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What is ePI and Why is Electronic Labelling Taking So Long in Europe?

UBIQ Events
·
November 4, 2026
What is ePI and Why is Electronic Labelling Taking So Long in Europe?

Key takeaway

ePI and e-labelling are not the same thing. What the EU pharma package changes for package leaflets, where other regions already are, and why a Deputy QPPV says the missing piece is an app.

Short answer: Electronic product information (ePI) is the EU's structured, machine-readable format for the summary of product characteristics, labelling and package leaflet, built on the FHIR standard. E-labelling is something simpler: a digital version of the paper leaflet that patients can open from a code on the pack. Europe has the format, a completed pilot and, with the new pharmaceutical legislation, a legal basis. What it still lacks is a single, patient-facing way to get from the pack to the leaflet, and a decision in each Member State on whether paper can go.

Key takeaways

  • ePI and e-labelling are often confused. As Karsten Lollike put it on our stage: "eLabelling = eLeaflet" and "eLabelling ≠ ePI".
  • EMA's draft ePI roadmap (March 2026) phases centrally authorised products in from Q4 2026, starting with vaccines, then oncology, then all centrally authorised products, in English first (EMA).
  • The EU pharma package keeps the paper leaflet mandatory but requires an electronic version too, and lets Member States move to electronic-only for some or all medicines, with a free printed copy on request. The Council adopted its position on 28 September 2026; Parliament's final vote is pending.
  • Hospital pilots in Belgium and Luxembourg have shipped more than 4.29 million packs of 129 products without paper leaflets since 2018, and 100% of hospital pharmacists surveyed reported no inconvenience (IATF overview, data to mid-2025).
  • Japan has allowed paperless package inserts since 2021. Taiwan, Malaysia and the Gulf states are following. The US still blocks electronic-only labelling by law.

What is electronic product information (ePI)?

In EMA's terms, ePI is "authorised, statutory product information for medicines" in a structured electronic format. It covers the summary of product characteristics (SmPC) for healthcare professionals, the labelling and the package leaflet for patients. The EU ePI Common Standard is based on HL7 FHIR, the same standard used for electronic health records, so the content can be read by apps, websites and hospital systems rather than copied from a PDF.

EMA, the Heads of Medicines Agencies and the European Commission ran a pilot from July 2023 to August 2024 with Denmark, the Netherlands, Spain and Sweden, publishing 23 ePIs from real procedures. The pilot report, published in December 2024, concluded that the system was "generally prepared for the introduction of ePI" and recommended starting with voluntary adoption for centrally authorised products (EMA).

What is the difference between ePI and e-labelling?

The two terms are used as if they meant the same thing, and they do not. Lollike made the distinction his opening point: "E-labelling means digitalising the paper leaflet that comes with the drug package." By contrast, "Electronic Product Information e(PI) is – in EMA terms – something else."

E-labelling, also called ePIL, eLeaflet or eIFU, is the patient-facing outcome: a leaflet you can read on a phone, usually by scanning a code on the pack. ePI is the regulatory data format that makes that leaflet, and every other piece of product information, structured and machine-readable. In his summary: "EMA has focused on ePI as the underlying technology to facilitate e-Labelling". One is the pipe; the other is the tap.

Why does e-labelling matter for patient safety?

Lollike asked the audience two questions. "What is the biggest overall safety issue we are facing in Europe right now?" And: "How long time does it take from decision to update a label until the updated label is in the hands of the patient?"

The second question is the heart of the safety case. When a regulator approves a change to a leaflet, the new text has to be printed and packed, and old stock has to sell through before patients see it. A digital leaflet can be updated the day the change is approved. The UK's Consumer Healthcare Association makes the same point in its 2026 paper on electronic leaflets, noting that paper updates "can lag by months", and estimates that about 3.5 billion paper leaflets are printed for Great Britain each year. In its survey, 71% of people said they would be happy to read a leaflet online.

There are other benefits along the value chain, which Lollike grouped by patients, industry, authorities and the environment: searchable text in large fonts and many languages, fewer repackaging operations, and less waste. Industry's own figures, prepared by Deloitte for EFPIA, put the carbon saving from removing paper leaflets across the EU market at more than 700,000 tonnes of CO2 equivalent (2025, industry-commissioned).

It also helps with shortages. Multilingual packs can move between countries when supply is short, and the leaflet in the patient's language is a scan away. The European Court of Auditors counted 136 critical shortages reported in the EU between 2022 and October 2024, and the Critical Medicines Act, agreed in May 2026, is expected to apply from the end of 2026.

What did we hear on our stage?

At the 5th Pharmacovigilance & Drug Safety Conference in Madrid in April 2026, Karsten Lollike, Scientific VP and Deputy QPPV at Novo Nordisk, gave a tour of e-labelling around the world and asked why Europe is behind. His conclusion was blunt:

"We need somebody to take responsibility to develop technology - app - to link e-Labelling to ePI in Europe"
Karsten Lollike, Scientific VP and Deputy QPPV, Novo Nordisk, 5th Pharmacovigilance & Drug Safety Conference, April 2026

His presentation listed what Europe has: the ePI format, pilots, and now a legal basis in the pharma package. What it lacks is the patient-facing layer. EMA's draft reflection paper on linking packs to ePI, which he summarised, points to using the existing DataMatrix code that already serves the falsified medicines system, preferring HTML over PDF, excluding promotional content, consolidating on one app for simplicity, and involving patients and HCPs in testing. Regulators, in his words, "encourage industry–led initiative to create solution".

The obstacles he named will be familiar to anyone who has sat in a working group: "Evolving technology, but access to internet still a challenge in some regions", regulations still under development, pilots with different scopes and "many national variations", variable technical standards, and three open questions: "What about patients without access? Print out at Pharmacy? Who to pay?"

Where is e-labelling already allowed?

  • Japan abolished paper package inserts in principle from August 2021, replacing them with codes on the pack.
  • Gulf states: according to Lollike's presentation, the Gulf Cooperation Council countries require electronic leaflets, hosted on a mandated regional platform, with QR codes on packs; the deadlines were 30 June 2025 for centrally approved products and 31 December 2025 for the rest. Jordan already asks for leaflets in FHIR XML, the ePI format.
  • Taiwan announced a two-phase move to electronic leaflets in July 2025, with a QR code on the outer box and paper on request (phase 1 by end 2025, phase 2 by end 2026) (Lee and Li).
  • Malaysia is running voluntary e-labelling until 31 December 2026, with over-the-counter generics moving from August 2026 and printed information still available on request.
  • Brazil is consulting on the results of its digital leaflet pilot (2026), keeping a printed leaflet on request.
  • United States: federal spending law still bars the FDA from finalising an electronic-only labelling rule, most recently in the 2026 appropriations act.

Lollike's map showed "54+ Pioneer Markets experimenting with eLabelling" and summed it up: "E-Labelling is already here in several countries, and more countries are joining all the time".

What does the EU pharma package change?

The revised General Pharmaceutical Legislation, politically agreed on 11 December 2025, gives e-labelling a legal basis for the first time. According to the text Lollike presented and the Council's position of 28 September 2026:

  • The package leaflet stays mandatory and must be provided in paper form in the pack and electronically, in the format set by an implementing act.
  • Member States may decide that the leaflet is made available only electronically, for specific categories of medicines or for all of them, after consulting patients, healthcare professionals and other stakeholders.
  • Where the leaflet is electronic only, the patient's right to a printed copy on request, free of charge, must be guaranteed.

The timelines are the open question. Lollike's presentation noted that 18, 24 and 36 months were on the table. The Commission and EMA's October 2026 slides describe an implementing act on electronic leaflet standards due 18 months after entry into force, with the leaflet provisions applying from around Q2 2028. Parliament's final vote and publication in the Official Journal were still pending in autumn 2026.

For what this means for the person accountable for product safety, see What Does a QPPV Do? The Role Explained for 2026.

What is EMA's ePI timeline?

EMA's draft roadmap, first published in March 2026, sets out a phased go-live for centrally authorised products from Q4 2026: vaccines first, then oncology medicines, then all centrally authorised products, with English first and other languages optional during the voluntary phase. Guidance for applicants followed in September 2026, with industry user testing before a go/no-go decision on the Q4 launch (RAPS). National roll-out is pencilled in for 2027 and 2028. EMA has said that ePI will eventually become mandatory for newly authorised medicines, and that submission in all languages will follow.

What this means for pharmacovigilance and regulatory teams

  • Use the right word. ePI is the data format; e-labelling is the patient outcome. Mixing them up confuses project scope and budgets.
  • Start with centrally authorised products. EMA's voluntary phase is the lowest-risk way to learn the FHIR workflow before it becomes mandatory.
  • Plan for paper plus digital. Under the new law, both are required until a Member State decides otherwise. Budget for the transition, not a switch.
  • Measure the safety gain. Track how long label updates take to reach patients today; it is the number that justifies the project.
  • Join the pilots. Hospital pilots in Belgium, Luxembourg, Portugal, the Netherlands, France and the Nordics are where the evidence on patient access is being built.
  • Ask who owns the app. Lollike's question is still open: which body, or which industry consortium, will build and run the link between the pack and the ePI?

What to watch in 2027

  • EMA go-live: whether vaccines move to ePI in Q4 2026 and oncology follows in the first half of 2027.
  • The EU pharma package: Parliament's final vote, publication in the Official Journal and the start of the 18-month clock for the electronic leaflet implementing act.
  • The first Member State to go paperless: the law allows it; the first country to use it will set the template.
  • A European leaflet app: whether EMA, national agencies or industry answer the call to build one patient-facing solution.
  • More Asian markets: Taiwan's phase 2 and Malaysia's deadline at the end of 2026.

These topics will be on the agenda at the 6th Pharmacovigilance & Drug Safety Conference in Barcelona on 27–28 April 2027.

Sources

  1. Lollike, K. (2026). Electronic Product Information (ePI), why is it taking so long to implement in Europe? Presentation at the 5th Pharmacovigilance & Drug Safety Conference, UBIQ Events, Madrid, April 2026.
  2. European Medicines Agency. (2026). Electronic product information (ePI). ema.europa.eu (accessed 4 November 2026)
  3. European Medicines Agency. (2024). Successful pilot paves the way for the implementation of ePI, 16 December 2024. ema.europa.eu (accessed 4 November 2026)
  4. European Medicines Agency. (2026). Electronic product information (ePI) roadmap, draft, March 2026. ema.europa.eu (accessed 4 November 2026)
  5. RAPS. (2026). EMA issues guidance on submitting ePI ahead of upcoming requirement, 8 September 2026. raps.org (accessed 4 November 2026)
  6. European Commission and EMA. (2026). Pharma package implementation slides, 20 October 2026. ema.europa.eu (accessed 4 November 2026)
  7. Sidley Austin. (2026). EU pharma package: compromise text published, 18 May 2026. sidley.com (accessed 4 November 2026)
  8. IATF (EFPIA, Medicines for Europe, AESGP). (2025). Digital leap: industry proposes phased rollout of ePI, 8 January 2025. efpia.eu (accessed 4 November 2026)
  9. IATF. (2026). Overview of the pilots in Europe testing the use of ePI for medicines, data to Q2 2025. PDF (accessed 4 November 2026)
  10. Consumer Healthcare Association. (2026). Electronic patient information leaflets. thecca.org.uk (accessed 4 November 2026)
  11. Lee and Li. (2025). Taiwan MOHW announcement on electronic package inserts, 28 August 2025. leeandli.com (accessed 4 November 2026)
  12. NPRA Malaysia. (2026). E-labelling FAQ, 13 May 2026.
  13. Lachman Consultants. (2025). FY2026 appropriations and FDA electronic labeling, 18 November 2025.
  14. Euronews. (2025). European Court of Auditors report on medicine shortages, 17 September 2025.

Header photo: Christine Sandu on Unsplash.

Frequently asked questions

What does ePI stand for?

ePI stands for electronic product information: the EU's structured, machine-readable format for the summary of product characteristics, labelling and package leaflet, based on the HL7 FHIR standard.

Is e-labelling the same as ePI?

No. E-labelling is a digital version of the patient leaflet, usually opened by scanning a code on the pack. ePI is the underlying data format that makes product information structured and machine-readable. ePI enables e-labelling, but a country can allow e-labelling without ePI.

Will paper leaflets disappear in the EU?

Not automatically. The new EU pharmaceutical legislation keeps the paper leaflet mandatory alongside an electronic version. Each Member State can decide to go electronic-only for some or all medicines, provided patients can get a free printed copy on request.

When will ePI be mandatory in the EU?

EMA's draft roadmap starts a voluntary phase for centrally authorised products from Q4 2026, beginning with vaccines. EMA has said ePI will become mandatory for newly authorised medicines, with national roll-out planned for 2027 and 2028.

Which countries already allow electronic-only leaflets?

Japan has allowed paperless package inserts since 2021. Gulf states require electronic leaflets with QR codes on packs, and Taiwan and Malaysia are phasing in e-labelling with paper on request. The US does not yet allow electronic-only labelling.

Where can I discuss ePI and e-labelling with drug safety leaders?

The Pharmacovigilance & Drug Safety Conference, organised by UBIQ Events, brings together QPPVs, regulatory and drug safety leaders. The 6th edition takes place in Barcelona on 27–28 April 2027.

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