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Directive 2024/825 by country: transposition status in key markets for food supplements
Directive 2024/825 applies from 27 September 2026, but not every Member State has enacted its own implementing legislation. Below is the status in the markets where our clients operate and our reading of it. A transposition map informs, but it does not measure regulatory risk.
Three dates
The Directive entered into force on 26 March 2024. The transposition deadline expired on 27 March 2026. Its rules apply from 27 September 2026. On 28 May 2026 the Commission sent letters of formal notice to twenty Member States for failing to communicate complete transposition: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Estonia, Finland, France, Greece, Hungary, Latvia, Luxembourg, Malta, Netherlands, Poland, Portugal, Slovenia, Spain and Sweden.
Status in key markets (as at 28 September 2026)
| Market | May notice | Status | Legislation and date |
|---|---|---|---|
| Germany | No | Transposed | UWG reform published February 2026; applicable from 27/09/2026 |
| Italy | No | Transposed | Legislative decree published March 2026; applicable from 27/09/2026 |
| Netherlands | Yes | Transposed after May | Act in force July 2026; applicable from 27/09/2026 |
| Belgium | Yes | Transposed after May | Published August 2026; in force 27/09/2026 |
| Luxembourg | Yes | Transposed after May | Published June 2026; in force 27/09/2026 |
| France | Yes | Pending | Passed by the Senate in February 2026; pending National Assembly vote |
| Spain | Yes | Pending | Draft Sustainable Consumption Act (first reading: July 2025); not published in the BOE |
| Portugal | Yes | To be verified | To be verified |
| Poland | Yes | To be verified | To be verified |
How to read the table
The May notice is a snapshot: three of the Member States that received it have since transposed the Directive. But the column “Status” is not the relevant data point for a labelling decision, for three reasons.
In pending markets, prior law continues to operate. France already prohibits on products and packaging references such as “environmentally friendly” under the AGEC Act. Spain allows action under Ley 3/1991 de Competencia Desleal and the TRLGDCU, interpreted in the light of the Directive. We analyse this in the article on Spain.
In transposed markets, enforcement intensity varies. Germany combines literal transposition with a very active private competitor-notice system. The Netherlands has an authority with its own guidance and well-established administrative practice that predates the Directive.
Communicated transposition does not guarantee correct transposition. The Commission may open subsequent proceedings for incomplete transposition, and national courts will interpret domestic law in conformity with the Directive.
That is why a multi-country packaging decision is governed by the most active market in which the product is sold, not the most laggard. We set this out in One packaging, multiple markets.
Our take
Knowing which country has transposed is information. Deciding which environmental claim goes to print, in which version and for which markets, is regulatory expertise. For food supplement companies with international reach, that strategic decision is made before the print run, not after the first warning notice. At LegaleGo we do not file paperwork , we decide.
Table last updated: 28 September 2026.
