Intergraf European Federation for Print and Digital Communication
INTERGRAF
Intergraf represents 22 national printing federations in 21 countries in Europe.
ID: 15519132837-45
Lobbying Activity
Response to Omnibus Directive Aligning product legislation with the digital age
25 Aug 2025
Intergraf warns against setting a digital only approach in EU product legislation. The practice applied to professional equipment under the Machinery Regulation should not be extended to consumer goods. At present, EU consumers receive printed instructions with their products, containing essential information on use, assembly, and repair. They are vital for product safety and consumer protection. We therefore urge legislators to preserve the requirement for printed instructions in EU consumer product legislation.
Read full responseResponse to Consumer Agenda 2025-2030 and Action Plan on Consumers in the Single Market
25 Aug 2025
Intergraf welcomes the opportunity to contribute to the Consumer Agenda 2025-2030 and wishes to highlight our concerns regarding the current shift in EU policy towards a digital-only approach for consumer information. In several legislative initiatives and policy proposals, we observe a tendency to replace important printed information, provided directly with goods and services to consumers, with information that is exclusively available online or only upon request. This change effectively shifts the burden of access from the manufacturer or service provider to the consumer. Consumers are now required to search for essential details rather than being equipped with them at the moment of purchase. We strongly object to this trend, especially in the fields of consumer product legislation and pharmaceutical legislation. Information provided in a clear, accessible, and immediately available format is a fundamental safeguard for consumers. Printed information serves as a guarantee that product and service details, including for consumer goods and medicines, are transparent and accessible to all, regardless of digital literacy, internet connectivity, or device ownership. While digital information can be a valuable complement, it cannot replace printed information. A digital-only approach risks excluding vulnerable groups, creating inequality of access, and reducing the effectiveness of consumer protection. It undermines the principle of fairness, where the responsibility to provide accurate and accessible information should remain with the producer and not the individual consumer. For these reasons, we call on the Commission to ensure that the EU Consumer Agenda 20252030 safeguards the availability of printed information as a baseline requirement in EU consumer legislation. A balanced approach that combines printed and digital formats is the best way to strengthen consumer rights, promote informed decision-making, and ensure inclusion for all EU citizens.
Read full responseResponse to Omnibus Regulation Aligning product legislation with the digital age
22 Aug 2025
Intergraf warns against setting a digital only approach in EU product legislation. The practice applied to professional equipment under the Machinery Regulation should not be extended to consumer goods. At present, EU consumers receive printed instructions with their products, containing essential information on use, assembly, and repair. They are vital for product safety and consumer protection. We therefore urge legislators to preserve the requirement for printed instructions in EU consumer product legislation.
Read full responseResponse to Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EU Deforestation Regulation)
12 May 2025
Representing over 100.000 companies, the European printing industry is actively preparing for the compliance of its companies, who are generally considered as downstream operators under the European Deforestation Regulation (EUDR). Printing companies manufacture printed products classified under HS 49. While we fully welcome the exclusion of 'accessory materials accompanying another product' from the scope of the Regulation, we suggest clarifying that these materials are also excluded when being provided on their own, without accompanying a product. This is for example the case of marketing materials provided at supermarkets, brochures provided by travel agencies or any information leaflets provided by any organisation. Ultimately, any company and organisation are using some form of printed material when communicating, advertising, informing or educating. These products will be placed on the EU market by the manufacturer, i.e. printing companies in most cases, who will retain EUDR obligations. Companies further down the value chain should not be burdened with EUDR obligations when using printed products as part of a marketing or information activity. Intergraf therefore suggests excluding from the scope accessory products 'accompanying a service or distributed for information purposes'.
Read full responseResponse to Single Market Strategy 2025
31 Jan 2025
Intergraf, representing the European printing industry, welcomes the opportunity to comment on the upcoming single market strategy. Our contribution recommends addressing the growing fragmentation of the single market, focusing on the packaging sector.
Read full responseResponse to Evaluation and revision of the general pharmaceutical legislation
7 Nov 2023
Intergraf represents the European printing industry. Intergraf contribution addresses the provision on package leaflets (article 63.3). The proposal presents a revolutionary approach in granting the flexibility to Member States to remove paper leaflets from the packaging to rely only on the information made available online through the electronic product information. Package leaflets provide vital information which should be accessible to all patients. If medication information is only available online, many patients will be penalised, in particular the most vulnerable ones, which may be excluded because of age, lack of digital skills or lack of resources. The proposal includes a patients' right to a printed copy. It cannot be implemented in practice. Its practical implementation has unfortunately not been assessed as the Impact Assessment does not address the feasibility of this provision. Moreover, this provision unfairly shifts the burden to access the medication information from the pharmaceutical company to pharmacists and to the patients. The electronic product information should complement the paper leaflet but not replace it. Europe should not implement a 'digital by default' approach to its healthcare system.
Read full responseMeeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)
15 Sept 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)
Meeting with Tomasz Frankowski (Member of the European Parliament, Rapporteur) and European Disability Forum and
21 Mar 2023 · The future of the European book sector-consultation meeting with stakeholders
Response to Declaration of Digital Principles
4 Jun 2021
We welcome the European Commission’s latest initiatives on Europe’s digital transition and look forward to publication of the Declaration of Digital Principles, which should not pursue a ‘digital only’ or ‘digital first’ agenda. The European graphical sector offers our support to facilitate a fair, inclusive, and non-discriminatory digital transition for all citizens. We will work with the Commission to ensure that print and digital are used to their best advantage, and to highlight the key role of print in Europe’s transition to a digital society.
Please review the attached position paper for our extended feedback and recommendations on the Declaration of Digital Principles.
Read full responseResponse to Revision of EU rules on food contact materials
27 Jan 2021
Intergraf provides feedback to the Revision of EU rules on food contact materials on behalf of the European printing industry. Please find our comments in the attached document. We remain at your disposal for further information and look forward to working with the European Commission on this crucial area of legislation.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
5 Aug 2020
Intergraf, the European federation for the printing industry, welcomes the European Commission’s review of the essential requirements of packaging. A key part of the value chain and the circular economy, the printing industry brings together the materials, ink, and packaging design which make the final packaging product. In this position paper, we set out the key areas which the European Commission should pay particular attention to during this review. We remain at your disposal for further information and look forward to working with the European Commission in the next steps of this process.
Read full responseResponse to Digital Education Action Plan
26 Jun 2020
Preparing for a “future-proof education” is vital, but it needs to be clearly addressed that such a future is not only digital, and digital education is not automatically better by default. Digital learning tools do (and should) play a crucial role in current and future learning environments, but there are some situations in which digital tools are proven not to be the best option for learning. In these cases, traditional (or alternative) methods of learning need to be explicitly preserved.
Digital education tools should only be used when it is necessary and proven to improve learning outcomes. At the very least, digital tools should not be promoted when they have been proven to provide lesser learning outcomes. Sometimes digital resources are proven to be not needed or beneficial – such as with reading. Reading from a screen, rather than in print, has been proven to be detrimental to the development of literacy skills (e.g. comprehension, critical thinking, concentration and deep reading).
A research network (COST Action: www.cost.eu) of over 120 scholars and scientists of reading, publishing and literacy from 33 countries concluded the COST Action E-READ Initiative (“Evolution of Reading in the Age of Digitisation”) in 2018 (www.cost.eu/actions/IS1404/#tabs|Name:overview). They assessed the impact of digitisation on reading practices. The results demonstrate a clear learning advantage for print “when reading for deeper comprehension and retention”, regardless of whether someone is a ‘digital native’ or not.
Key findings presented in the Stavanger Declaration (www.ereadcost.eu/stavanger-declaration) include:
• “A meta-study of 54 studies with more than 170.000 participants demonstrates that comprehension of long-form informational text is stronger when reading on paper than on screens, particularly when the reader is under time pressure.”
• “Digital environments also pose challenges. Readers are more likely to be overconfident about their comprehension abilities when reading digitally than when reading print, in particular when under time pressure, leading to more skimming and less concentration on reading matter.”
• “Contrary to expectations about the behaviour of ‘digital natives’, such screen inferiority effects compared to paper have increased rather than decreased over time, regardless of age group and of prior experience with digital environments.”
Key recommendations include:
• “Teachers and other educators must be made aware that rapid and indiscriminate swaps of print, paper, and pencils for digital technologies in primary education are not neutral. […] They may cause a setback in the development of children’s reading comprehension and emerging critical thinking skills.”
• “It remains important that schools and school libraries continue to motivate students to read paper books, and to set time apart for it in the curriculum.”
We welcome the reference to “hybrid modes of learning and teaching (online + offline)”. However, the importance of reading printed texts (rather than reading from a screen) for literacy should be specifically addressed to sufficiently counter the widespread (incorrect) notion that digital is always better by default. This will help to protect learning outcomes and cognitive development.
The COST Action E-READ Initiative is an example of recent large-scale independent research on the state of digital education in Europe (specifically focusing on reading practices in the digital age). The unambiguous results of this research, which proves that reading in print is better for the development of comprehension, critical thinking, concentration and deep reading skills than reading from a screen, should be considered in any communication or legislation about digital education.
Read full responseResponse to Evaluation of the Industrial Emissions Directive
4 Dec 2018
Intergraf, representing the European printing industry, welcomes the opportunity to comment on the evaluation roadmap of the Industrial Emissions Directive. The adoption of the Industrial Emissions Directive was of key relevance for the printing sector with the inclusion of the Solvent Directive. The BREF governing our activities, ie Surface Treatment using Organic Solvents BREF, is not yet finalised. The new permits conditions to operate our plants will not be adopted before 2019. An evaluation of the Industrial Emissions Directive in 2020 is for our industry very premature. Our industry will lack the necessary experience on permit conditions under IED to adequately assess the Directive.
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