On 25 February 2026, the Austrian National Council passed the Federal Act on the Labelling of Goods Whose Quantity Has Been Reduced Without a Corresponding Price Reduction – in short, the ‘Anti-Deceptive Packaging Act’. The aim is to combat ‘shrinkflation’, i.e. goods whose quantity has been reduced without a corresponding reduction in price.
What does the law stipulate?
From 1 April 2026, large supermarkets and drugstores (with a sales area of over 400 m² or more than five branches) must label products if
- the quantity or number of items has been reduced and
- there has been no corresponding price reduction.
The labelling must be clearly visible, e.g. with the note ‘Attention: Less content – higher price’, and must remain in place for at least 60 days.
Exceptions include minor price changes (less than 3%) or if the reduction in quantity is already clearly indicated by the manufacturer on the packaging. The law is limited until 30 June 2030.
Legal classification and criticism
From a legal perspective, it should be noted that the area of misleading commercial practices is fully harmonised at EU level by the Unfair Commercial Practices Directive. Misleading packaging designs are already prohibited under current fair trading law.
In a ruling from autumn 2025, the Vienna Higher Regional Court ruled that packaging containing frozen fish fillets violated the prohibition of deception and misleading practices in unfair competition because it assumed that the reduction in net weight would not be noticed by an average attentive consumer, since in this case not only had the packaging size remained the same, but the information on the packaging and the price had also remained unchanged.
However, the new law goes further: it standardises a general labelling requirement regardless of whether there is specific misleading information in individual cases. This raises the question of whether this additional national information requirement is permissible under EU law.
Relevance for manufacturers
Even though the labelling requirement formally affects retailers, the law has a significant indirect impact on manufacturers:
- De facto stigmatisation of product adjustments (‘Warning: less content’),
- Additional coordination and documentation requirements with retailers,
- Potential reputational risks despite transparent packaging labelling,
- Shift in public discussion about pricing to the product level.
Especially in times of volatile raw material prices, regulatory adjustments and rising production costs, quantity adjustments are a legitimate tool of business calculation. A blanket warning label does not differentiate between misleading practices and economically justified product adjustments.
Conclusion
The Anti-Deceptive Packaging Act sends a clear political signal in favour of increased price transparency. From a Union law and systematic perspective, however, it remains unclear whether a general labelling requirement is permissible alongside the existing, fully harmonised prohibition of misleading practices.
Manufacturers should take early action to
- structure coordination processes with trading partners,
- review packaging and communication concepts,
- and keep an eye on further developments in EU law.
We would be happy to assist you with the legal assessment of specific product adjustments or with strategic preparation for the new legal situation.