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Environmental claims based on environmental footprint methods

Environment

To increase consumer confidence in green labels and strengthen the protection against green washing, the initiative will require companies to substantiate their claims on environmental performance using Product and Organisation Environmental Footprint methods.

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Public consultation

ID: 12511

Lobbying Activity

246 responses

Environmental groups urge stricter rules against greenwashing

European Environmental Bureau, 17 Jul 2023

The EEB requests harmonised EU requirements for substantiating green claims, a ban on offsetting-based neutrality claims, and mandatory third-party verification before claims reach the market. They want all environmental labels to meet robust standards regardless of sector.
This would reduce consumer confusion and strengthen market position of genuinely sustainable products.
Companies using weak self-assessment or offsetting lose ability to market products as green.

Environmental groups demand stricter rules for green product claims

European Environmental Bureau, 31 Aug 2020

The EEB supports Policy Option 3 but insists companies only make claims about performance that differentiates them from competitors and exceeds market averages. Claims must address the entire supply chain and avoid hiding negative impacts through burden shifting.
This would reduce competition from unsubstantiated green claims and strengthen ISO Type 1 ecolabels they endorse.
Companies making green claims below market average or addressing only limited supply chain stages lose marketing advantages.

Consumer group BEUC demands ban on carbon neutral claims

Bureau Européen des Unions de Consommateurs, 13 Jul 2023

BEUC requests that claims are verified before being made public and calls for a ban on carbon neutral claims. They also urge including microenterprises to ensure all company claims are regulated.
This would protect consumers from systemic greenwashing and help identify truly sustainable products.
Companies using misleading environmental labels would face removal from the market.

Consultation response

Bureau Européen des Unions de Consommateurs, 26 Aug 2020

Many traders are taking advantage of consumers’ growing interest in environmental matters because of the climate crisis and are using green claims to differentiate themselves. Many claims are not or cannot be substantiated. This triggers confusion and mistrust among consumers and jeopardizes their…

AmCham EU urges streamlined verification for green product claims

American Chamber of Commerce to the European Union, 20 Jul 2023

The group wants to clarify the scope of claims and exclude corporate communications. They suggest extending the transition period to 18 months to avoid supply chain disruptions.
Allowing a sell-off period would prevent the exceptionally expensive cost of product recalls.
Consumers might lose access to detailed technical evidence if disclosure requirements are streamlined.

Consultation response

Association des Constructeurs Européens d'Automobiles, 31 Aug 2020

ACEA welcomes LCA analyses as they are important procedures that can help to reduce a motor vehicle’s impact on the environment and believes that the studies made should be scientifically sound and compare equivalent systems. LCA can be a useful tool to address environmental issues and is applied…

German Industry Group Urges Flexible Green Claims Rules

Bundesverband der Deutschen Industrie e.V., 11 Jul 2023

BDI requests that mandatory third-party verification be dropped or simplified to reduce bureaucratic burdens and costs. They advocate for longer implementation deadlines and an extended timeframe for companies to take corrective actions on labels.
This would prevent excessive administrative costs and maintain marketing speed for companies.
Consumers lose access to product information if companies stop communicating their sustainability features.

Consultation response

Bundesverband der Deutschen Industrie e.V., 27 Aug 2020

The BDI supports the further development of the Product Environmental Footprint (PEF) method as a voluntary procedure for evaluating the environmental impact of products. The further development should be brought in line with the ISO standards for calculation and reporting or communication. The…

Chemical Industry Seeks Green Claims for Products with Hazardous Substances

European Chemical Industry Council, 13 Jul 2023

The industry requests that products containing hazardous substances remain eligible for environmental claims when safe use is demonstrated. They oppose the proposed five-year review that could ban such claims except for essential uses. They also seek extended transition periods and adjustments to the Product Environmental Footprint methodology to account for recycled materials and biogenic carbon.
This preserves their ability to market products containing hazardous chemicals as environmentally beneficial.
Consumers lose stronger safeguards against potentially misleading environmental claims on hazardous products.

Chemical Industry Calls for Voluntary Green Claims Framework

European Chemical Industry Council, 31 Aug 2020

Cefic requests a voluntary scheme for environmental claims rather than mandatory requirements. They want methods that are science-based, practical, and cost-efficient with no disproportionate administrative burden. They advocate for alignment with existing ISO frameworks and sector-specific approaches.
This would allow them flexibility to use their own substantiation methods beyond legal requirements.
Consumer groups lose stronger protections against misleading environmental claims and greenwashing.

EuroCommerce urges simpler rules for environmental product claims

EuroCommerce, 11 Jul 2023

EuroCommerce requests excluding food and corporate reports from the scope to avoid overlapping rules. They also call for a 12-month transition period and simplified, harmonized verification procedures.
This would lower administrative costs and provide legal certainty for cross-border retailers.
Consumers might experience delays in sustainability messaging due to complex approval procedures.

Consultation response

EuroCommerce, 31 Aug 2020

EuroCommerce welcomes the opportunity to provide feedback regarding the Inception Impact Assessment on substantiating green claims. The attached statement aims to summarize key points from the retail and wholesale sector on green claims and the Product Environmental Footprint (PEF) and support…

DigitalEurope urges harmonized rules and digital environmental labelling

DIGITALEUROPE, 20 Jul 2023

The association proposes turning the directive into a regulation to ensure maximum harmonization. They advocate for digital labelling via QR codes to replace physical packaging requirements. They also suggest using alternative standards when specific product footprint rules are unavailable.
A harmonized approach with digital labels would significantly lower compliance costs for companies.
Environmental groups lose assurance if verifiers prioritize desk audits over on-site inspections.

Steel industry demands common standards for EU green claims

The European Steel Association, 21 Jul 2023

The association wants the EU to use environmental footprint rules for substantiating claims. They oppose banning green claims for products containing hazardous substances if deemed safe.
This would reduce regulatory barriers and allow companies to market products across borders.
Environmental groups lose stricter controls on marketing products that contain hazardous chemicals.

Consultation response

The European Steel Association, 31 Aug 2020

The European Steel Association - EUROFER, supports the establishment of a common and consistent assessment framework that will, in principle, reduce cost to industry by limiting the proliferation of assessment methods and labels. This should help retain access to a single market without barriers to…

SMEunited demands simplified green claim rules for European SMEs

SMEunited aisbl, 24 May 2023

The association requests simplified substantiation criteria and an alternative verification scheme for smaller businesses. They advocate for EU-level tools to facilitate lifecycle analysis and help businesses comply. Additionally, they propose an assumption of conformity for small-scale marketing and local advertising.
Smaller companies would avoid excessive administrative costs and maintain a level playing field.
Third-party verification providers would lose business if SMEs use alternative national schemes.

Consultation response

SMEunited aisbl, 27 Aug 2020

Putting some order in the world of green claims is definitely useful and important. However, there is a big risk that the use of certain methodologies, such as PEF / OEF, could make life much more difficult for craft and SMEs in terms of higher costs and administrative work. This is due to the fact…

Consultation response

EPIA SolarPower Europe, 31 Aug 2020

Please find SolarPower Europe feedback attached, thank you.

Finnish Forest Industry Urges Stronger Support for PEF Methodology

Finnish Forest Industries Federation (Metsäteollisuus ry), 3 Jul 2023

The industry calls for stronger recommendations to use the Product Environmental Footprint methodology. They insist that industry actors must be involved in drafting specific product rules. Verification must not be too complicated or costly for companies.
Stronger PEF integration allows them to leverage existing work and lower compliance costs.
Independent verifiers lose if accreditation standards are lowered to accommodate industry preferences.

BASF seeks longer transition and hazardous substance exemptions

BASF SE, 21 Jul 2023

BASF requests extending the transition period to at least 30 months. They want environmental claims allowed for products containing hazardous substances. The company suggests using international standards and the mass balance approach.
This ensures BASF can market complex chemicals as sustainable without facing immediate verification delays.
Environmental groups lose stricter European-specific methods designed to reduce corporate greenwashing.

Danish Industry urges simpler rules for environmental claims

Confederation of Danish Industry, 18 Jul 2023

DI requests simple rules to prevent companies from avoiding green communication. They oppose mandatory third-party certification and want animal welfare excluded. Rules should align with existing Danish guidelines to ensure consistency.
Reducing documentation and removing certification requirements would lower administrative costs.
Animal welfare groups lose by having ethical concerns removed from assessments.

BirdLife Europe demands ban on misleading nature-friendly imagery

Stichting BirdLife Europe, 20 Jul 2023

The group wants the law to cover implicit messages like pictures of flowers or insects. They advocate for public agencies to handle certifications to ensure higher consumer trust. They also call for environmental groups to be involved in setting label criteria.
Direct involvement in criteria setting would increase the group's institutional influence over labels.
Intensive farming companies would lose the ability to use generic nature-inspired marketing.

Orgalim Demands Maximum EU Harmonization for Environmental Product Claims

Orgalim – Europe's Technology Industries, 20 Jul 2023

The group supports common criteria against greenwashing but requests a Regulation to ensure uniform implementation. They urge the Commission to avoid double regulation and simplify documentation requirements.
Maximum harmonization would reduce compliance costs and prevent legal fragmentation across the internal market.
Private labeling schemes face new restrictions that could stifle innovation in emerging sustainability areas.

Insurance Europe demands consistent EU green claim regulations

Insurance Europe, 20 Jul 2023

The federation calls for the directive to be aligned with existing financial regulations. They request uniform criteria to prevent inconsistent implementation across different member states.
Alignment with existing laws would reduce compliance costs and prevent redundant administrative burdens.
Environmental groups would face restricted access to justice and limited influence over authorities.

DIHK warns Green Claims Directive creates overregulation and burdens SMEs

Deutsche Industrie- und Handelskammer, 20 Jul 2023

The DIHK argues that existing unfair competition laws already prevent greenwashing effectively. They request focus on term transparency instead of creating new bureaucratic control structures. This would avoid a competitive distortion that disproportionately harms smaller businesses.
Businesses would avoid paying an estimated fifty-four thousand euros per individual certified claim.
Consumers lose access to green information as firms avoid communication to escape legal risks.

FoodDrinkEurope urges streamlined verification for green product claims

FoodDrinkEurope, 20 Jul 2023

The industry calls for a 36-month transition period and simplified verification to avoid administrative delays. They suggest a life cycle perspective instead of full assessments for every claim. They propose qualitative assessments when scientific evidence for specific environmental impacts is missing.
Less rigorous assessment requirements would lower compliance costs and protect confidential business information.
Consumers may receive less granular data if detailed impact studies are kept confidential.

Consultation response

FoodDrinkEurope, 31 Aug 2020

Methodology FoodDrinkEurope supports a credible and EU-harmonized environmental footprint methodology based on PEF. The harmonized PEF methodology should be the basis for identifying hotspots, promoting continuous improvement and provide product information to other businesses or consumers. You…

WKO urges radical simplification of EU green claim rules

Wirtschaftskammer Österreich, 5 Jul 2023

The organization demands the proposal be massively toned down by deleting mandatory third-party verification and extending exemptions to all small businesses. They seek a radical simplification of requirements to ensure companies continue communicating their voluntary environmental measures.
This would reduce the time-consuming and cost-intensive administrative burdens currently facing Austrian businesses.
Consumers may lose access to helpful environmental orientation if companies abandon voluntary communication.

Consultation response

Wirtschaftskammer Österreich, 28 Aug 2020

• In general: EU framework for methodology on PEF and OEF on voluntary basis in a harmonised matter may be useful – mandatory system not first choice, different P(O)EFCRs in Member States to be avoided – therefore WKO proposing to consider option 1 (update of PEFs and OEFs) or 2 (voluntary legal…

Eurometaux demands EU formalize environmental footprint methodology

EUROMETAUX, 20 Jul 2023

The organization requests integrating the Product Environmental Footprint methodology directly into the directive. They also argue that hazardous substances shouldn't automatically disqualify products from green claims.
Using these standards allows the industry to market essential green-transition metals.
Environmental groups lose if hazard-based bans on green claims are weakened.

Consultation response

EUROMETAUX, 31 Aug 2020

Eurometaux, the European non-ferrous metals industry, has been actively engaged in the European Commission’s Environmental Footprint (EF) project and has developed, during the EF Pilot Phase, the ‘Product Environmental Footprint Category Rules (PEFCR) for Metal Sheets in Various Applications’.…

Schneider Electric calls for EU regulation on green claims

Schneider Electric, 21 Jul 2023

Schneider Electric urges the Commission to make the Directive a Regulation to avoid a fragmented approach. They advocate for expanding the scope to include business to business practices.
This would ensure a uniform application of rules across the European Single Market.
Business-to-business companies would face new compliance requirements if the scope is expanded.

Consultation response

MedTech Europe, 31 Aug 2020

MedTech Europe - the European trade association for the medical technology industry including diagnostics, medical devices and digital health - welcomes the opportunity to contribute to the initial roadmap consultation regarding the legislative proposal for substantiating green claims. Medical…

MEDEF demands pragmatic EU rules for environmental claims

Mouvement des Entreprises de France, 21 Jul 2023

MEDEF requests the preservation of national tools and the removal of pre-approval requirements. They also call for a 36-month implementation period for technical adjustments.
This would lower administrative costs and protect existing French business investments.
Consumers may lose access to environmental information if companies abandon green claims.

European Aluminium demands strict verification and industry expertise

European Aluminium AISBL, 19 Jul 2023

The association supports strict verification to prevent unfair advantages from false claims. They request technical committees with industry experts to support national authorities. The group also seeks clear rules for comparative environmental assessments.
Robust rules would protect industry competitiveness by ensuring a level playing field.
Products with unsubstantiated claims would lose their current unfair competitive advantage.

European paper industry calls for realistic green claim rules

Confederation of European Paper Industries, 19 Jul 2023

Cepi urges alignment with existing EU laws and the recognition of established forest certification labels. They also request updates to calculation methods to better reflect sustainable forestry and carbon storage.
This would reduce administrative burdens and ensure environmental impacts are not unfairly calculated.
Foreign exporters would lose their competitive advantage unless they meet the same strict verification standards.

Consultation response

Confederation of European Paper Industries, 31 Aug 2020

Joint paper value chain reply on the EU Consultation on Green Claims : In December 2019, the European Commission presented its ambitious Green Deal roadmap, a comprehensive strategy aimed at putting Europe on the right track for climate neutrality in 2050 while encouraging sustainable economic…

IFOAM Organic Europe Demands Stronger Agri-Food Labeling Standards

International Federation of Organic Agriculture Movements EU Regional Group, 30 Jun 2023

The organization calls for integrating biodiversity and animal welfare into environmental assessments, as current methodologies fail to capture systemic impacts. They also demand uniform enforcement to prevent companies from seeking verification from lenient national regulators.
This approach protects organic producers by ensuring that greenwashing does not disadvantage truly sustainable farming practices.
Producers using simple efficiency scores lose the ability to market products that ignore broader ecological impacts.

Consultation response

International Federation of Organic Agriculture Movements EU Regional Group, 20 Aug 2020

IFOAM Organics Europe (IFOAM OE) welcomes the Commission's initiative on the "Environmental performance of products & businesses – substantiating claims", as it aims to increase trustworthiness of environmental claims. Similarly, IFOAM OE welcomes that the Farm to Fork strategy stipulates that “the…

German insurers demand consistency in EU green claim regulations

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 10 Jul 2023

The association demands alignment between the Green Claims Directive and existing disclosure regulations. They want the Sustainable Finance Disclosure Regulation explicitly included to avoid legal uncertainty. They also request that auditors be permitted to act as official verifiers.
Coordination of different legislative projects would provide a clear and predictable legal framework.
Interest groups would lose the right to take legal action against supervisory authorities.

Bitkom rejects EU Green Claims Directive over bureaucratic burdens

Bitkom e.V., 18 Jul 2023

Bitkom calls for the removal of mandatory pre-approval procedures for environmental claims. They also request extending the transitional implementation period to at least 30 months.
These changes would lower compliance costs and ensure companies communicate product improvements faster.
Consumer protection organisations lose the intended administrative relief of pre-verified certificates for monitoring claims.

Consultation response

Zentralverband des Deutschen Handwerks e.V., 31 Aug 2020

Der ZDH hat das Vorhaben der europäischen Produkt- und Organisationsökobilanzen bisher kritisch begleitet. Grund dafür war erstens die Befürchtung, dass die Ökobilanzen mit erheblichen Aufwänden und Kosten verbunden sein werden und damit handwerkliche Herstellung strukturell benachteiligt wird…

Consultation response

CEMBUREAU - The European Cement Association, 28 Aug 2020

CEMBUREAU, the European Cement Association, welcomes the opportunity to provide feedback on the Commission Inception Impact Assessment on a legislative proposal on substantiating green claims. Please find attached a position paper which sets out our views. We hope this can serve as a basis for…

Swedish forest industry urges clarity on green claim rules

Swedish Forest Industries Federation, 14 Jul 2023

SFIF calls for a mechanism allowing commercial stakeholders to contribute to monitoring and implementation. They urge the Commission to clarify vague criteria to prevent the risk for arbitrary interpretation. They also demand industry involvement during the development of secondary legislation.
Specific guidelines would reduce the risk of facing unpredictable legal consequences.
Environmental groups lose influence if product rules are shaped by industry majorities.

Consultation response

Swedish Forest Industries Federation, 28 Aug 2020

The Swedish Forest Industries Federation represents the Swedish forest industry. Our members refine wood resources to bio-based products. This includes among others pulp, paper, board, packaging material, sawn timber, refined wood products and advanced biofuels. Some members have large forest…

Home appliance makers urge delay for new green claim rules

APPLiA (Home Appliance Europe), 20 Jul 2023

APPLiA proposes making the rules uniform across Europe by using a Regulation. They suggest extending the application timeline to 30 months and removing requirements to compare products against competitors.
Companies would avoid disclosing confidential commercial information and the expense of reworking packaging.
Consumer advocates lose the ability to compare specific environmental performance between competing brands.

European Brands Association Urges Longer Transition For Green Claims

AIM - European Brands Association, 20 Jul 2023

AIM requests a 36-month implementation period and the removal of requirements to compare products against common industry standards. They also support using digital means like QR codes to provide environmental data to consumers.
A longer transition and digital tools would reduce immediate compliance costs and packaging burdens.
Micro-enterprises would lose their current regulatory advantage if exemptions are removed as requested.

Consultation response

AIM - European Brands Association, 31 Aug 2020

When it comes to the empowerment of consumers to play their part in the Circular Economy and the Green Deal, simple, understandable and EU-harmonised information about the sustainability features of a product is key. Any such information needs to be ‘actionable’ by consumers. Brands inform and…

Consultation response

Verband der Chemischen Industrie e.V., 20 Jul 2023

The German Chemical Industry Association (VCI) is committed to bringing products to market that are both safe and have lower burdens on the environment. Therefore, the VCI welcomes as a matter of principle the EU Commissions approach to create more transparency in the business-to-consumer sector.…

Danish agriculture group demands harmonized standards for green labels

Landbrug Fødevarer - Danish Agriculture and Food Council, 30 Jun 2023

The group wants a single calculation method used across Europe for all environmental claims. They also argue that animal welfare should be excluded and all farming methods treated equally.
A common methodology would lower the administrative burden and costs for food exporters.
Local national labeling schemes would lose their advantage in promoting domestic goods over imports.

Consultation response

Landbrug Fødevarer - Danish Agriculture and Food Council, 31 Aug 2020

Kommentarer til public consultation om Legislative proposal on substantiating green claims: Landbrug & Fødevarer (Danish Agriculture and Food Council) takker Kommissionen for at inddrage offentligheden og relevante stakeholderes i udviklingen af et framework for green claims. Vi repræsenterer hele…

Carbon Market Watch calls for ban on misleading neutrality claims

Carbon Market Watch, 20 Jul 2023

The organization demands an explicit ban on carbon neutrality and offsetting claims. These claims are scientifically unproven and frequently mislead consumers about climate impacts.
A total ban would fulfill the organization's primary objective of stopping greenwashing.
Companies using cheap offsets would lose their ability to claim climate neutrality.

German steel industry demands practical and coherent green claim rules

Wirtschaftsvereinigung Stahl, 21 Jul 2023

WV Stahl demands that established assessment tools remain valid and warns against excessive secondary legislation. They call for uniform enforcement across Europe and limiting legal complaints to expert groups.
Recognizing existing standards would prevent high administrative costs and reduce bureaucratic burdens.
Individual consumers would lose their direct right to challenge corporate environmental claims.

Consultation response

European Association of Mining Industries, Metal Ores & Industrial Minerals, 28 Aug 2020

Euromines members are committed to facilitating and encouraging the promotion of safe use, recycling and disposal of products through an understanding of their life cycles. Euromines has made significant contributions to the science of Life Cycle Assessment, on which the Environmental Footprint…

Consultation response

Wirtschaftsvereinigung Stahl, 14 Aug 2020

Die Wirtschaftsvereinigung Stahl begrüßt die Anstrengungen der Kommission, einen einheitlichen Bewertungsrahmen für Umweltleistungen von Produkten und Dienstleistungen zu schaffen, der Kosteneinsparungen zum Ziel hat, indem die Zahl der Bewertungsmethoden und deren Kommunikation begrenzt wird. Ein…

Cosmetics Europe urges harmonized rules and longer implementation timelines

Cosmetics Europe, 18 Jul 2023

The industry requests a harmonized verification process and a 36-month implementation period. They also advocate for digital disclosure to protect sensitive business data.
Extended deadlines and digital summaries would minimize market disruption and compliance costs.
Environmental rating apps and NGOs would face new, burdensome regulatory constraints.

Consultation response

Cosmetics Europe, 28 Aug 2020

Cosmetics Europe represents the cosmetics and personal care industry in Europe. From dermo-cosmetics, fragrances, make-up and shampoos, to soaps, sunscreens and toothpastes, cosmetics and personal care products play an essential role in consumers’ every-day lives. We welcome the opportunity to…

ECOS urges ban on offsets in Green Claims Directive

Environmental Coalition on Standards, 20 Jul 2023

ECOS calls for a ban on environmental claims involving carbon offsets or hazardous substances. They request standardized methods to prevent verifiers from rubberstamping greenwashing through inconsistent interpretations.
Stricter rules ensure green marketing promotes sustainable consumption instead of supporting polluting industries.
Polluting companies lose the ability to protect their market share through misleading green branding.

Consultation response

Environmental Coalition on Standards, 31 Aug 2020

ECOS supports the provision of environmental information to consumers environmentally relevant, reliable, comparable and verifiable, through the development of an EU legal framework requiring companies to substantiate claims via the Environmental Footprint methods. Having said this, for sustainable…

Consultation response

The European Organisation for Packaging and the Environment, 27 Aug 2020

EUROPEN supports the general objective of this initiative, which is to unlock opportunities for the circular and green economy, including by fostering the growth of green markets through value chain thinking and ensuring a more efficient use of resources. We also specifically support the objective…

German consumer group vzbv demands stricter rules against greenwashing

Verbraucherzentrale Bundesverband, 13 Jul 2023

vzbv demands that the Green Claims Directive applies to all sectors and company sizes to protect consumers. They specifically call for a ban on advertising with climate neutrality based on carbon offsetting and future environmental performance.
Stricter regulations and broader scope would make it easier for vzbv to hold companies accountable.
Financial firms and microenterprises would face higher compliance costs and stricter advertising limits.

A2A calls for clearer scope in Green Claims Directive

A2A, 21 Jul 2023

A2A requests clarity on whether institutional brand positioning is included in the directive's scope. They advocate for a proportionality principle and reusing verified claims across multiple channels. Finally, they suggest simple wording to avoid technical information overload for consumers.
Streamlining the verification process would reduce administrative burdens and prevent market entry delays.
Consumers could face higher prices for essential services if verification procedures are overly burdensome.

ICA Europe urges flexible standards for environmental claims

International Copper Association Europe, 20 Jul 2023

ICA Europe requests that multiple assessment methods be accepted. They advocate for harmonized recognition of labelling schemes. They also oppose banning claims on products containing hazardous substances.
This allows the industry to use existing schemes and avoid costs of new EU methodologies.

Consultation response

International Copper Association Europe, 31 Aug 2020

The European Copper Institute (ECI) welcomes the European Commission’s efforts to establish positive rules to substantiate environmental claims as a tool to unlock opportunities for a green and circular economy. Option 1 & Option 2 as outlined in the Inception Impact Assessment of the European…

Independent Retail Europe demands retailer immunity from producer liabilities

Independent Retail Europe (formerly UGAL - Union of Groups of Independent Retailers of Europe), 7 Jul 2023

Retailers should not be liable for any wrongful claim made by producers on products they sell. The proposal must maintain the business case for sustainability and clarify the obligations of traders.
This would protect retailers from financial penalties and revenue confiscation for errors beyond their control.
Producers would carry the full legal and financial burden for incorrect product environmental claims.

Recyclers demand independent expert verification for green claims

European Recycling Industries' Confederation, 21 Jun 2023

EuRIC requests that environmental claims are verified by independent third-party experts with specific competence. They also call for all data to be transparent, freely accessible, and sufficiently detailed.
The industry benefits from rules preventing competitors from falsely claiming products contain recycled materials.
Producers making false or exaggerated environmental claims will lose the ability to mislead consumers.

Detergent industry urges harmonized rules and longer green claim timelines

Association Internationale de la Savonnerie, de la Détergence et des Produits d'Entretien, 20 Jul 2023

The association calls for a harmonised approach across Member States to protect the market. They request a 36-month transition period and a 30-day deadline for verifier assessments. They also seek mutual recognition for existing environmental labels to avoid further verification.
A longer transition period avoids the cost of withdrawing and destroying current product stocks.
Consumer groups lose the benefit of rigorous new oversight for existing environmental labeling schemes.

Consultation response

Association Internationale de la Savonnerie, de la Détergence et des Produits d'Entretien, 28 Aug 2020

A.I.S.E. calls for measures that are: • based on sound science and in consideration of impacts across the full life cycle of the product and its packaging; • developed in a consistent and coherent way with existing legislation. A.I.S.E. recommends to consider “Option 1” (ie. update the 2013…

Ecommerce Europe urges harmonised guidance for green claims rules

Ecommerce Europe, 21 Jul 2023

The group requests clear guidance to avoid overlaps with other sustainability laws. They advocate for a regulation rather than a directive to prevent legal fragmentation. They also suggest exempting second-hand goods and extending the transition period.
Better harmonisation would reduce legal complexity and administrative costs for cross-border retailers.
Smaller manufacturers may be priced out by expensive and slow verification procedures.

Consultation response

Cruise Lines International Association, 30 Aug 2020

Dear, An EU initiative on “Environmental performance of products & businesses – substantiating claims” could have far reaching unintended consequences for a worldwide operating sector which is highly regulated and already knows various environmental indicators, many of whom determined by the…

EU self-care industry urges realistic timelines for green claims

Association of the European Self-Care Industry, 20 Jul 2023

We recommend extending the timelines for application to thirty-six months. Digital means like QR codes should be allowed for providing required evidence. Self-certification would be a more proportionate approach for certain clear claims.
This would reduce the financial burden and prevent increasing packaging sizes.
Strict rules for new private labeling schemes create barriers for market entry.

Consultation response

Norsk Hydro, 31 Aug 2020

Please find Hydro's contribution attached

Finnish small businesses warn green claim rules burden SMEs

Suomen Yrittäjät ry, 10 Jul 2023

The Federation requests mandatory state support and fairer penalties for small businesses. They argue that high costs and strict rules currently threaten firm survival.
This would reduce administrative costs and prevent small firms from market exclusion.
Consumers lose transparency if inspection results are suppressed to protect company reputations.

Consultation response

PepsiCo, 31 Aug 2020

PepsiCo welcomes the opportunity to provide feedback on the Inception Impact Assessment on the legislative proposal on substantiating green claims. PepsiCo strongly supports the EU’s objective to achieve a circular and green economy as well as climate neutrality by 2050. The harmonisation and…

Consultation response

Forum Atomique Européen, 14 Aug 2020

FORATOM welcomes the goal of ensuring that consumers receive accurate information about the environmental footprint of products and services available in the EU. In order to be credible, such assessments need to be science-based and applied in the same way. Furthermore they should take account the…

WWF Germany demands ban on offset-based climate claims

WWF Deutschland, 20 Jul 2023

WWF supports a holistic assessment of environmental impacts using the Product Environmental Footprint method. They specifically demand a ban on climate neutrality claims based solely on carbon offsets. Additionally, they call for better-equipped national authorities to verify claims and enforce sanctions.
Standardized rules would protect the credibility of green labels and prevent market-wide greenwashing.
Companies using cheap carbon offsets would lose their ability to make climate-neutral claims.

Consultation response

Association de l'Aviculture, de l'Industrie et du Commerce de Volailles dans les Pays de l'Union Europeenne asbl, 31 Aug 2020

AVEC (transparency number 9803788883-16), representing the EU poultry meat sector, would like to thank the Commission to give use the possibility to provide feedbacks on this public consultation on the upcoming legislative proposal on substantiating green claims. Over the last decades, our…

UECBV calls for clear rules on environmental green claims

Union Européenne du Commerce du Bétail et des Métiers de la Viande, 21 Jul 2023

UECBV supports the effort to harmonise claims and labels to ensure sector credibility. They argue that additional criteria like animal welfare should not be part of this directive. They also demand clearer wording to ensure a level playing field.
This would allow companies to get credit for specific environmental improvements.
Animal welfare groups may lose visibility if excluded from these labels.

ECTAA: Green claims rules risk silencing travel industry sustainability

ECTAA, Group of National Travel Agents' and Tour Operators' Associations within the EU, 21 Jul 2023

ECTAA requests simpler verification for SMEs and clarification on intermediary liability. They urge the Commission to avoid duplicating audits for existing certification schemes.
Simplified rules would reduce compliance costs and help SMEs promote sustainable tourism choices.
Consumers lose access to sustainability data if companies stop making environmental claims.

Consultation response

Union Européenne du Commerce du Bétail et des Métiers de la Viande, 31 Aug 2020

UECBV sees the upcoming legislative proposal on substantiating green claims as the basement for allowing businesses to go to carbon neutrality. It is of the utmost importance to go towards scientifically based, fair and “harmonised claims” so that efforts are comparable, looking for the same…

FEFAC urges single harmonised methodology for environmental claims

Fédération Européenne des Fabricants d'Aliments Composés, 12 Jul 2023

FEFAC suggests adopting the PEF method as the primary option for harmonised footprint determination. The group will propose professional rules for business communication to support sustainable livestock.
The industry avoids new costs by using their established sector-specific tools.
Consumers suffer from confusion caused by a lack of clear benchmarks.

Consultation response

Fédération Européenne des Fabricants d'Aliments Composés, 31 Aug 2020

FEFAC, the European Feed Manufacturers’ Association, is an early supporter of the PEF methodology & harmonisation initiative at European level. FEFAC coordinated the Technical Secretariat on the PEFCR Feed for Food-Producing Animals which was published in April 2018. Prior to the launch of PEF…

Consultation response

Confédération des Petites et Moyennes Entreprises, 31 Aug 2020

Vous voudrez bien trouver ci-joint la contribution de la Confédération des petites et moyennes entreprises. La CPME est l’organisation patronale française des petites et moyennes entreprises, tous secteurs confondus : industrie, services, commerce, artisanat et professions libérales.

EURATEX urges clear rules to avoid green claim confusion

EUROPEAN APPAREL AND TEXTILE CONFEDERATION, 20 Jul 2023

EURATEX calls for a coherent framework to avoid a 'methodological jungle' and minimize administrative burdens. They advocate for fast, flexible verification procedures and clarity on the Product Environmental Footprint method.
A streamlined system would lower costs and protect their investments in green transition.
Non-EU importers would face higher costs if required to meet the same standards.

Consultation response

Aurubis AG, 31 Aug 2020

Aurubis, a world’s leading manufacturer of non-ferrous metals, welcomes the opportunity to provide feedback on the Inception Impact Assessment of the legislative proposal on substantiating green claims. Our recommended options are Option 1 and Option 2. We support the use of life cycle…

European Dairy Association urges harmonized footprint rules for food

European Dairy Association aisbl, 20 Jul 2023

The association requests using the Product Environmental Footprint method as the primary standard. They also propose restricting comparisons to items within the same food category and including nutritional value.
This would allow the dairy sector to use its own pre-approved measurement rules.
Consumers lose the ability to compare environmental impacts across different food categories.

Consultation response

European Dairy Association aisbl, 27 Aug 2020

EDA supports the use of the Product Environmental Footprint (PEF) methodology to substantiate green claims in the EU. We support action by the EU Commission to integrate the PEF into existing or new policy instruments, to reward sustainable practices and limit the risk of credibility loss that the…

Consultation response

Carbon Gap ASBL, 20 Jul 2023

Climate-related claims are one way for companies to attempt to communicate their climate mitigation efforts to their customers. If such claims fail, arent real, and dont stand up to scientific scrutiny, they become a dangerous tool for greenwashing. Not only do such false claims mislead consumers,…

H&M Group Urges Harmonized EU Green Claims Rules

H M Hennes Mauritz AB, 20 Jul 2023

H&M requests an implementation period longer than six months to adapt internal processes and supply chains. They support recognizing the apparel and footwear industry's efforts in developing footprint measurement methodologies. The company seeks complete recognition of verified claims across all EU Member States.
A harmonized approach would reduce regulatory complexity and the associated administrative burdens for the company.
National authorities lose the ability to challenge certificates verified in other Member States without solid grounds.

Consultation response

European Insulation Manufacturers Association, 31 Aug 2020

Eurima welcomes the Commission’s intention to harmonize and set a baseline for the substantiation of green claims for products and businesses. Our industry shares the concerns raised in the Roadmap regarding the detrimental impact of unsubstantiated green claims on consumers, both on B2B and…

Branded clothing alliance urges single methodology for green claims

European Branded Clothing Association, 21 Jul 2023

EBCA recommends a single methodology and a harmonized verification process with time limits. They also call for a longer implementation period to allow for necessary adjustments.
This would reduce administrative costs and provide certainty for product development and marketing.

Consultation response

FEAD, 31 Aug 2020

FEAD, the European Federation for Waste Management and Environmental Services, welcomes the European Commission’s initiative to substantiate green claims in order to empower the consumer and business partners for the green transition. Private waste management companies are major operators in this…

Arla Foods urges clearer definitions and longer green claims transition

Arla Foods amba, 21 Jul 2023

Arla Foods encourages decision makers to provide further clarity in the definitions. They suggest the proposal should reference the specific dairy environmental footprint methodology. The group also recommends extending the transition period to provide enough time to comply.
Following a single methodology would ensure legal certainty and transparency for the company.
Consumers face a delay in receiving environmental information if the application period is extended.

Consultation response

Environmental Defense Fund Europe, 28 Aug 2020

The amount of sustainability certifications and markers on products and packaging is confusing for brands, retailers, and especially consumers. Environmental Defense Fund is excited to see the EU develop regulation around product claims ensuring such claims be backed by scientific evidence. The…

IKEA urges harmonised and efficient EU green claim rules

Inter Ikea Systems BV, 19 Jul 2023

IKEA advocates for harmonising ways to measure environmental impacts at the EU level. They request a manageable pre-approval system to avoid long and costly procedures. The proposal should establish a centralised pre-approval process for labelling schemes.
This centralized approach would reduce administrative complexity and lower compliance costs.
Consumers may face higher prices if the verification system is too costly.

ChemSec demands toxic-free standards for green product claims

International Chemical Secretariat, 7 Jul 2023

ChemSec demands that green claims reflect actual material content rather than creative bookkeeping. They argue products must be free from hazardous substances to be marketed as green.
Truly non-toxic and sustainably produced materials would gain a clear market advantage.
Firms using accounting tricks or harmful chemicals would be barred from using green labels.

Consultation response

Glass for Europe, 31 Aug 2020

Glass for Europe welcomes the European Commission’s initiative on Environmental product performances’ claims and supports the objective to limit the number of methods to evaluate the environmental impacts of the products. The roadmap highlights the central role of the Product Environmental…

Consultation response

RECHARGE aisbl, 31 Aug 2020

RECHARGE, the industry association for advanced rechargeable and lithium batteries in Europe, welcomes the new legislative proposal for better substantiating green claims. RECHARGE promotes a legislative framework that helps establish meaningful environmental impact indicators based on (a)…

Consultation response

The Food and Beverage Carton Alliance, 14 Aug 2020

REPLY TO THE CONSULTATION ON THE INCEPTION STUDY ON ENVIRONMENTAL PERFORMANCE OF PRODUCTS AND BUSINESSES – SUBSTANTIATING GREEN CLAIMS ACE contribution to the consultation on the inception impact assessment ACE acknowledges the fact that existing claims are not always reliable and in some cases…

Decathlon urges EU to harmonise green claim standards

Decathlon SE, 21 Jul 2023

Decathlon recommends using the Product Environmental Footprint as the primary methodology. They request a 12-month transition period and a stakeholder expert group.
Uniform EU rules would reduce administrative burdens and legal uncertainties for their multinational operations.
Consumers would face a longer delay before seeing verified environmental information on products.

Pharma Deutschland Urges Leaner EU Green Claim Regulations

Pharma Deutschland e.V, 20 Jul 2023

The association calls for a more streamlined regulation accessible to small and medium-sized enterprises. They argue existing national laws and unfair practice directives already effectively prevent misleading green claims.
Maintaining the current system would prevent pharmaceutical companies from facing excessive certification costs.
Consumers risk higher prices and limited information if smaller firms are priced out.

TIC Council demands mandatory third-party verification for green claims

TIC Council, 19 Jul 2023

The group calls for mandatory third-party verification of all green claims by accredited bodies. They want the responsibility for proving claims shifted from consumers to businesses. They also urge clearer definitions for new labels to ensure fair competition.
Mandatory certification would create significant new business opportunities for independent testing and inspection firms.
Dishonest companies using misleading green labels would face higher costs and stricter market exclusion.

Policy Hub Urges Simplified Verification for Textile Green Claims

Policy Hub - Circularity for Apparel and Footwear, 15 Jul 2023

The group calls for a single mandatory method and a simplified verification process. They request better policy coordination and a longer implementation period for businesses.
Streamlined verification and longer timelines would lower administrative costs and reduce legal risks.
Verification bodies could lose revenue if the EU moves away from individual claim-by-claim checks.

Swedish environmentalists urge equal status for national eco-labels

Swedish Society for Nature Conservation, 3 Jul 2023

The organization requests that officially recognized Type I labels receive status equivalent to the EU Flower label. They propose that businesses using these labels be exempt from additional pre-approval for green claims. Existing labeling systems must also be allowed to expand into new product areas.
Equal status would protect their labeling scheme and reduce administrative costs for businesses.
Public authorities lose vital verification tools needed for environmentally responsible procurement.

Consultation response

Policy Hub - Circularity for Apparel and Footwear, 31 Aug 2020

The Policy Hub welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment "Legislative proposal on substantiating green claims". We recommend the European Commission to further explore option 2 “Establish a voluntary EU legal framework enabling companies to make…

Advertising alliance urges recognition of self-regulation in green claims

European Advertising Standards Alliance, 20 Jul 2023

EASA requests clarification on the definition of explicit environmental claims and official recognition for collective advertising self-regulation. They also warn that mandatory pre-approval risks creating backlogs for seasonal goods.
Preserving self-regulation protects the industry from expensive, rigid oversight and prevents administrative delays.
Consumers may face higher prices or reduced information if companies stop voluntary green advertising.

Freshfel Europe demands green claim rights for loose produce

Freshfel Europe - the forum for the European fresh fruits and vegetables chain, 20 Jul 2023

The association supports using Product Environmental Footprint methods to build consumer trust. They demand that fresh produce sold in bulk has equal access to green claims. They also propose extending the compliance correction period to three months for operators.
This approach would protect industry competitiveness by reducing costs and avoiding excessive penalties.
Pre-packaged food producers may lose their marketing advantage if loose products display similar claims.

JBCE calls for B2C focus in Green Claims Directive

Japan Business Council in Europe, 20 Jul 2023

The group requests that the scope be limited to B2C commercial practices. They argue that B2B communications should be explicitly excluded to remain workable for global companies.
Excluding B2B communications reduces compliance costs and operational burdens for global firms.
Business clients lose legal protections against misleading environmental claims from their suppliers.

Expedia Group Urges EU to Allow Sustainability Label Comparisons

Expedia Group, 14 Jul 2023

Expedia requests permission for travel platforms to compare different green labels using a tiered rating system. They suggest using standardized attributes to reflect the ambition level of various schemes.
This allows Expedia to introduce search filters that boost user engagement and bookings.
Strict certification schemes may lose their market advantage to lower-barrier sustainability programs.

ANEC Demands Stricter EU Rules Against Misleading Green Claims

The European Consumer Voice in Standardisation, 27 Jun 2023

The organization requests that legislation specify binding criteria and conditions for environmental claims. It calls for prohibiting green claims on products containing hazardous substances without any postponement. The group also recommends using the European Ecolabel as a primary benchmark.
Consumers would benefit from better protection against greenwashing and more affordable sustainable products.
Companies using misleading environmental labels would face stricter enforcement and mandatory financial penalties.

Consultation response

Jernkontoret, 31 Aug 2020

Jernkontoret supports the establishment of a common and consistent assessment framework for how companies making green claims should assess their product's or organisation's impacts on the environment. Jernkontoret also find it important that this initiative is consistent with other policy…

Consultation response

Freshfel Europe - the forum for the European fresh fruits and vegetables chain, 28 Aug 2020

Consumers are key to a successful and effective green transition. The fresh fruit and vegetable sector endeavours to supply consumers with safe, high quality and fresh products that also meet their environmental, social and sustainability product expectations. The fresh fruit and vegetable sector…

Consultation response

The European Consumer Voice in Standardisation, 28 Aug 2020

The intention set in the Green Deal to tackle misleading green claims is laudable. So too is the recognition that consumers need reliable, comparable and verifiable information on the environmental performance of products and services. We disagree, however, that the substantiation of claims should…

Federchimica urges realistic timelines for EU green claim rules

Federazione Nazionale dell'Industria Chimica italiana, 21 Jul 2023

They suggest a 36-month transition and updated rules for bio-based materials. They also argue against banning green claims for items containing hazardous substances.
Streamlined verification would reduce administrative burdens and protect the industry's market competitiveness.
Environmental organizations lose if the ban on hazardous substance claims is delayed.

Consultation response

Association nationale interprofessionnelle du bétail et des viandes, 28 Aug 2020

Au sein de la filière agricole est l’une des premières, la mesure de l’impact de la production au moyen d’analyse de cycle de vie, prenant en compte l’ensemble des étapes de vie du produit et les étapes qui y sont liées, ainsi que l’ensemble des externalités – positives comme négatives –…

Consultation response

Natural Mineral Waters Europe aisbl, 31 Aug 2020

The European Green Deal with its Circular Economy Action Plan and its Farm to Fork Strategy announced actions to empower consumers to make informed, healthy and sustainable food choices, including an action to examine ways to harmonise voluntary green claims for food products. The European…

WFA urges streamlined verification for EU green marketing claims

World Federation of Advertisers, 20 Jul 2023

The WFA requests a streamlined approval system with a 30-day deadline for verifiers. They also recommend extending the transition period to 30 months to ensure compliance.
Faster verification processes would protect marketing timelines and reduce the cost of compliance.
Consumers lose transparency if companies restrict public access to data to protect commercial secrets.

Consultation response

Construction Products Europe, 31 Aug 2020

Construction Products Europe shares the views of the European Commission about the delivery of accurate and reliable environmental information from products. Our industry worked during the last years to accomplish these goals under a European approach considering that the environmental performance…

German waste industry urges EU to allow national recycling labels

BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V., 20 Jul 2023

BDE requests removing the prohibition on introducing new national or regional environmental labels. They argue Member States should retain national labels to support green public procurement.
Maintaining national labels helps their members win public contracts by highlighting recycled content.
Multinational companies lose a level playing field if diverse national labels are allowed.

European glass industry urges robust green claim standards

European Container Glass Federation, 13 Jul 2023

The federation supports the proposal but highlights gaps in current environmental impact calculations. They advocate for including packaging circularity, infinite recyclability, and human health impacts.
The glass industry benefits from inclusion of recyclability metrics which showcase their products' environmental performance.
Businesses using misleading environmental claims will face stricter verification requirements and potential penalties.

Rainforest Alliance urges clearer verification for environmental labelling schemes

Rainforest Alliance, 23 Jun 2023

Rainforest Alliance requests clearer verification procedures to prevent market distortions and ensure legal certainty. They advocate for flexibility in methodology and support for labels that continuously improve standards.
Uniform verification standards provide legal certainty and protect against market distortions across Europe.
Providers of misleading green labels face tougher rules and higher verification burdens.

Consultation response

Rainforest Alliance, 31 Aug 2020

The Rainforest Alliance welcomes the EU Roadmap on Substantiating Green Claims and recognizes the importance of providing clear and reliable information on sustainability claims. This is an important element of ensuring that consumers, but also buyers and investors, can make more sustainable…

Consultation response

Eurogypsum, 31 Aug 2020

Eurogypsum represents the interests of gypsum product manufacturers and believes in the benefits of gypsum for sustainable and comfortable living and working spaces and promotes its contribution to Europe’s built environment. We strongly support the objectives of the Green Deal and are committed to…

Consultation response

European Container Glass Federation, 28 Aug 2020

The European Container Glass manufacturing (FEVE) industry welcomes the European Commission’s ambition to ensure that consumers and businesses have access to reliable, comparable, and verifiable information to make sustainable decisions. FEVE has been an active member of the Product Environmental…

Consultation response

LightingEurope, 31 Aug 2020

LightingEurope takes this public consultation as an opportunity to share some preliminary remarks and questions for the consideration of the European Commission ahead of the drafting of the proposal for a Regulation. LightingEurope makes general remarks on the following issues in its detailed…

Consultation response

Essity Aktiebolag (publ), 19 Jul 2023

Essity aspires to be the undisputed global leader in hygiene and health. With headquarters in Stockholm, Sweden, sales are conducted in approximately 150 countries under the leading global brands TENA and Tork, and under other strong brands, such as Actimove, JOBST, Knix, Leukoplast, Libero,…

Agroecology Europe demands holistic biodiversity metrics for green claims

Agroecology Europe, 13 Jul 2023

Agroecology Europe calls for rules to integrate positive externalities like biodiversity and animal welfare. They recommend adopting the OASIS indicator system and supporting Participatory Guarantee Systems to empower communities.
These changes would facilitate the scaling up of agroecology practices across the European Union.
Consumers lose because current methods provide an incomplete picture of environmental credentials.

European Bioplastics urges updated footprint rules to benefit bio-based materials

European Bioplastics, 21 Jul 2023

The association calls for the footprint method to be revised to recognize the benefits of biomass. They also seek flexibility regarding primary data requirements to protect trade secrets and innovation.
This allows the industry to highlight its environmental benefits while protecting sensitive intellectual property.
Fossil fuel companies would lose their comparative advantage if biomass receives specific carbon removal credits.

Czech Chamber of Commerce urges practical green claim rules

Hospodářská komora České republiky, 21 Jul 2023

The Chamber suggests excluding claims covered by existing rules and removing competitor comparison requirements. They argue that disclosing competitor data is often impossible and risky under competition laws. They also recommend extending the application period to thirty months.
This would reduce administrative burdens and protect businesses from sharing sensitive commercial secrets.
Consumers would wait longer for protections and lose access to third-party verified data.

Consultation response

EDANA AISBL, 20 Jul 2023

EDANA, the voice of the nonwovens and related industries, represents the entire nonwovens value chain. This includes manufacturers of the materials that go into many different product applications such as absorbent hygiene products, automobiles, agriculture, protective clothing, and medical…

Consultation response

Visita, 29 Jun 2023

Visitas position on Proposal for a Directive on green claims: - Visita questions whether the problem the proposed regulation wants to solve cannot be handled with existing, and other upcoming, legislation. - Visita believes that so-called "greenwashing" should be counteracted in order to, among…

Consultation response

European Bioplastics, 31 Aug 2020

Position of European Bioplastics Inception Impact Assessment on legislative proposal substantiating green claims Introduction – the role of bioplastics: The members of European Bioplastics are active contributors, investors and innovators involved in the transformation of the packaging…

Consultation response

EDANA AISBL, 14 Aug 2020

EDANA developed a Sustainability Vision, giving clear insight into the priority topics on sustainability for our industry. Building Trust, through transparency to consumers and other stakeholders is an essential pillar of this Vision. When making green claims, this transparency allows for reliable…

Polish Cosmetics Union Warns Green Claims Rules Risk Market Clog

Polski Związek Przemysłu Kosmetycznego, 21 Jul 2023

The Union requests a 36-month implementation period and a clear definition of scientific evidence. They propose allowing partial self-verification to prevent administrative bottlenecks and high compliance costs.
This would reduce the financial burden and prevent delays in product launches.
NGOs and rating apps would face stricter regulations if the Union's transparency demands are adopted.

Consultation response

World Travel and Tourism Council, 20 Jul 2023

With appreciation for the opportunity to provide feedback on the proposed directive on substantiating claims in regard to environmental performance of products & businesses, please find attached the World Travel & Tourism Council's contribution to this public consultation.

Consultation response

Polski Związek Przemysłu Kosmetycznego, 31 Aug 2020

The cosmetics industry in Poland shares the European Commission views with regards to the impact of climate change by 2050. The Polish Union of the Cosmetics Industry welcomes the European Commission’s European Green Deal announcement and its goals. The Polish Union of the Cosmetics Industry…

Consultation response

European Panel Federation, 14 Aug 2020

The European Panel Federation (EPF), welcomes the Inception Impact Assessment on environmental performance of products and businesses. The wood-based panels industry produces sustainably sourced circular products with a low environmental footprint. We believe that misleading claims on product and…

German confectionery industry calls for uniform green claim rules

Bundesverband der Deutschen Süßwarenindustrie, 19 Jul 2023

The BDSI demands uniform EU-wide requirements and reliable data for environmental claims. They prefer ex-post verification over ex-ante systems to avoid delays and greenhushing. The industry calls for measures to reduce the financial burden on small companies.
Harmonized standards would prevent market fragmentation and reduce the risk of verification shopping.
Small and medium businesses lose the ability to affordably communicate their sustainability efforts.

German advertising federation warns EU green claims rules stifle innovation

Zentralverband der deutschen Werbewirtschaft ZAW e.V., 19 Jul 2023

ZAW warns that mandatory pre-approval of environmental claims creates excessive financial and bureaucratic burdens. They argue that these checks will lead to 'Green Hushing,' where companies stop communicating legitimate improvements to avoid legal risks. They also request longer implementation periods to prevent the destruction of existing product packaging.
Exempting companies from pre-approval would reduce administrative costs and protect their marketing agility.
Smaller firms and consumers lose if environmental marketing becomes exclusive to wealthy corporations.

EACA urges clarity on EU rules for green advertising

European Association of Communications Agencies, 13 Jul 2023

EACA requests a clearer definition of environmental claims to include visuals and audio. They seek specific guidance for different advertising mediums and propose that EU labels exempt companies from case-by-case verification.
This would reduce compliance costs by allowing advertisers to avoid case-by-case verification.
Consumers may be misled if broad environmental campaigns disguise a product's actual impact.

Consultation response

Minderoo Foundation Limited ATF The Minderoo Foundation Trust, 21 Jul 2023

Minderoo welcomes the publication of the proposal for a Green Claims Directive as a positive step towards promoting transparent and accurate environmental claims in the European market. Indeed, Minderoo supports the general objective of this initiative, which is to unlock opportunities for the…

Ventilation industry supports green claims rules but rejects mandatory verification

European Ventilation Industry Association, 20 Jul 2023

EVIA supports a harmonized EU framework to prevent market fragmentation caused by diverging national initiatives. They also argue that mandatory third-party verification is disproportionate and seek self-declaration options.
Avoiding mandatory third-party audits would reduce compliance costs for manufacturers.
External auditors lose guaranteed revenue if the EU allows companies to self-certify.

Novamont demands scientific rigor for EU green claims

Novamont SpA, 19 Jul 2023

The company supports strict criteria based on scientific evidence and life-cycle assessments. They argue current footprint methods are insufficient because they fail to account for microplastics. They suggest claims for bio-based products must be based on measurable biogenic content.
Harmonized rules would reduce regulatory burdens for Novamont’s international bioplastics trade.
Firms using vague mass balance labels would lose the ability to claim sustainability.

Consultation response

Oatly AB, 21 Jul 2023

Oatly welcomes the opportunity to contribute to the public consultation on the EU Green Claims Directive. Oatly supports the overall objective to make companies responsible for substantiating claims about the environmental footprint of their products. We recognize the need to establish a regulatory…

Consultation response

Marine Stewardship Council, 28 Jun 2023

See attached file

Consultation response

Oatly AB, 31 Aug 2020

Oatly was founded back in the 1990s and is based on Swedish research from Lund University. The company’s patented enzyme technology copies nature’s own process and turns fiber rich oats into nutritional liquid food that is perfectly designed for humans. Oatly actively supports the overall…

Consultation response

European Confederation of Woodworking Industries, 31 Aug 2020

CEI-Bois fully supports the ambition of the EU to reduce significantly the environmental footprint of products consumed in the Union and to attain the carbon neutrality target by 2050. CEI-Bois also agrees with the aim of moving towards a more harmonised approach for providing reliable product…

Consultation response

European Council of the Paint, Printing Ink and Artists' Colours Industry, 31 Aug 2020

CEPE contribution on the roadmap for a Legislative proposal on substantiating green claims CEPE welcomes the opportunity to comment on the European Commission's roadmap for a legislative proposal on substantiating green claims. The paint, printing ink and artists' colours manufacturers are…

Consultation response

Stockholm Exergi, 19 Jul 2023

Stockholm Exergi has submitted a response to the invitation to provide comments on the draft EU Green Claims Directive. The full response is provided as a public PDF-document, also available at https://beccs.se/about-beccs-stockholm/documents/. In the response, we propose Ten Principles for…

German paint and ink industry urges lower green claim costs

Verband der deutschen Lack- und Druckfarbenindustrie e. V., 18 Jul 2023

The association demands replacing mandatory verification with internal documentation. They want longer implementation deadlines and reliance on existing chemical regulations.
This would reduce administrative costs and prevent a competitive disadvantage for smaller companies.
External auditors lose revenue while consumers receive information with less independent oversight.

Consultation response

Logitech, 28 Jun 2023

The Commissions initiative to reduce greenwashing by mandating the substantiation of voluntary green claims (the Green Claims Directive) is a fundamental piece to empower consumers by ensuring that the products environmental information they receive is accurate and transparent. As a leading company…

Consultation response

ISEAL Alliance, 21 Jun 2023

We would like to reiterate our longstanding support for the Commissions efforts to introduce more stringent regulations to tackle greenwashing, enabling consumers to make informed purchasing decisions, and we welcome this opportunity to submit our feedback (in attachment).

Consultation response

Bundesarchitektenkammer e.V., 31 Aug 2020

Allgemeine Anmerkungen: Die BAK begrüßt die mit der Green Claims Initiative verbundene Absicht: - die Einführung eines EU-weit einheitlichen Rahmens für die Bewertung der Umweltleistung von Produkten und Unternehmen zu prüfen. - die Nachhaltigkeit von Waren, Dienstleistungen und Geschäftsmodellen…

Consultation response

Fédération Nationale des Activités de Dépollution et de l'Environnement, 31 Aug 2020

FNADE, the French association of environmental services companies, welcomes the commission's new initiative to improve product performance as well as the information on this performance and thus help consumers make a reliable choice. Calculating the environmental performance of a product and its…

Consultation response

Verband der deutschen Lack- und Druckfarbenindustrie e. V., 31 Aug 2020

Bitte beachten Sie die angehängte Datei.

Consultation response

Fur Europe, 27 Aug 2020

Fur Europe welcomes the legislative proposal on substantiating green claims and supports in principle the use of product environmental footprint. But some issues need to be considered to make the PEF scheme truly functional and inclusive, which is a prerequisite to ensure the success of the…

Consultation response

Health Care Without Harm Europe, 27 Aug 2020

Health Care Without Harm (HCWH) Europe welcomes and supports the European Commission introducing a standard methodology for assessing products’ environmental impacts and requiring companies to substantiate environmental claims. This initiative is relevant for our members who are in need of a strong…

Consultation response

Textile Exchange, 19 Jul 2023

Textile Exchange is a global non-profit driving positive action on climate change across the fashion, textile and apparel industry. We guide and support a growing community of brands, retailers, manufacturers, and farmers towards more purposeful production right from the start of the supply chain.…

Consultation response

Steel for Packaging Europe, 31 Aug 2020

APEAL welcomes the EC public consultation initiative on substantiating green claims. We support the EC establishing legal framework that provides a level playing field, limits the proliferation of methods to measure and assess environmental impacts, limits the proliferation of labels and claims…

Consultation response

Assoziation ökologischer Lebensmittelherstellerinnen und -hersteller e.V., 31 Aug 2020

Wir begrüßen das Vorgehen der EU im Bereich der Angaben zu Nachhaltigkeit und ökologischem Fußabdruck für Unternehmen eine einheitliche Regelung zu finden. Wenn Verbraucherinnen und Verbraucher zum nachhaltigeren Produkt greifen sollen, so muss auch sichergestellt sein, dass die dafür gegebenen…

Consultation response

European Organisation of the Sawmill industry, 31 Aug 2020

The European Sawmill Organisation of the Sawmill Industry welcomes the new initiative of the EU Commission to substantiate green claims. Keeping track of consumption footprints globally, which requires good supply chain data and accounting, is increasingly recognised as critical to an inclusive…

Spanish steel industry urges strict verification of environmental claims

Unión de Empresas Siderúrgicas, 21 Jul 2023

UNESID calls for mandatory third-party verification of environmental claims to ensure credibility. All products from non-EU countries must also demonstrate their environmental performance to maintain a level playing field. The directive should allow claims for products containing hazardous substances if they pose no risk.
This would protect high-standard European producers from unfair competition and distinguish them from greenwashers.
Non-EU exporters and EU states with lower verification thresholds would lose their competitive advantage.

Consultation response

FRUCOM - European Federation of the Trade in Dried Fruit, Edible Nuts, Processed Fruit & Vegetables, Processed Fishery Products, Spices and Honey, 20 Jul 2023

Please find attached FRUCOM's full position on the Green Claims Directive proposal. FRUCOM represents European Union importers, and growers, processors, and traders, of edible nuts, dried and processed fruit and vegetables, and processed fish and seafood products. - FRUCOM welcomes the publication…

Consultation response

Plant-Based Foods Europe, 20 Jul 2023

ENSA, the European Plant-based Foods Association, representing the interests of plant-based food manufacturers in Europe, welcomes the Commissions Directive proposal on the substantiation and communication of explicit environmental claims (Green Claims). The Green Claims Directive will contribute,…

Consultation response

International Wool Textile Organisation, 31 Aug 2020

The International Wool Textile Organisation (IWTO) represents the collective interests of the global wool industry. We are based in Brussels and our goal is to ensure a sustainable future for wool through scientific research, wool textile education and knowledge sharing. Our members come from all…

Consultation response

Competere - Policies for sustainable development, 28 Aug 2020

Competere is a research center based in Rome and Brussels that elaborates ideas to improve our lives, producing and promoting policies and business models to foster innovation and develop better human technology design interaction. Competere is a creative platform where citizens come together to…

Consultation response

European Carton Makers Association, 21 Jul 2023

The European Carton Makers Association (ECMA) welcomes the Commissions proposal for a Directive for the substantiation and communication of explicit environmental claims. ECMA brings together folding carton converters, cartonboard mills, national associations, and suppliers to the folding carton…

Consultation response

Groupe Avril, 20 Jul 2023

Veuillez trouver ci-joint la contribution écrite du Groupe Avril à la consultation publique sur la proposition de Directive relative aux allégations environnementales explicites.

Consultation response

Impossible Foods, 20 Jul 2023

Please find attached Impossible Foods' feedback to the Green claims directive.

Consultation response

Roundtable on Sustainable Palm Oil, 12 Jul 2023

RSPO Feedback to the European Commission on the proposed directive on substantiation and communication of explicit environmental claims (Green Claims Directive). The RSPO welcomes the proposal for this directive as an important step to tackle misleading claims and greenwashing and as an opportunity…

Consultation response

Confédération des Associations Nationales de Tanneurs et Mégissiers de la Communauté Européenne, 31 Aug 2020

COTANCE represents the leather industry in Europe. European tanners supply leather to the most demanding value customers in the luxury, fashion, automotive and home decoration sectors. Leather products play an essential role in consumers’ every-day lives. The European Tanning Industry is composed…

Consultation response

Syctom Agence métropolitaine des déchets ménagers, 26 Aug 2020

Les fabricants de produits manufacturés ne communiquent pas systématiquement toutes les données concernant les matériaux et/ou substances qu'ils utilisent. Au-delà de la nécessaire information des consommateurs sur le potentiel réel de recyclabilité et sur la composition des produits qu'ils…

Consultation response

European Carton Makers Association, 17 Aug 2020

The European Carton Makers Association support the European Green Deal and the aspiration to move from a part linear to fully circular economy. We fully support this ‘Substantiating Claims’ initiative as a route for reducing the quantity of misleading claims – so called ‘greenwash’ - and providing…

Finnish Bioenergy Association Calls for Less Bureaucracy in Green Claims

Bioenergia ry - Bioenergy Association of Finland, 19 Jul 2023

The group wants to minimize bureaucracy and align rules with the RED3 Directive. They advocate for simple labels to prevent consumers from ignoring complex info.
This would reduce administrative costs and protect international competitiveness for bioenergy firms.
Regulatory bodies seeking granular transparency might lose access to comprehensive data.

Consultation response

Beryllium Science & Technology Association, 7 Jun 2023

Please see attached the position paper of The Beryllium Science and Technology Association (BeST).

Consultation response

Organic Processing and Trade Association Europe e.V., 3 Apr 2023

OPTA Europe (www.opta-eu.org) is the membership organization representing the interest of EU organic processing and trade companies. Its membership encompasses 11 EU Member States plus North America and Switzerland. Taken together, the companies represented by OPTA Europe account for a large share…

Consultation response

CITEO, 31 Aug 2020

Citeo strongly welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission to propose a new legislation on substantiating green claims, aiming at enhancing environmental performance of products and businesses. Building on experience in the sector of…

Consultation response

European Committee of Heating, Ventilation, Air Conditioning and Refrigeration Manufacturers, 31 Aug 2020

Eurovent appreciates the recognition by the Commission of the proliferation of green claims and the related measurement and assessment methods. National legislation regarding green claims exists, supported in cases by the fact that some Member States recognize specific voluntary labels. This…

Consultation response

Advertising Information Group, 19 Jul 2023

AIG response to the EU Commissions call for evidence on the Green Claims Directive SUMMARY 1. The Advertising Information Group (AIG) (transparency number: 11220347045-31) welcomes the opportunity to respond to the European Commissions call for evidence on the Directive on substantiation and…

Spanish chemical industry seeks flexibility on EU green claims

FEDERACIÓN EMPRESARIAL DE LA INDUSTRIA QUÍMICA ESPAÑOLA, 18 Jul 2023

Feique argues for allowing green claims for products with hazardous substances if safe. They recommend extending the implementation period and updating methodology for the environmental footprint of products.
This would protect the sector's market access and reduce administrative and legal costs.
Public authorities would lose a powerful deterrent against large-scale greenwashing by major companies.

Consultation response

Round Table on Responsible Soy Association (RTRS), 17 Jul 2023

The Round Table on Responsible Soy Association (RTRS) welcomes the opportunity to provide feedback on the European Commissions proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive). As a multi-stakeholder organisation with the mission…

Consultation response

Bureau International du Béton Manufacturé, 28 Aug 2020

BIBM, the federation of the European Precast Concrete Industry, fully supports the position of Construction Products Europe on this topic. Our industry actively contributed in the past years to the establishment of a framework for the delivery of accurate and reliable information about…

Consultation response

Industrial Minerals Association - Europe, 14 Aug 2020

Inception impact assessment: Legislative proposal on substantiating green claims (14 August 2020) The Industrial Minerals Association, IMA-Europe, and its members welcome the opportunity to comment on the Commission Roadmap on Substantiating Green Claims. Minerals' unique properties provide…

Consultation response

Confédération Européenne de l’Industrie de la Chaussure, 21 Jul 2023

The European Footwear Confederation (CEC) welcomes the adoption of the proposal for an EU Directive on Substantiating Green Claims and the consequent implementation of a science-based approach, which represents a step forward towards harmonisation in the EU single market while allowing certain…

European Safety Federation urges simple green claim rules for SMEs

European Safety Federation, 21 Jul 2023

ESF stresses the importance of harmonizing environmental measurement rules across the EU and globally. They request that authorities provide practical tools and keep systems simple for small businesses. Finally, they advocate for enforcement to ensure a level playing field.
Keeping rules simple prevents small businesses from being disadvantaged compared to large corporations.
Companies from third countries would lose their ability to sell products without verification.

Consultation response

Puro.earth, 21 Jul 2023

Hello, Please find attached the feedback from Puro.earth, a carbon removal crediting programme and through the Puro Standard we certify durable removal of CO2 from the atmosphere. We issue CO2 Removal Certificates, CORCs, per tonne of CO2 removed and durably stored for at least 100 years. CORCs are…

Consultation response

TomatoEurope Processors Association, 21 Jul 2023

Please find the position of TomatoEurope enclosed.

Consultation response

Citeo, 21 Jul 2023

Citeo is the French company in charge of the Extended Producer Responsibility (EPR) for household packaging and graphic papers. Citeo welcomes the EC proposal to provide harmonized rules on substantiation, communication, verification of voluntary green claims at European level. Since one of its…

Consultation response

VF Europe, 21 Jul 2023

VF Corporation welcomes the publication of the Commissions proposal for a Directive on substantiation and communication of explicit environmental claims (a.k.a.: Green Claims Directive) and would like to emphasize few concerns and recommendations. 1. Clarification on rules is necessary. The…

Consultation response

K+S Aktiengesellschaft, 20 Jul 2023

As K+S, we see ourselves as pioneers in environmentally friendly and sustainable mining. Our constant efforts to set global standards resulted in several developments of new techniques and processes to better protect the environment and reduce our products footprints and these efforts are on-going.…

Consultation response

UL GmbH, 14 Jul 2023

UL Solutions welcomes the possibility to comment on the European Commissions legislative proposal on environmental claims with the aim to require companies to substantiate claims they make about the environmental footprint of their products/services by using standard methods for quantifying them. A…

Consultation response

Topsector Logistiek, 30 Aug 2020

Topsector Logistics The European Green Deal has more forcefully put logistics emissions on the policy agenda of the European Commission. As Topsector Logistics in The Netherlands, we applaud this. As we will explain below, we have been active in reducing transport and logistics emissions in The…

Consultation response

Health and Environment Justice Support, 21 Jul 2023

This is a submission on behalf of the following members of the NGO Coalition Exit Plastik: a tip: tap e.V., Bund für Umwelt und Naturschutz Deutschland e.V., Forum Umwelt und Entwicklung, Heinrich-Böll-Stiftung, HEJSupport e.V., Küste gegen Plastik e.V., Women Engage for a Common Future e.V.…

Chemical distributors seek longer transition for green claim rules

European Association of Chemical Distributors, 21 Jul 2023

Fecc requests extending the implementation period to 30 months to avoid administrative delays. They argue that microenterprises should adhere to the same substantiation standards as larger companies. The group also opposes banning green claims for safe products containing hazardous substances.
This would reduce administrative pressure and maintain market access for many chemical products.
Microenterprises would lose the proposed lighter regulatory burden intended to prevent disproportionate impacts.

Consultation response

European Margarine Association, 20 Jul 2023

IMACE would like to thank the Commission to give us the possibility to provide feedback on the legislative proposal on substantiating green claims. We expressed several concerns and suggestions in the document in annex to further improve the current proposal, making it as effective as possible…

Consultation response

ASSUC- European Association of Sugar Traders, 20 Jul 2023

ASSUC is the voice of European sugar traders, representing over sixty sugar trading companies across Europe through its membership. We welcome the publication of the Proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive), on 22 March…

Consultation response

CIRFS: European Man-made Fibres Association, 20 Jul 2023

CIRFS is the association for Europes 12 billion man-made fibres industry, representing the industry to the European authorities and providing the industry with a wide range of services. Its members cover about 75% of European man-made fibres output. It provides for around 20,000 jobs in ca. 250…

EFIC Urges Regulatory Alignment for Green Claims

European Furniture Industries Confederation, 20 Jul 2023

EFIC recommends aligning definitions across EU legislation to ensure a level playing field. They request clearer guidance on scientific evidence and third-party verifier liability. The industry also seeks guaranteed mutual recognition of certificates by national authorities.
Decreasing legal uncertainties would help companies avoid the risk of not communicating environmental results.
Establishing new private schemes would be prohibited unless they provide specific added value.

Consultation response

COSMED, 19 Jul 2023

First of all, COSMED supports overall objectives of the Green Claim Directive to protect consumers and companies against greenwashing. However, we alert on the need to maintain a rationale balance to avoid disproportionate burden on companies and especially on SMEs and to leave the possibility for…

Consultation response

OsloMet – Oslo Metropolitan University, 17 Jul 2023

Consumption Research Norway (SIFO) welcomes the EC's efforts to halt greenwashing and the opportunity to provide feedback on the proposal. SIFO is a non-profit, transdisciplinary research institute at the Oslo Metropolitan University. Our research aims to understand the role of consumption and…

Consultation response

United Company RUSAL, 31 Aug 2020

RUSAL’s input to the European Commission’s public consultation Environmental performance of products & businesses – substantiating claims 1. Expression of support to the EC’s work on the societal ambition to address climate urgency: A common approach to declaring environmental performance of…

Consultation response

European Furniture Industries Confederation, 31 Aug 2020

The European furniture industries embrace EU circularity objectives and are already transitioning to and promoting circular business models based on reuse, repair, refurbishment and remanufacturing of products. A true circular economy can only be achieved through collaboration and requires the…

Consultation response

Instituut voor Landbouw en Visserijonderzoek, 31 Aug 2020

Dear organisers, I have read the note with much interest and I have some additional questions and suggestions in the attached document. Thank you very much for considering this feedback. Best regards, Veerle Van linden

Consultation response

Flustix GmbH, 27 Aug 2020

In the field of plastic reduction and plastics sustainability, the Flustix initiative already provides, what the EU Inception Impact Assessment strives for. The Flustix initiative is dedicated to plastic reduction and the avoidance of plastic waste by recycling to support the responsible use of…

Consultation response

Clean Smoke Coalition, 21 Aug 2020

Please find the feedback of the CleanSmoke Coalition in the attached document.

Consultation response

Federation of The European Cookware, Cutlery and Housewares Industries, 21 Jul 2023

The Federation of European Manufacturers of Cookware and Cutlery (FEC) and its members fully support the objectives of Green Claim Directive. Too often product labels give vague, misleading, or unfounded information to the customers. The Federation of European Manufacturers of Cookware and Cutlery…

Consultation response

Bundesverband Medizintechnologie e.V., 21 Jul 2023

Sehr geehrte Damen und Herren, als Anlage teilen wir die BVMed-Stellungnahme zu Green Claims mit der Bitte um Berücksichtigung. Für Rückfragen stehen wir gerne zur Verfügung. Herzliche Grüße Clara Allonge

Consultation response

Zentrale zur Bekämpfung unlauteren Wettbewerbs Frankfurt am Main e.V., 20 Jul 2023

Die Zentrale zur Bekämpfung unlauteren Wettbewerbs Frankfurt am Main (kurz: Wettbewerbszentrale) bedankt sich für die Gelegenheit zur Stellungnahme zu der geplanten Green Claims Richtlinie. Sie begrüßt vollumfänglich alle drei Aspekte der Zielsetzungen der EU-Kommission - insbesondere auch,…

Consultation response

Industrieverband Klebstoffe e.V., 20 Jul 2023

Preventing greenwashing is crucial to maintain consumer trust in products and claims. It is important that environmental claims adhere to established standards to ensure fair competition and market orientation. Therefore, the German Adhesives Association (IVK) supports the European Commission's…

Consultation response

ETSA (EUROPEAN TEXTILE SERVICES ASSOCIATION), 20 Jul 2023

ETSA the European Textile Service Association, a business association with membership consisting of laundries, detergents, machineries and national associations would like to express support and outline concerns regarding the EU Commission Proposed Directive on "Green Claims." While we appreciate…

Food industry group urges clarity on environmental footprint rules

Primary Food Processors, 29 Jun 2023

The group urges the Commission to confirm which food products require specific environmental footprint rules. They question prioritizing food claims now to avoid risks of switching between different regulations. Finally, they advocate for harmonized recognition of labeling schemes across the EU.
Harmonized rules would reduce administrative burdens and prevent companies from adapting to multiple regulations.
The broader green transition suffers because the directive primarily benefits a niche of leading companies.

Consultation response

Flower Auctions International (Vereniging van Bloemenveilingen), 31 Aug 2020

The Association of Dutch Flower Auctions (VBN) represents cooperatives in the ornamental chain with over 4000 member companies, producers of ornamental products, and 2500 associated buyers/wholesalers. Yearly 12 billion products (flowers and plants) are being traded at the auction market places.…

Consultation response

Primary Food Processors, 31 Aug 2020

PFP, the association representing European primary food processors welcomes the intention of the European Commission to improve the regulatory framework for the use of green claims. In this regard, we would like to highlight the following points: 1) Product Environmental Footprint Category Rules…

Consultation response

Institut Bauen und Umwelt e.V., 31 Aug 2020

Institut Bauen und Umwelt e.V. (IBU) agrees that all environmental claims must be based on transparent, comparable and trustworthy information. Particularly in the construction sector, where individual products can only be evaluated in the context of the complete building, the consistency and…

Consultation response

Verein für Konsumenteninformation, 31 Aug 2020

Please find enclosed the joint feedback from two competent bodies for national ecolabels, SMK (Stichting Milieukeur) and VKI - Austrian Consumer Association (Austrian Ecolabel) as well as the Austrian Position Paper on "Handling Green Claims". In our feedback we express our concerns regarding a…

Consultation response

European Expanded Clay Association, 31 Aug 2020

The European Expanded Clay Association, EXCA (www.exca.eu) and its members welcome the opportunity to comment on the Commission Roadmap on Substantiating Green Claims. Expanded clay is a well-proven, high quality, efficient and durable lightweight aggregate suitable for a wide range of…

Consultation response

Deutsche Bauchemie e.V., 28 Aug 2020

Deutsche Bauchemie fully supports the aim to provide consumers and businesses with reliable, comparable and verifiable information to make sustainable decisions. As a sector, we firmly condemn any misleading claims and “greenwashing”. As a basis for achieving these goals, it is useful and necessary…

Consultation response

European Parquet Federation, 28 Aug 2020

FEP – the European Federation of the Parquet industry – is welcoming the EC Inception Impact Assessment on the “Legislative proposal on substantiating green claims” initiative. This initiative is clearly supporting the recent EU Green Deal, the New Circular Economy Action Plan, and the Renovation…

Consultation response

European Flour Millers, 25 Aug 2020

European Flour Millers welcome this Commission's initiative, as it aims to increase trustworthiness of environmental claims. The EU pilot phase on Product Environmental Footprint (PEF) was designed as a bottom-up process where industry sectors could apply for voluntary participation. So far,…

Consultation response

Bio-based and Biodegradable Industries Association, 4 Aug 2020

BBIA represents producers of compostable packaging materials in the UK. We strongly support the Option 3 to establish a binding legal EU wide framework for environmental claims. We are sick of companies announcing their packaging to be "biodegradable" without having supporting scientific evidence,…

Consultation response

FEDIAF EuropeanPetFood aisbl, 21 Jul 2023

FEDIAF Position Paper on Green Claims Directive, July 2023 FEDIAF, the European Pet Food Association, welcomes the European Commissions proposal for the Green Claims Directive. Throughout the Commissions consultation process, FEDIAF has sought to be a constructive partner. As such, FEDIAF…

Consultation response

Der Verband für Medien- und Veranstaltungstechnik, 21 Jul 2023

The German Entertainment Technology Association strongly supports European benchmarks and therefore a level playing field in regard to claims of sustainable products, services and organizations. We would greatly appreciate working with the EU Commission on creating valid PEFCR and OEFSR for our…

Consultation response

Asociación de Empresas de Detergentes y de Productos de Limpieza, Mantenimiento y Afines, 21 Jul 2023

ADELMA is a business organization that joins manufacturers and distributors of detergents and cleaning and maintenance products, pesticides and biocides, both those used at household and institutional, professional and industrial level. Within our Association there are companies dedicated to the…

Consultation response

FIPEC, 20 Jul 2023

Madame, Monsieur, Vous trouverez ci-jointe la contribution de la FIPEC à la consultation publique portant sur le projet de directive relative à la justification et à la communication des allégations environnementales explicites. Sincères salutations,

Consultation response

Better Cotton Initiative, 20 Jul 2023

Better Cotton welcomes the proposal for a directive on substantiation and communication of explicit environmental claims (Green Claims Directive), to ensure that consumers are protected and empowering them to contribute actively to the green transition by tackling false environmental claims. There…

Consultation response

Foundation for Environmental Education, 20 Jul 2023

The Foundation for Environmental Education (FEE), is a leading CSO in Education for Sustainable Development and Sustainable Tourism, representing over 100 member organisations in 80 countries. We have members in all EU member states except Hungary, as well as in most EU candidate countries. Thus,…

Consultation response

ecoinvent Association, 19 Jul 2023

ecoinvent welcomes the proposal from the Commission for a directive on the substantiation and communication of explicit environmental claims (Green Claims Directive). Addressing the issue of greenwashing and deceptive marketing practices is crucial in assisting both customers and companies to play…

Consultation response

Handelsverband, 19 Jul 2023

Der Handelsverband unterstützt grundsätzlich das hehre Ziel der Richtlinie, in der aktuellen Form schafft der Vorschlag aber einen administrativen Mehraufwand und Rechtsunsicherheit für Unternehmen, ohne ein Problem effektiv zu lösen. Im Anhang finden Sie unsere detaillierte Position.

Consultation response

The International Natural and Organic Cosmetic Association, 16 Jul 2023

NATRUE AISBL is an international non-profit association representing pioneering producers from global natural and organic cosmetics sector, and welcomes the opportunity to provide input to the publication of the EU Commissions proposal of a Green Claims Directive (GCD). The objectives to tackle…

Consultation response

Puutuoteteollisuus ry, 7 Jul 2023

Proposal for Green Claims Directive On behalf of the producers of wood-based products we would like to give following feedback: At this stage the proposal looks complicated and regulations intertwined on with another. At the moment the Construction Products Regulation is under revision and the ESPR…

Consultation response

Australian Wool Innovation Ltd, 26 May 2023

The Green Claims Directive represents a promising and critical step against the propagation of unregulated claims and labels. A certification framework and verification mechanism will be effective in providing legal clarity and ensuring fairness when it comes to companies marketing activities…

Consultation response

Växtbaserat Sverige, 31 Aug 2020

This feedback is submitted on behalf of the Swedish industry organisation Plant-food Sweden (Växtbaserat Sverige), which is an industry organization representing food producing companies of plant-based food and drinks. The members of Plant-based Sweden are Fazer, Findus, Food for Progress,…

Consultation response

UNION FLEURS - The International Flower Trade Association, 31 Aug 2020

Union Fleurs is the international umbrella organisation for national associations and companies active in the floricultural trade (cut flowers and potted plants) and represents the interests of operators involved in the trade of these products (importers, exporters, wholesalers and distributors) in…

Consultation response

Federation of European Rigid Polyurethane Foam Associations, 31 Aug 2020

PU Europe, representing the European polyurethane insulation industry, has been following the debate on the Single Market for Green Products for many years and welcomes the opportunity to provide input to the European Commission’s Inception Impact Assessment on a legislative proposal on…

Consultation response

Związek Pracodawców Polska Miedź (The Polish Copper Employers' Association), 31 Aug 2020

Lubin, 31 sierpnia 2020 r. ZPPM / 89 / VII / 2020 European Commission Directorate-General for Environment Unit B1 –Sustainable Production, Products and Consumption 1049 Brussels Belgium Public Consultation – Roadmap – Proposal for a regulation: Ref. Ares(2020)3820384: Legislative proposal on…

Consultation response

The Norwegian Seafood Federation, 31 Aug 2020

The Norwegian Seafood Federation welcomes the Commission's initiative on legislative proposal on substantiating green claims. The Norwegian Seafood Federation (NSA) represents the interests of approximately 680 member companies. Our member companies represent the entire supply chain from sea to…

Consultation response

European Federation for Construction Chemicals, 31 Aug 2020

Please see included file

Consultation response

European Fat Processors Renderers Association, 31 Aug 2020

EFPRA, the European Fat Processors and Renderers Association, appreciates the initiative of the EU set in the Green Deal. And we agree that results of environmental foot print calculations should be comparable to give consumer a better overview. In the 2013-2018 consultation a lot of time, money…

Consultation response

International Thin-Film Solar Industry Association, 28 Aug 2020

Pvthin – the international trade body promoting thin-film photovoltaic (PV) technologies - welcomes the European Commission’s initiative on ‘green claims’ and the overarching objective to harmonise these claims in the EU. The thin-film PV industry would support this approach as a continuation of…

Consultation response

EuroWindoor AISBL, 27 Aug 2020

EuroWindoor support to have one harmonized European method of making green claims. For construction products the CEN/TC350 suite of standards (EN 15804, EN 15978 etc.), aligned to PEF methodology, should be preferred with the arguments that: 1) the systems of EPDs for construction products and…

Consultation response

Associação Portuguesa para a Defesa do Consumidor, 26 Aug 2020

Green claims are an issue that must be addressed by the UE with priority, many traders are taking advantage of consumers’ growing interest in environmental matters because of the climate crisis and are using green claims to differentiate themselves from their competitors. Many claims are not or…

Consultation response

Club EMAS - Associació d'organitzacions registrades EMAS a Catalunya, 25 Aug 2020

We share the opinion that consumers and organisations need reliable and verifiable information to make sustainable decisions, and this is essential in the context of the circular economy, although it’s not clear how this initiative will be aligned with the existing EU Eco-management and Audit…

Consultation response

Geschäftsstelle des Umweltgutachterausschusses, 24 Aug 2020

Der Umweltgutachterausschuss (UGA) unterstützt die Bemühungen der Kommission ausdrücklich, eine ehrgeizige Strategie vorzulegen, die mit Blick auf die 2050 zu erreichenden Klimaziele konkrete Fahrpläne für die Zielerreichung vorsieht. Der UGA lehnt jedoch alle genannten Optionen ab, da er der…

Consultation response

restado UG (haftungsbeschränkt), 5 Aug 2020

We are supporting option 3 to harmonize all the labels in a common standard on EU level. This is especially true for the construction sector where a lot of false claims of the environmental impact of the products are made.

Consultation response

Association européenne de producteurs de mollusques, 31 Jul 2020

Les producteurs de mollusques des 6 principaux pays producteurs conchylicoles de l'UE réunis au sein de l’AEPM militent depuis plusieurs années pour une information claire, précise et univoque sur l’empreinte environnementale de leurs produits. Ils sont également de longue date en faveur du "Level…

Consultation response

ProTerra Foundation, 23 Jul 2020

We support this initiative. Consumers and businesses need reliable, comparable and verifiable information to make sustainable decisions. Only this way are they able to make well-informed decisions. Their role is crucial in order to develop sustainable supply chains. Unified and pragmatic solutions…