion of the sale of the reduced-size product;
• also inform the National Authority for Trade and Consumer Protection (NKFH) with the same content.

There is also an implementing ministerial decree to the above Government Decree (Ministry of Economics Decree No. 7/2024.), which specifies the format and placement of information signs.

These signs must be clearly visible at the point of sale and must include:

• A statement that the product’s packaging has been reduced,
• The previous weight or volume,
• The new weight or volume,
• The percentage reduction.

Failure to comply with the above obligations may result in an administrative fine of up to HUF 1 million. The local consumer protection authorities (which are the county government offices) are responsible to ensure compliance with the legislations.

Are there any other measures against shrinkflation in your jurisdiction?

To enhance transparency and consumer awareness regarding shrinkflation, the National Authority for Trade and Consumer Protection has launched an online platform dedicated to providing information on shrinkflation to consumers (in Hungarian). The website contains detailed information about those “shrinked” products that were notified to the authority.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

We are not aware of any notable cases.

Is there any other important information on shrinkflation from your jurisdiction?

In addition to the specific Hungarian regulatory requirements, shrinkflation may be relevant from a general consumer protection perspective, in particular under the prohibition of unfair commercial practices vis-à-vis consumers.

Specifically, both consumer protection authorities and – in nation-wide cases – the Hungarian Competition Authority (GVH) have the power to investigate cases where shrinkflation might constitute a misleading commercial practice, particularly if price increases are disguised through reduced packaging without clear disclosure.

Contacts: Zoltán Marosi, Rebeka Bakos and Panna Virág

Are there dedicated regulations on shrinkflation in your jurisdiction?

No.

Are there any other measures against shrinkflation in your jurisdiction?

Though it has been much discussed in the media and has been raised in parliamentary debates, there are no specific legislative measures in Ireland that address shrinkflation.

Section 43 of the Consumer Protection Act, 2007 (as amended) prohibits misleading commercial practices. A practice will be deemed to be misleading if it contains false information or information that is likely to cause the average consumer to be deceived or mislead, in relation to the characteristics of a product and, as a result, the consumer makes a transactional decision that they would not otherwise make. These characteristics include the quantity, weight or volume of the product and the price of the product, the manner in which it is calculated or the nature of a particular price advantage.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

No.

Is there any other important information on shrinkflation from your jurisdiction?

The Consumers’ Association of Ireland (CAI), Ireland’s primary consumer advocacy group, has called for Ireland to take action to address shrinkflation.

The Chairperson of the CAI has called for legislation to be introduced that would require retailers to put notices on goods that have been reduced in size without a cut in the price (as has been done in France).

Contacts: Michael Twomey and Sarah Murphy

Are there dedicated regulations on shrinkflation in your jurisdiction?

Yes, see below.

Are there any other measures against shrinkflation in your jurisdiction?

In December 2024, Italy took legislative measures to address the phenomenon of shrinkflation, implementing a dedicated provision within Law No. 193 of 16 December 2024 (the Annual Law for the Market and Competition).

In particular, Article 23 of the Annual Law for the Market and Competition, titled “Provisions on the reproportioning of Prepackaged Products”, amends Legislative Decree No. 206/2005 (the Italian Consumer Code) by introducing Article 15-bis.

Such provision introduces an obligation for the producer to inform consumers about the reduced quantity of product purchased.

Specifically, Article 15-bis provides that:

1. “Producers who offer for sale, also through distributors operating in Italy, a consumer product that, while maintaining the previous packaging, has undergone a reduction in the nominal quantity and a related increase in the price per unit of measurement, shall inform the consumer about the reduced quantity by affixing, in the principal visual field of the packaging or on an adhesive label, the following wording: “this package contains a product that is X (unit of measurement) less than the previous quantity”.
2. “The information obligation referred to in paragraph 1 shall apply for a period of six months from the date on which the product concerned is placed on the market.”;

The entry into force of the provision has been postponed from 1 April 2025 to 1 October 2025.

Several issues have been raised concerning the described measure, particularly in relation to its compatibility with EU Directive 2015/1535 and its procedure, the Technical Regulation Information System (TRIS), which could indeed have an impact on the enforceability of the provision.

For further details on this, please refer to the answer provided under Question 4.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

Over the years Italian consumer associations have drawn significant attention to the issue of shrinkflation, prompting the Italian Competition Authority (AGCM) to closely monitor the phenomenon.

To date, there has been one notable case in which the AGCM has found that the conduct of a company active in the manufacture and distribution of kitchen rolls amounted to shrinkflation, which the AGCM defined as “the reduction in the size or weight of a product at the same price, typically in response to rising production costs, inflation or increased competitive pressure”.

In the mentioned case, the company had reduced the length of its product while keeping the price unchanged, to offset rising raw material and energy costs. However, it continued to indicate the original length (100 meters) on the product packaging and its online catalog, misleading consumers about the actual quantity.

The AGCM found this practice to be misleading under Articles 20(2) and 21(1)(b) of the Italian Consumer Code and imposed a EUR15,000 fine on the company (sanctions for unfair commercial practices range between EUR5,000 and EUR10,000,000).

Considering the recent steps taken by the Italian Parliament to tackle the phenomenon of shrinkflation and the provision expressly dedicated to shrinkflation we expect to see increased regulatory scrutiny and further enforcement actions in the near future.

Is there any other important information on shrinkflation from your jurisdiction?

A key aspect of the Italian provision on shrinkflation (Art. 15-bis of the Legislative Decree No. 206/2005) relates to the potential issues on its enforceability in light of the incompatibility with the TRIS procedure of the legislative process leading to its enactment.

Indeed, under Article 5 of Directive 2015/1035, Member States are required to notify the EU Commission without delay of any draft technical regulation they intend to implement, together with a brief explanation of the reasons for its adoption. If concerns arise the Commission may issue a detailed opinion.

The new legislation was duly notified to the European Commission on 7 October 2024, and the EU Commission, after having examined the proposal, on 12 December 2024 issued a detailed opinion raising several concerns about the measure.

Among the various problems identified in relation to the provision, the EU Commission also highlighted the lack of a transitional period for implementing the measure. It emphasized that the introduction of an appropriate timeframe was essential in order to give producers sufficient time to adapt to the new requirements.

The EU Commission also reminded Italy of its procedural obligations following the delivery of its detailed opinion. It stressed that any amendments to the proposed measure have to be duly notified to the Commission in accordance with Directive 2015/1535. Additionally, it warned Italy that failure to comply with its obligations under Directive 2015/1535 could have resulted in infringement proceedings under Article 258 TFEU.

Despite this, the Italian legislator proceeded with the implementation of the technical regulation in its original form without any amendments.

On 12 March 2025, the European Commission formally opened infringement proceedings by sending a letter of formal notice to Italy (INFR(2025)4000) for failing to address the incompatibility of its labelling requirements with Articles 34-36 of the Treaty on the Functioning of the European Union (TFEU). The Commission contends that the Italian authorities have not provided sufficient evidence to justify the proportionality of the measure, particularly given the availability of less restrictive alternatives (e.g., displaying the same information near the relevant products). Furthermore, the Commission also considers Italy to be in breach of Directive (EU) 2015/1535, as the measure was adopted during the standstill period and without taking into account the concerns raised in the detailed opinion.

Following the formal notice, Italy had two months to respond and address the shortcomings raised by the Commission. However, as of today, no reply appears to have been submitted by the Italian authorities, nor has the Commission issued a reasoned opinion on the matter. Should Italy fail to provide an adequate response, the Commission may decide to proceed with the next steps of the infringement procedure, including – but not limited − to issuing a reasoned opinion.

Given the ongoing infringement procedure and the shortcomings identified by the Commission, there is a significant possibility that the provision may be considered unenforceable at a national level. Indeed, failure to notify a technical regulation to the EU Commission or failure to properly follow the procedure established by Directive 2015/1535 results in the inapplicability of the national provision and its unenforceability against private parties. Consequently, any interested party could challenge the provision before national courts, which would then be obliged to disapply it.

In light of the above, there is a significant possibility that the provision will remain ineffective, and it will therefore be important to monitor the situation closely in the upcoming months.

Contacts: Elena Varese, Alessandro Ferrari and Federico Maria Di Vizio

Are there dedicated regulations on shrinkflation in your jurisdiction?

No.

Are there any other measures against shrinkflation in your jurisdiction?

No.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

No.

Is there any other important information on shrinkflation from your jurisdiction?

It is necessary to indicate the exact amount of food in a package under Japanese labelling law but it is not necessary to inform consumers when decreasing the amount.

Contacts: Beelian Tay, Masahiko Ishida and Tomomi Fujijkouge

Are there dedicated regulations on shrinkflation in your jurisdiction? 

No.

Are there any other measures against shrinkflation in your jurisdiction? 

No.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

No.

Is there any other important information on shrinkflation from your jurisdiction?

No.

Contacts: David Alexandre and Adélia Valladares

Are there dedicated regulations on shrinkflation in your jurisdiction?

No.

Are there any other measures against shrinkflation in your jurisdiction?

There are not any measures against shrinkflation, nor any legislative changes planned.

The Dutch consumer organization (Consumentenbond) announced in 2023 they are actively researching on how to combat shrinkflation in court, eg under the Dutch implementation of the Unfair Commercial Practices Directive (link in Dutch). They have put this on the radar of the Dutch (governmental) Authority for Consumers & Markets (ACM). However, the ACM indicated that this needs to be assessed on a case-by-case basis and that it is not going to proactively monitor and enforce markets on this.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

We are not aware of any challenges on shrinkflation under consumer protection litigation.

Is there any other important information on shrinkflation from your jurisdiction?

While there are no specific regulations for shrinkflation in the Netherlands, misleading advertising and unfair commercial practices are prohibited. For example, the Consumentenbond stated that changes in familiar products and packaging should be announced in the just as increases of packaging are announced.

Contacts: Niels Mulder, Rens van Blaricum and Rutger Stoop

Are there dedicated regulations on shrinkflation in your jurisdiction?

No.

Are there any other measures against shrinkflation in your jurisdiction?

No, a proposal brought forward in the Norwegian Parliament in 2022 by a representative of the Norwegian Red Party demanding mandatory labelling of the packaging of products that have been reduced in size was not followed up by the Government.

The Norwegian Consumer Authorities have, however, stated in a 2024 position paper that “packages that have become smaller must be labeled”.

We have not seen any further official statements from any governmental agency related to shrinkflation.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

No, despite media attention related to shrinkflation, especially within the groceries market in Norway, we are not aware of any cases involving shrinkflation as such.

The Norwegian Consumer Authorities have stated that downsizing packages without labeling is permitted provided that: (i) unit price and (ii) kilogram prices are both displayed on the in-store shelf (or online for the specific product in online stores).

Is there any other important information on shrinkflation from your jurisdiction?

No, regardless of Norwegian version of the term shrinkflation (Nw: Krympflasjon) in 2022 was announced as the Norwegian ‘word of the year’ by the Norwegian Language Council, and despite vigorous public attention towards price increases with a special focus on groceries in Norwegian media and among parliamentarians in recent years, there have been few official statements on potential measures concerning shrinkflation as such.

Contacts: Oda Linneberg Uggen and Kjetil H. Johansen

Are there dedicated regulations on shrinkflation in your jurisdiction?

No.

Are there any other measures against shrinkflation in your jurisdiction?

No. There is no public information on any legislative work or plans in this regard.

In 2023, the President of the Office for Competition and Consumer Protection (Prezes Urzędu Ochrony Konkurencji i Konsumentów, UOKiK) commissioned a report on the experience of Polish consumers with shrinkflation, prepared by a group of independent experts from one of the Polish universities.  The report concludes with recommendations that UOKiK should take on the role of a promoter of best practices and that there should be a legislative change in information obligations. So far, however, no official action has been taken.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

No, there is no publicly available information on notable cases in this regard.

Is there any other important information on shrinkflation from your jurisdiction?

In media statements, representatives of the UOKiK confirmed that changing the size of the packaging or the weight of a product is possible and allowed, but it must not be misleading.

Contacts: Andrzej Balicki and Jolanta Dabrowicz

Are there dedicated regulations on shrinkflation in your jurisdiction?

No.

Are there any other measures against shrinkflation in your jurisdiction?

Deco - Associação para a Defesa do Consumidor (Association for Consumer Protection) presented a request to the government in 2022 and to Parliament in 2023 for legislation to be created to reinforce transparency and the obligation to inform consumers about products subject to shrinkflation.

However, neither the Government nor Parliament has acted on this request to date.

DECO has proposed the creation of specific regulations for  shrinkflation through an amendment to the Consumer Protection Act (Law no. 24/96, of 31 July), containing rules that reinforce consumer information through clear information that there has been a change in the quantity of the product, highlighting the ‘before’ and the ‘after’, stipulating an obligation to provide consumer information when there is a quantitative change in pre-packaged products offered for sale.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

We are not aware of any court cases involving shrinkflation in food packaging.

Is there any other important information on shrinkflation from your jurisdiction?

Shrinkflation has been raised by the main consumer protection association (DECO) in Portugal, especially in 2022 when inflation rose drastically and the price of products in the food basket has risen.

DECO did not consider the reduction of quantities to be illegal, if this information is correctly labelled on the product, otherwise it would be considered a situation in which ‘the information is misleading”, which is an unfair commercial practice.

Nevertheless, DECO warned that the practice of shrinkflation is a price increase, even if indirect, and in a climate of rising inflation, reinforcing the duty of information is fundamental for consumers.

Contacts: Benjamim Mendes and Catarina Portela Morais

Are there dedicated regulations on shrinkflation in your jurisdiction?

Yes. ANPC (ie. Romanian consumer protection authority) adopted Order 539/2024 regarding consumer information when selling pre-packaged products where volume or weight has decreased (Order), in force as of 10 October 2024.

Summary of the main provisions of the Order:

• In order to ensure a high level of consumer protection and a good functioning of the internal market, this Order regulates aspects relating to the direct and indirect protection of consumers against market malfunctions with repercussions on them, by informing them about certain commercial practices that involve reducing the volume or weight of a product while maintaining the same price.

• It is the obligation of economic operators who sell products intended for consumption on the shelf in sales premises to inform consumers completely, correctly and precisely about the modification of product quantities by reducing their volume or weight, having the presentation, packaging, shape, but not limited to these, identical, under the conditions of maintaining the same price. This order does not apply to distance sales.

• There are certain mandatory information requirements for the changes, eg to use a signaling display stating that the weight/quantity changed but the price remained the same or other, under a template model set by the authority, with a certain font, height etc.

• The information obligation shall apply for a period of at least 30 days from the date on which the reduced-volume or reduced-weight product is put on sale at the shelf.

Are there any other measures against shrinkflation in your jurisdiction?

We are not aware of any other measures against shrinkflation planned in Romania.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

We have not identified publicly available, recent case law tackling shrinkflation.

Is there any other important information on shrinkflation from your jurisdiction?

Prior to the entry into force of the Order, the ANPC was available to advise economic operators who wished to do so, in order to apply the provisions of the normative act.

As a result, based on public information, meetings were held with the Association of Large Commercial Networks in Romania (AMRCR), during which various aspects related to the display methods imposed by this order were discussed, giving as an example how other countries in the European Union have found solutions for informing consumers by economic operators on this issue.

In October, acting president of ANPC mentioned in a press release that ANPC will strictly monitor the application of this Order and will not tolerate any kind of deviations.

Contacts: Amalia Musat

Are there dedicated regulations on shrinkflation in your jurisdiction?

No. Currently, there are no specific regulations addressing shrinkflation in Singapore.

Are there any other measures against shrinkflation in your jurisdiction?

There are no direct measures against shrinkflation in Singapore. There are also no current legislative changes specifically targeting shrinkflation.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

There have not been any specific or notable court cases in Singapore that challenges consumer protection legislation on the grounds of shrinkflation.

Is there any other important information on shrinkflation from your jurisdiction?

Whilst there have not been any specific regulations or legislative changes specifically targeting shrinkflation at the time of this writing, there are consumer protection laws in Singapore that generally protects consumers against unfair practices carried out by a business in Singapore.

In this regard, the Consumer Protection (Fair Trading) Act (CPFTA) in Singapore protects consumers against unfair business practices by allowing them to seek civil redress against suppliers engaging in such practices. “Unfair practice” in relation to a consumer transaction is defined under the CPFTA as (i) doing or saying anything, or omitting to do or say anything, if as a result, a consumer might reasonably be deceived or misled; (ii) making false claims; (iii) taking advantage of consumers if the supplier of goods / service knows or ought reasonably to know that the consumer is not in a position to protect his own interests or is not reasonable able to understand the character, nature, language or effect of the transaction or any matter related to the transaction; or (iv) commits any of the unfair practice specified in the CPFTA.   Some examples of unfair practices specified in the CPFTA include, among others:

• representing that goods are of a certain weight, volume, standard, quality (among other metrics) when they are not,
• representing that goods are available in particular quantities if the supplier knows or can reasonably be expected to know it is not so,
• omitting to provide a material fact to a consumer,
• using small print to conceal a material fact from the consumer or misleading a consumer as to a material fact,

in connection with the supply of goods or services. It is unlikely that Shrinkflation practices would fall foul of the above Act unless they fall within the ambit of the above provisions.

As a first port of call, local consumers can submit complaints to Consumer Association of Singapore (CASE), which is a non-profit, non-governmental organisation that is committed towards promoting consumer interest. CASE will assist aggrieved consumers to obtain redress, and in some cases, compensation through negotiation and/or mediation. CASE may also engage the errant suppliers to warn them and/or enter into an agreement where the errant suppliers agree in writing to stop the unfair practice, and in certain cases, compensate affected consumers.

On the other hand, CCCS, being a statutory board, administers the CPFTA and can take action against businesses that persist in unfair practices under the CPFTA. In the event that a business persistently engages in unfair practices, CASE may refer such business to CCCS for non-criminal infringements. CCCS investigates such businesses and may apply to the courts for injunction orders against suppliers for conducting unfair practices and ensures that such suppliers comply with their injunction orders.   

Although there are no legislative changes currently proposed to specifically address shrinkflation, CASE has displayed some efforts to help combat shrinkflation, such as updating its mobile application “Price Kaki” to enable the display of unit pricing on the application in January 2023. “Price Kaki” is the first mobile application in Singapore that allows consumers to compare and contribute in-store prices of groceries, household items and hawker food in Singapore through the platform.  

Contacts: Philip Lee and Le Jing Ong

Are there dedicated regulations on shrinkflation in your jurisdiction?

There are no specifically dedicated regulations yet but please note Question 2-4 on ongoing initiatives.

Are there any other measures against shrinkflation in your jurisdiction?

The Spanish Parliament has approved a non-binding proposal presented by the government’s parliamentary group (PSOE), calling for the government to:

• Conduct campaigns to enable consumers to recognize and protect themselves from predatory practices.
• Oblige businesses to inform consumers clearly of any reduction in the size or weight of a product when an equivalent or higher price is maintained.
• Reinforce controls on the presentation of products that may be misleading as to the quantity contained in their packaging.

In line with the above, a Draft Law amending Royal Legislative Decree 1/2007 of 16 November, which approves the consolidated text of the General Law for the Defense of Consumers and Users and other complementary laws (LCU), is currently progressing through the legislative process. It was admitted for consideration by the Lower House of Parliament on 17 December 2024, which resolved to refer it to the Committee on Social Rights and Consumer Affairs for final approval, following the conclusion of a public consultation period that remained open until 18 February 2025. As of now, the Draft Law remains pending approval by the Lower House and once approved, must subsequently be ratified by the Upper House of Parliament.

Substantively, the Draft Law introduces a new paragraph to article 20 of the LCU, specifically stating that where a pre-packaged consumer product is offered for sale with a constant nominal quantity, consumers shall be informed in a clear and comprehensible manner whenever this quantity is reduced, and such reduction results in an increase in the price per unit of measurement.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

In October 2022, the Consumers and Users Organization (OCU) raised a complaint before the Spanish Competition Authority (CNMC) against several food companies for shrinkflation. The investigation is still ongoing.

Additionally, the CNMC has challenged practices similar to shrinkflation in the past. For example, in case S/0084/08 FABRICANTES DE GEL, the CNMC fined manufacturers of shower gels for implementing an anticompetitive agreement to reduce the format of the sales of bath and shower gels from a capacity of 750 ml to 650 ml while keeping the selling price of the container at the same level (ie reducing the size of the packages while keeping the package prices unchanged), with the object and effect of an indirect price fixing.

Is there any other important information on shrinkflation from your jurisdiction?

Although not specifically enacted to combat shrinkflation, Spanish Royal Decree 3423/2000, of 15 December, regulating the indication of prices for products offered to consumers and users, is highly relevant.

It introduces the obligation to display product prices in the form of "price per unit of measurement", described as the final price, including VAT and all other taxes, per kilogram, liter, meter, square meter, or cubic meter of the product, or per product unit.

Given that only one unit of measurement can be applied to each product category, this regulation enables consumers to detect price increases hidden behind portion reductions.

Contacts: Paula Gonzalez de Castejón Llano-Ponte, Joaquin Hervada and Daniela Mejia

Are there dedicated regulations on shrinkflation in your jurisdiction?

No.

Are there any other measures against shrinkflation in your jurisdiction?

No. However, the Swedish Social Democrats (Sw. Socialdemokraterna) have proposed placing warning triangles on packaging that has been reduced in size to combat shrinkflation. However, since the Social Democrats are not currently in office, any legislative actions are unlikely to be initiated before the next election in the autumn of 2026.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

We are not aware of any court cases specifically addressing shrinkflation. However, representatives of the Swedish Consumer Agency (Sw. Konsumentverket) have, on occasions, urged consumers to report cases of shrinkflation as it could be considered misleading advertisement.

The Swedish Consumer Agency has confirmed that it currently does not have any supervisory cases regarding shrinkflation.

Is there any other important information on shrinkflation from your jurisdiction?

Shrinkflation has been raised by consumer advocacy groups in Sweden which have for instance argued that it constitutes misleading advertisement.

While there is no legal regulation for shrinkflation in Sweden, there is a legal prohibition of so-called “misleading packaging size” (Sw. vilseledande förpackningsstorlekar) in Section 13 of the Swedish Marketing Practices Act which states that it is prohibited to use packaging which, due its size, exterior design or otherwise, is misleading in respect of the product’s quantity, size or form.

Contacts: Anna Jussil Broms and Emanuel Sonstrand

Are there dedicated regulations on shrinkflation in your jurisdiction?

There is no legislation or code that specifically targets Shrinkflation. Nevertheless, the UK has legislation and code that imposes general obligations on retailers and manufacturers not to mislead consumers. These obligations extend to requiring traders to be clear and transparent about any reduction in size of a product that is presented in packaging that consumers have become habituated to, but which previously contained a bigger product/portion size, where there is a risk that not doing so would be misleading.

The key legislation underpinning this is a pre-Brexit EU directive, the Unfair Commercial Practices Directive 2005, the relevant provisions of which are now largely replicated in the recently-enacted Digital Markets Competition and Consumer Act 2024 (DMCCA; the Directive was initially implemented in UK law as the Consumer Protection from Unfair Trading Regulations, which the DMCCA has replaced).

This provides that it is an offence to engage in an aggressive or misleading practice that impacts the consumer's economic decision making (ie the decision to purchase in this context). In the context of shrinkflation, a commercial practice is misleading if a product or a product’s overall presentation deceives or is likely to deceive the average consumer in relation to a number of matters including the main characteristics of the product, which includes the quantity of the product contained in the package.

There are also advertising codes of the UK Advertising Standards Authority: a print and digital media code – Code of Advertising Practice (CAP code), and a broadcast equivalent called the BCAP code. These regulate advertising content, and in particular require that adverts do not materially mislead the consumer. An ad which made a price claim using a previous larger product size as the reference comparison without clearly identifying that product sizes had changed (eg claiming “10% lower than 2024 prices” when the relevant 2024 reference price was in fact for a product of greater weight) could be considered misleading and in breach of the Code.

The easiest solution to mitigate risk of infringing CAP or BCAP code and the DMCCA would be clearly to spell out the price, weight and quantity of product being purchased. It may also be prudent to make it clear that the ‘shrunk portion/product size’ is a smaller product/portion size or new product/portion packaging size.

Are there any other measures against shrinkflation in your jurisdiction?

The UK’s consumer regulator the Competition and Markets Authority (CMA) in a 2023 report (published in light of the very high UK inflation rates in 2022-23) specifically considered the phenomenon of shrinkflation and called on retailers to provide consumers with the unit price information they need to make meaningful comparisons, particularly for promoted products, ‘even before the introduction of any Price Marking Order (PMO) reforms’. PMO reforms have since been introduced, which from 1 October 2025 will add a few additional restrictions around the way grocery prices must be displayed in the UK, eg using a clear font of reasonable size, and including unit price reductions for general price reductions.

Has shrinkflation been challenged under consumer protection legislation in your jurisdiction?

No not yet, but it has been on the CMA’s radar (see Question 2), as enforcer of the DMCCA.

Is there any other important information on shrinkflation from your jurisdiction?

There has been commentary but the DMCCA (and in the case of advertising, the CAP and BCAP codes) will apply in case of usage of shrinkflation misleading a consumer into making a purchase they might not otherwise make or deemed not to be honest or truthful, by giving the impression that the product of the reduced product size is the same as the previous larger product size. A case is unlikely if the size and price is highlighted (and the risk of a case could further be reduced by stating that a new product size is a new/reduced product size). Cases if they are brought will be decided on their own separate sets of facts.

Contacts: John Wilks, Sophie Lessar and Duncan Calow