Who is excluded by packaging labels?

The audience the label assumes

Every label in the preceding themes is designed for a particular consumer: literate in the national language, sighted, holding the pack in adequate light, disposing at home with time to read. The assumption is nowhere stated and everywhere operative — in six-point font, colour-coded pictograms, multi-step instructions, and QR codes that need a smartphone and the inclination to use it.

No study of excluded audiences for environmental labels specifically was found: nothing on how blind consumers, low-literacy consumers or non-native speakers fare with recyclability and disposal marks. What was located is adjacent evidence: disability surveys about packaging information generally, health-literacy research on warning labels, demographic gradients inside general comprehension surveys, one accessibility-law near-miss, and one deployable technology with no published evaluation. Every transfer is flagged as a transfer. Labels are designed for an assumed audience whose composition has not been checked. Comprehension thresholds are legislated on samples from which the excluded populations are absent.

Vision

The Royal National Institute of Blind People’s accessible-packaging campaign: “9 in 10” blind and partially sighted people surveyed said packaging information is “difficult or impossible to read,” with almost three in four rating access to product information as very important (Packaging Europe, reporting RNIB research, n.d.). Evidential basis: weak-to-moderate — advocacy survey, second-hand trade coverage, sample size and method not retrievable, packaging information generally rather than environmental labels. The direction does not depend on that precision. For a population counted in the millions per market, every visual mark, grade, pictogram and instruction in Theme 3 is not accessible through vision at all.

NaviLens — a high-contrast code readable “from 12 meters (40 feet) away” — was deployed by Kellogg in the United States from December 2022 on four cereal brands after a UK pilot with the RNIB, reading out product and nutritional information (Kellogg Company, 2022). Deployment is verified from the company’s announcement. No evaluation was located: no published data on usage, comprehension or disposal outcomes. A channel for non-visual delivery exists in commercial use. Whether it delivers disposal instruction is unmeasured.

The European Accessibility Act, applicable from June 2025, covers a closed list of products and services. Covered products’ information, including on packaging, must be accessible “via more than one sensory channel.” General consumer-goods packaging is not on the list. The EAA does not impose accessibility requirements on food packaging or recycling labels. The one horizontal accessibility statute in the jurisdiction with the most extensive packaging-label regulation stops short of the packaging label.

Literacy

Davis, Wolf and colleagues interviewed 251 primary-care patients with literacy assessed by a standard instrument. “[P]atients with low literacy were 3.4 times less likely to interpret prescription medication warning labels correctly (95% confidence interval: 2.3 to 4.9).” “[M]ultistep instructions proved difficult for patients across all literacy levels” (Davis et al., 2006). Evidential basis: peer-reviewed, defined sample, validated instrument. Subject: medication labels, not disposal marks. Transfer flagged. The analogy is structural: the modern disposal label is a multi-step instruction in terse text with icons — “rinse, remove sleeve, check locally, recycle” — the format the health literature identifies as failing low-literacy readers first.

No direct study of literacy and environmental-label comprehension was found. The nearest evidence is demographic gradients: the APR/GLS survey found adults 65 and over least likely to know recycled-content terms, within a dataset already showing near-universal failure on technical vocabulary (GLS Research, 2021). Age gradients are not literacy gradients. They show that comprehension failure is not uniformly distributed.

Language

Of the four exclusions here, language is the one for which no direct evidence at all was found. Searches for recyclability or disposal-label comprehension among non-native speakers — Canada’s bilingualism, Spanish-speaking US households, EU cross-border SKUs — returned nothing on point. The EU’s turn to pictograms exists partly because multi-language packs cannot carry twenty-four text instructions. That remedy was adopted without measurement of the exclusion it addresses. Text-dependent labels exclude those who do not read the label’s language, in proportions no located study has measured.

Household context

85 per cent of single-family households in the United States have recycling access, against 37 per cent of multifamily (The Recycling Partnership, 2024). A recyclability instruction on a pack sold into both housing types tells a large share of multifamily residents to use a service they do not have. QR-based detail assumes a smartphone and the inclination to scan; the age gradient in the scanning article is the same exclusion from another direction. Time, light and the presence of a second adult who reads English are situational filters no label evaluation samples for.

What adjacent literatures prescribe

For vision: more than one sensory channel. NaviLens shows the channel exists; it has not been evaluated for disposal instruction. For literacy: fewer steps, concrete verbs, no technical vocabulary. Action-oriented disposal text already outperforms symbol-only and technical content claims in the comprehension record. For language: pictograms paired with words, not pictograms instead of words, and not words in one language only. For household context: do not write “Recycle” as an unqualified instruction where access is 37 per cent. None of these prescriptions requires new theory. They require applying what adjacent fields already treat as basic.

Summary

The excluded populations are large, and for vision the exclusion is total rather than marginal. Direct evidence on environmental labels specifically is almost absent. Adjacent evidence is consistent enough to act on, and should be labelled as adjacent. Legislated comprehension thresholds built on general-population samples do not describe the people the label never reaches.

References

Davis, T.C., Wolf, M.S., Bass, P.F., et al. (2006) 'Low literacy impairs comprehension of prescription drug warning labels', Journal of General Internal Medicine, 21(8), pp. 847–851. Available at: Open source (Accessed: 18 August 2026).

EUR-Lex (n.d.) European Accessibility Act — summary (Directive (EU) 2019/882). Available at: Open source (Accessed: 18 August 2026).

GLS Research (2021) Recycling Terms Survey (for the Association of Plastic Recyclers), March. Available at: Open source (Accessed: 18 August 2026).

Kellogg Company (2022) Kellogg empowers blind consumers in U.S. with NaviLens technology on packaging, 14 December. Available at: Open source (Accessed: 18 August 2026).

Packaging Europe (n.d.) Leading charity urges businesses to improve accessibility of packaging design (RNIB research). Available at: Open source (Accessed: 18 August 2026).

Note on sources and verification

The RNIB figures ("9 in 10"; almost three in four) are as reported in the trade coverage cited; the survey's sample size and method were not retrievable, the RNIB's own page not being retrievable by the fetcher used, and the figures are graded accordingly. The NaviLens deployment facts are from Kellogg's press release; no usage or outcome evaluation was located. The EAA's scope is verified from the EUR-Lex summary and practitioner analyses: it applies from 28 June 2025 to a closed product list and does not cover general consumer-goods packaging — a correction to circulating claims that EU law now requires accessible packaging labels. Davis et al.'s odds ratio and multistep-instruction findings are verbatim from the open-access record; the study concerns medication labels and is used strictly as transfer evidence. The APR/GLS age gradient is from the survey PDF. The absence of any located study on non-native-speaker, low-literacy or vision-impaired comprehension of environmental labels specifically is an absence claim based on searches conducted for this article, and the section on language rests entirely on documented absence plus design arithmetic. The three concluding claims are synthesis prepared for this article, with their evidentiary status graded in the text.

Last verified: 18 August 2026.