Fake Labels Are Now One of the EU’s Biggest Counterfeit Categories.

Fake Labels Are Now One of the EU’s Biggest Counterfeit Categories. Korea’s Answer Is a Better Label.

The EU detained a record 196 million counterfeit articles in 2025, and labels, tags and stickers sit in the small group of categories that account for almost three quarters of them. Two bodies of law already treat trafficking in that layer as the offence. The newest state response is a mark printed by a national mint.

On 22 October 2026 the European Union Intellectual Property Office and the European Commission’s taxation and customs directorate published their annual account of IP enforcement at the EU border and in the internal market. The headline is a record. More than 196 million counterfeit items were detained in the EU in 2025, worth an estimated EUR 6.3 billion, which EUIPO puts at 67 per cent higher than 2024 and 29 per cent above the previous record set in 2023.

Further down there is a line about categories. EUIPO states that almost 75 per cent of detained products fell into one group of six: recorded CDs and DVDs including software, toys, cigarettes including electronic cigarettes, games, clothing, and labels, tags and stickers.

Read that list again. Five of the six are things people buy. The sixth is the thing that tells you what you are buying.

That is the subject of this piece. The identity layer has become one of the highest-volume counterfeit commodities in Europe, by the European Union’s own count. Both American and European law decided long ago that trafficking in it is the offence. And the newest answer a government has produced is a better-printed mark, designed by the people who print the banknotes.

What the report says, and what it does not

Precision matters here, because the most quoted number is not in the primary source.

EUIPO’s own release gives the headline totals above and a partial category breakdown: recorded CDs and DVDs at nearly 30 per cent of seizures, toys at almost one in five, and labels, tags and stickers named among the high-volume categories with no percentage attached. On detaining countries, it reports that Romania accounted for 43 per cent of articles detained at the border, followed by Bulgaria and Italy, and that Italy alone accounted for over 70 per cent of internal-market detentions, with France at 6.2 per cent and the Netherlands at 4.8 per cent. No official is quoted anywhere in the release.

Reporting on the full report, IPWatchdog puts labels, tags and stickers at 13.41 per cent of detentions, against 2.11 per cent the year before, a six-fold rise in a single year. The same account gives origin shares of 40.77 per cent for China, 18.63 per cent for Türkiye and 5.70 per cent for Hong Kong, a destruction rate of 84.69 per cent of procedures, rights-holder alerts through the IP Enforcement Portal falling to 1,305 from 1,981, and border detentions amounting to 0.66 per mille of third-country imports and about 0.43 per cent of the EUR 99 billion counterfeit-trade estimate.

What is reported, not confirmed

Those are the figures that make the argument, and they are reported rather than confirmed. The EUIPO press release does not carry them, the publication page does not carry them, and the full PDF returned a server error on every attempt. Two of them also sit oddly beside the release: IPWatchdog gives Italy at 80.21 per cent of internal-market articles where EUIPO says over 70 per cent, and its origin shares are a different measure from the detaining-country shares EUIPO published. So treat the six-fold rise in labels as the trade press’s account of a report nobody in this piece has read, and treat the EUIPO totals as firm.

What is firm is enough. A category consisting of labels, tags and stickers is inside the group that makes up almost three quarters of everything the EU detained in a record year.

Why a label is a commodity

The enforcement record of the past three months explains how a category like that gets filled.

In Samut Sakhon and Bangkok on 23 September, the Thai FDA raided four sites producing counterfeit antihistamine syrup and seized more than 1.4 million items. About 37,000 were finished bottles. The rest included more than 400,000 empty bottles, more than 850,000 caps and more than 150,000 label stickers. Eleven empty bottles and four labels for every filled one.

In Birmingham on 14 October, the Medicines and Healthcare products Regulatory Agency and West Midlands Police found over 12,000 counterfeit weight-loss pens and, in the agency’s own words, packaging for around 30,000 more products.

In Aba, Nigeria, counterfeit packaging materials were seized from five shops on Old Court Road Market at a reported value of over 200 million naira. Not counterfeit medicine. Packaging, sold from shops, at a price.

In Karnataka, investigators established that generic medicines had been filled into vials carrying counterfeit Pfizer labels, and that the labels were procured from Turkey. The label was not printed in a back room. It was imported as a separate commodity from another country.

Add the hologram sheets seized by the sheet in Chhattisgarh, and the 40,000 counterfeit track-and-trace stickers and 48,000 holograms found at a single Himachal Pradesh distillery, and the shape is clear. The identity layer has its own manufacturers, its own wholesalers, its own prices and its own inventory. A customs category made of labels is what that industry looks like when a border intercepts it.

The law decided this a long time ago

None of this is a new discovery, and the statute books are the proof.

In 2000 the United States Court of Appeals for the Tenth Circuit decided United States v. Giles, 213 F.3d 1247. The defendant had sold wholesale sets of counterfeit designer patches, unattached to any bag. The court held that the trademark counterfeiting statute did not clearly penalise trafficking in counterfeit labels unattached to any goods, applied the rule of lenity, and the conviction did not stand. The Sixth Circuit had reached the opposite result in United States v. Koehler, 24 F.3d 867, in 1994, so for most of a decade the answer depended on which circuit you were caught in. In the meantime, counterfeiters shipped labels separately from goods, and by 2004 component parts had risen into the top ten commodities seized by US Customs.

Congress closed it. The Stop Counterfeiting in Manufactured Goods Act passed the Senate unanimously on 15 February 2006 and was signed on 16 March as Public Law 109–181. The amended 18 U.S.C. § 2320(a)(2) now reaches whoever intentionally “traffics in labels, patches, stickers, wrappers, badges, emblems, medallions, charms, boxes, containers, cans, cases, hangtags, documentation, or packaging of any type or nature, knowing that a counterfeit mark has been applied thereto.” The definition goes further than the offence: a counterfeit mark includes one applied to packaging “designed, marketed, or otherwise intended to be used” on the goods for which the mark is registered. Intended. The product need never have existed. And trafficking is defined to include making, importing, exporting, obtaining control of or possessing with intent. An individual faces up to 2,000,000 dollars or ten years, and 5,000,000 dollars and twenty years where the goods are drugs.

The European Union reached the same place from the civil side. Article 10 of Regulation (EU) 2017/1001 on the European Union trade mark lets a proprietor act where the risk exists that “the packaging, labels, tags, security or authenticity features or devices” could be used on goods in an infringing way, and prohibits affixing the sign to such items and offering, marketing, stocking, importing or exporting them.

Note what sits in that list. Not only packaging and labels, but security and authenticity features. European trade mark law already contemplates that the device intended to prove a product genuine is itself an article counterfeiters make and ship.

So the EU’s 2025 category breakdown is not a surprise to the law. It is the law’s own prediction, arriving as a customs statistic twenty years later.

Korea’s mint is now printing authenticity

Which brings us to the most interesting development of the month, and it deserves to be taken seriously rather than dismissed.

On 10 October 2026, according to Korea.net reporting two days later, the Korea Minting and Security Printing Corporation and the Ministry of Intellectual Property announced a K-brand verification system for Korean export goods. The design is better than the usual. An AI-assisted digital watermark embeds invisible information in an irregular shape or pattern inside the certification mark, readable by an ordinary smartphone camera. A consumer scans a QR code beside the mark, with no separate app required. A genuine product returns a confirmation message in one of 15 languages, selected from the phone’s own language setting. A product carrying an imitation of the mark returns the warning “Suspected counterfeit.” Use is voluntary for Korean companies, who can apply labels bearing the mark and code or print them directly onto export goods.

The institution is the point. KOMSCO prints South Korea’s currency. The authentication layer for the country’s export brands is now being produced using banknote expertise, and offered to exporters as industrial policy. That is a serious response, and three parts of it are genuinely good: the security feature is covert rather than ornamental, the check needs no app, and the system returns a negative result rather than silence, which is the detail most consumer verification schemes get wrong.

It is also, unavoidably, a printed mark on a carton.

The problem with winning a printing contest

Here is the difficulty, stated as fairly as I can.

Banknotes carry the most advanced printed security features ever deployed at scale: intaglio, microtext, security threads, optically variable ink, watermarks in the substrate itself. They are produced by institutions like KOMSCO whose entire purpose is to make a printed object that cannot be reproduced. And counterfeit currency is still manufactured industrially. Europol reported in February 2026 that its Operation DECOY III, running from June to November 2025 across 18 countries, took counterfeit currency with a face value of about EUR 1.2 billion off more than 7 million items, over 90 per cent of it traced to shipments from China and moved by post.

If the best printed security object in the world is forged at that volume, a better-printed label is an improvement rather than a resolution. And the Korean scheme’s published account does not say how a copied QR code is prevented from passing, or what happens when the watermark is reproduced well enough to read as genuine. It detects an imitation of the mark. It does not, on the published description, establish that the object the mark sits on is the object the mark was issued for.

The counterpoint from another regulator, in the same month, is the sharpest line available on this. Reporting on the K-beauty import trade in Bangladesh on 24 October, The Business Standard quoted Dr Md Akter Hossain, a director of the Directorate General of Drug Administration, on the country’s own import-sticker regime: “Some people produce fake stickers and sell the products, so consumers need to be careful.” A national drug regulator describing its verification sticker as forgeable and placing the burden on the shopper. In the same piece, a freight forwarder said the customer who places the order is responsible for the authenticity of the products, and an importer declined to produce sourcing documents on the grounds that they were private company records.

One state is printing a better sticker. Another state is telling consumers its stickers are copied. Both are true at once, and they are the same problem at different stages.

What the EU’s own numbers say about the limit

The firmest thing in the EUIPO release is also the most sobering for everyone in this story.

A record year of enforcement, 196 million articles, up 67 per cent. On the trade press account of the full report, that is 0.66 per mille of third-country imports and roughly 0.43 per cent of the estimated counterfeit trade. Rights-holder alerts through the IP Enforcement Portal went down, to 1,305 from 1,981, while detentions went up 67 per cent.

So the fastest-growing category in the sample is the identity layer, the sample itself captures well under one per cent of the estimated trade, and the brands who are supposed to feed the system information filed a third fewer alerts than the year before. None of those three facts is improved by a better printing process.

Credit where it is due

It would be easy to write this as institutional failure and it is not one.

The EU’s enforcement data is more granular and more honest than most jurisdictions produce, including about its own coverage. Romania detained 43 per cent of border articles and Italy over 70 per cent of internal-market ones, which is real work by two member states rather than a statistical artefact. Destruction, on the trade account, followed in nearly 85 per cent of procedures.

Korea built something, built it out of its mint rather than a vendor relationship, made it free to use and voluntary, and gave the consumer a negative result instead of a dead link. That is better than most national schemes and better than most brand schemes.

And Congress in 2006 correctly identified, from a case about handbag patches, that the identity layer travels independently of product and needs its own offence.

What we are not saying

No regulation anywhere requires a chip, a tag or any particular physical carrier, and nothing in the Korean scheme, the EU trade mark regulation or the 2006 American statute asks for one.

We are not saying the Korean system does not work. We have not tested it, nobody independent appears to have tested it, and its covert-watermark design is materially stronger than a bare QR code. What we are saying is narrower: the published description does not explain how a reproduced mark is distinguished from an issued one, and that question is the whole question.

We are not claiming the six-fold rise in label detentions as established fact. It is the trade press’s account of a report we could not retrieve.

And we are not claiming a chip settles this either. Anything carried on the packaging can be moved to another package by whoever holds the packaging. The honest version of our own position is that identity has to be bound to the object in a way that cannot survive transfer, and that is an engineering problem with real trade-offs, not a claim a logo settles.

Who meets this problem

The customs officer in Constanța or Trieste, who detained a pallet of labels and can tell you how many there were but not what they were destined for.

The brand protection team whose alert count went down while their category’s detentions went up 67 per cent, because filing alerts is work and the return on it is hard to see.

The Korean exporter who will now pay for a mint-printed certification mark, and who still cannot answer a question about one unit in a Dhaka showroom.

The importer in that showroom, who has been told by his own regulator that the stickers are copied.

And the shopper, who is being asked to scan a code on a carton in order to learn something about what is inside the carton.

If you are one of these people

If you are a brand. Your cartons, labels and authenticity features are now a traded commodity with their own market, and the EU has put them in the same category group as toys and clothing. Work out what you could prove about a single unit if the carton were treated as evidence of nothing, because in the enforcement data it increasingly is.

If you run a brand protection programme. Cover the supply of your identity layer as a product line in its own right. Article 10 of the EU trade mark regulation gives you the civil instrument and 18 U.S.C. § 2320 the criminal one. Neither works if nobody is watching that layer. And if your IP Enforcement Portal alerts have fallen, that is a decision someone made without meaning to.

If you are designing a national verification scheme. Korea’s three good choices are worth copying: a covert feature, no app requirement, and an explicit negative result. The question to answer before launch is what happens when the mark itself is reproduced, because that is the attack the EU’s category data says is growing fastest.

If you are a customs or market-surveillance authority. A category called labels, tags and stickers is a measurement achievement, and it would be more useful still if it were published with its year-on-year change in the press release rather than only in the full report. The six-fold figure in this piece should not have been harder to confirm than it was.

The thing the category is telling us

A counterfeit label is a strange object. It has no use on its own. Nobody wants one. Its entire value is that somebody will later put it on something.

The European Union detained enough of them in 2025 for them to sit in the group of six categories that makes up almost three quarters of everything it stopped. American law has criminalised trafficking in them since 2006, after a court let a man walk because his patches were not sewn onto anything. European trade mark law lists authenticity devices among the articles a brand may prohibit others from stocking.

And the newest answer, from a national mint, is a better one. It may well be a good one. But a printing contest is a contest the printing industry is in, and the counterfeiters are the printing industry.

Aeroz, Making Authenticity Checkable. Visit aeroz.io to learn more & get in contact with our team via [email protected].

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