Stakeholder consultation on Single Market barriers

Context

The European Commission’s 2025 Single Market Strategy identifies fragmented rules on packaging, labelling and waste as one of the “Terrible Ten” barriers that most hinder the free movement of goods and the ability of businesses to operate and scale across the EU. Although these requirements pursue important environmental, public health and consumer-protection objectives, differences in national rules and implementation can fragment the market and create avoidable costs.

Purpose of this consultation

The department is seeking evidence on how packaging, labelling and waste-related requirements affect business activity and cross-border trade in the single market.

Stakeholders are invited to:

• identify specific instances of regulatory divergence or implementation difficulty
• quantify costs, delays or other impacts where possible
• highlight effects on SMEs and circular-economy activity
• propose practical opportunities for simplification, harmonisation, digitalisation or improved enforcement

Any proposed solution should preserve high standards of environmental protection, public health and consumer information.

Why this matters

A business selling the same product in several Member States may need to redesign packaging, produce market-specific labels, translate or adapt mandatory information, apply different recycling or environmental markings, register separately with national Extended Producer Responsibility (EPR) schemes, and meet different reporting, fee and deadline requirements. These obligations can duplicate compliance work, lengthen time to market and reduce the economies of scale that the single market is intended to provide.

• Packaging and labelling 
  Product labels are essential for communicating safety, composition, use, environmental performance and end-of-life information. However, divergent national content, language, placement and marking requirements may require multiple versions of the same product or package. This can generate redesign, relabelling, production and inventory costs, while an increasing volume of mandatory information can make clear and consistent consumer communication more difficult. 

• Waste and circular-economy obligations 
  Businesses also face differing approaches to EPR, waste classification, end-of-waste criteria, sorting and recycling rules, and the treatment or movement of secondary raw materials. Operating across borders may therefore involve multiple authorities and schemes with distinct registration procedures, data formats, reporting obligations and fee structures. The resulting friction can fall disproportionately on SMEs and micro-enterprises and can impede EU-wide circular value chains.

Context

The European Commission’s 2025 Single Market Strategy identified restrictive and diverging national services regulation as one of the “Terrible Ten” barriers that most hinder the free movement of services and the ability of businesses and professionals to operate and scale across the EU. Although these requirements can pursue important and legitimate general interest objectives, such as public health and safety, high regulatory and administrative restrictions can work to stifle innovation, scale up and business opportunities.

Purpose of this consultation

The department is seeking evidence on how restrictive and diverging national services regulation requirements affect business activity and cross-border trade and mobility in the single market.

Stakeholders are invited to:

• identify specific instances of regulatory divergence or difficulties in complying with cross border requirements
• quantify costs, delays or other impacts where possible
• highlight effects on SMEs
• propose practical solutions for simplification, harmonisation, digitalisation or improved implementation of national services regulation, in line with any public interest requirements

Why this matters

Services represent 75% of EU GDP while most EU jobs are created in services. 40% of the value added of EU products is also made up of services content.The single market for services, however, is profoundly undeveloped.Regulation serves to restrict access to around 5,700 services activities across Europe, covering 22% of the EU workforce. At 7.8% of EU GDP, intra EU services trade is no higher than services trade with third countries.

Relevant services activities

The Single Market Strategy identifies a range of services activities that are impacted in their ability to operate across EU borders by diverging regulation:

• industry related services, that is, installation, maintenance and repair services, which are crucial for manufacturing- especially with the shift towards servitisation and the integration of product and service solutions
• business services, including legal, accounting and tax advisory services
• construction services, which holds back the supply of affordable and energy efficient housing and infrastructure development
• retail services, whose competitiveness is held back by restrictions on the establishment of shops and their operations
• the single markets for telecommunications, energy, transport and financial services are also highlighted as being incomplete, at a cost to businesses and consumers

The European Commission published the Single Market Strategy in May 2025. This strategy was commissioned by the European Council and aims at deepening the EU’s single market, notably by addressing barriers to the free movement of goods, services and people between the EU’s 27 Member States.

These barriers ensure that rather than one seamless single market, businesses, workers and consumers are often forced to navigate 27 different administrative and regulatory regimes. These barriers work to impede trade, competition and consumer choice, and directly impact competitiveness and economic growth across Europe.

The Single Market Strategy has identified what are known as the “Terrible Ten” most impactful European market barriers, which the European Commission and Member States are working to address through EU and Member State level action. These are:

1. Overly complex EU rules
2. Lack of Single Market Ownership by Member States
3. Complicated business establishment and operations
4. Limited recognition of professional qualifications
5. Long delays in standard setting
6. Fragmented rules on packaging, labelling and waste
7. Outdated product rules and lack of product compliance
8. Restrictive and Diverging National Services Regulation
9. Burdensome procedures for temporary posting of workers
10. Territorial Supply Constraints

In order to support the delivery of the Single Market Strategy, the government has established new structures for single market implementation in Ireland. The Department of Enterprise, Tourism and Employment has been designated as a focal point for the single market within government, via the establishment of a dedicated Single Market Office.

The office is working to support Ireland’s Single Market Sherpa, the Secretary General of the Department of Enterprise, Tourism and Employment, in his mandate of preventing and addressing national regulatory and administrative single market barriers. This is by liaising closely with all government departments and agencies to promote whole of government compliance with single market rules.

This work is being supported by an interdepartmental Single Market Taskforce, which is actively monitoring Ireland’s compliance with its single market obligations and playing an active role in identifying, addressing and preventing national barriers.

Through active stakeholder outreach, the Single Market Office is also seeking business, academic and wider stakeholder insights with a view to advising the government and Ireland’s Single Market Sherpa on the most pressing issues of single market compliance and implementation.