The proposed EU packaging regulation could impact seasonal confectionery, such as heart-shaped boxes of chocolates, chocolate Easter bunnies, or chocolate Santas, the Federation of the German Confectionery Industry (Der Bundesverband der Deutschen Süßwarenindustrie e.V. - BDSI) has said.
The draft Packaging & Packaging Waste Regulation (PPWR) states that the focus should be on minimising packaging in future.
The proposed legislation only offers exemptions for products with brand or design trademark rights.
However, small and medium-sized companies, in particular, cannot apply for corresponding design trademarks for each of their products due to the considerable costs and administrative effort involved, the BDSI added.
Dr Carsten Bernoth, managing director of the BDSI explained, "By omitting a ribbon, for example, the suitability of a product as a gift is lost. It is precisely this type of design that makes many popular products unique.
"For example, the bell or bow on an Easter bunny or Father Christmas or a small Christmas tree on a chocolate snowman are unmistakable features that create added value in consumer expectations. A special presentation of a box of chocolates would no longer be possible under the EU Council's plans."
The BDSI also voiced its support for the EU Parliament's stance on the matter, which acknowledges the design considerations for products for special occasions beyond the sole function of packaging for protection.
The political trilogue on the PPWR commenced last week, the federation added.