In 2010, the European Commission launched a public consultation[103] on a proposal to revise Directive 2001/37/EC which covers health warnings, limits on toxic constituents, etc., for tobacco products. The consultation included a proposal to require plain packaging. Although Commissioner Dalli has rejected plain packaging as an option,[104] the European Union included in its proposal for a new Tobacco Products Directive, which became applicable in EU countries in May 2016,[105] the option for the Member States to introduce plain packaging.[106] Legal scholars consider plain packaging to be consistent with primary European law[107] and German law.[108]