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Sustainable products - disclosure of information on unsold consumer products

Environment

EU rules on Ecodesign for Sustainable Products identifies the destruction of unsold consumer products as an environmental problem. To dis-incentivize this practice, economic operators (except for micro and small enterprises), are required to disclose information on the unsold consumer products that they dispose of. This initiative will specify the product types concerned, the details and format for the disclosure of information, and how such information is to be verified.

Links

Public consultation

ID: 14590

Lobbying Activity

62 responses

European Environmental Bureau urges stricter unsold electronics reporting rules

European Environmental Bureau, 10 Jul 2025

The organization requests mandatory reporting for electronics and stricter verification rules. They advocate for clear public disclosure on websites and a ban on unknown waste destinations.
The proposal would provide environmental groups with transparent data to push for future bans.
Major online retailers would face higher costs and public scrutiny over their disposal practices.

AmCham EU urges removal of mandatory unsold product audits

American Chamber of Commerce to the European Union, 9 Jul 2025

The group requests removing the mandatory third-party verification requirement for reporting. They advocate for risk-based verification conducted by national authorities instead.
This would prevent significant reporting costs and unnecessary new compliance burdens.
National authorities would bear the administrative burden and costs of verifying data.

EuroCommerce urges clarity on unsold goods disclosure obligations

EuroCommerce, 10 Jul 2025

The organization requests clearer definition of which operator is responsible for reporting, a master list of affected product categories using CN codes, and alignment of assurance requirements with corporate sustainability reporting timelines. They want responsibility linked to ownership at time of discarding decision.
This would reduce administrative burden and provide legal certainty for compliance.

DIGITALEUROPE calls for clearer unsold product disclosure rules

DIGITALEUROPE, 9 Jul 2025

Responsibility should rest with the owner at the time of disposal. They also request excluding business-to-business products and using risk-based verification.
This would lower compliance costs and reduce administrative burdens for digital manufacturers.
Environmental monitors lose access to verified data on discarded industrial goods.

Finnish Forest Industries demands clear reporting exemptions for manufacturers

Finnish Forest Industries Federation (Metsäteollisuus ry), 25 Jun 2025

The organization requests that reporting only covers products made available on the market, excluding manufacturing components. They also demand that responsibility for disclosure shifts to traders once products reach the retail stage.
This would prevent manufacturers from being penalized for standard industrial recycling of production surplus.
Retailers and traders would face the entire administrative burden for unsold consumer products.

German Chamber of Commerce urges simpler unsold product reporting

Deutsche Industrie- und Handelskammer, 9 Jul 2025

DIHK proposes a minimum threshold so only significant quantities of discarded products are reported. They request two-year transition periods and simpler product categorization using two-digit codes. They argue that fields regarding waste treatment and prevention measures should be voluntary.
This would minimize administrative costs and prevent the disclosure of sensitive business information.
Environmental groups lose comprehensive data necessary to monitor and discourage product destruction.

Austrian chamber WKO urges practical rules for unsold goods

Wirtschaftskammer Österreich, 10 Jul 2025

WKO requests a reporting threshold of one tonne per product category. They also suggest reporting by units rather than weight to simplify tasks.
Avoiding these rules would save companies billions in IT and administrative costs.
Consumers face higher prices if companies pass on excessive administrative compliance costs.

Eurochambres seeks lighter reporting rules for discarded products

EUROCHAMBRES – Association of European Chambers of Commerce and Industry, 10 Jul 2025

The organization requests a minimum threshold for reporting, optional description fields, and voluntary disclosure of reduction strategies. They argue current requirements create unnecessary burdens while asking for estimates to suffice in the first implementation year.
This would reduce reporting burden and compliance costs for their member companies.
Environmental groups lose detailed transparency on product destruction practices and corporate waste reduction efforts.

MedTech Europe seeks exemption from unsold product disclosure rules

MedTech Europe, 10 Jul 2025

MedTech Europe requests that medical devices be exempt from disclosure requirements. They argue that existing sector laws should take precedence over these rules. Specific health and safety needs justify a derogation from these reporting obligations.
This would prevent companies from facing duplicative administrative burdens and additional financial costs.

Bosch urges EU to scrap mandatory audits for unsold goods

Robert Bosch GmbH, 10 Jul 2025

Bosch argues against mandatory third-party audits and requests that spare parts be excluded from reporting. They also support a one-year delay to set up internal reporting systems.
Avoiding external auditing would lower operational expenses and simplify internal reporting processes.
Regulatory transparency is reduced as the public loses independent verification of corporate waste data.

German machinery industry opposes costly audits for unsold products

Verband Deutscher Maschinen- und Anlagenbau e.V., 10 Jul 2025

VDMA opposes mandatory third-party auditing for discarded unsold consumer products. They recommend keeping product-level reporting separate from corporate sustainability frameworks to avoid duplicative processes.
This would reduce administrative costs and prevent procedural complexity for engineering firms.
Transparency groups lose access to independently verified technical data on product destruction.

ITI urges clearer EU rules for reporting unsold products

ITI - The Information Technology Industry Council, 10 Jul 2025

The organization requests a transitional period allowing for estimated data and a reporting format aligned with existing sustainability disclosures. They also want reporting limited to products destined for waste rather than those disassembled for parts.
This would streamline compliance and reduce the financial burden of redundant third-party auditing.
Regulators and environmental groups lose access to precise data if companies use estimated figures.

APPLiA urges more flexibility in reporting unsold consumer products

APPLiA (Home Appliance Europe), 10 Jul 2025

APPLiA requests extra time to establish reporting systems and clearer product classification codes. They advocate for internal verification systems instead of mandatory external audits for reporting accuracy.
This would reduce operational costs by replacing mandatory external audits with internal checks.
Environmental stakeholders lose the assurance of independently verified data regarding discarded consumer goods.

AIM urges EU to scrap third-party audits for unsold goods

AIM - European Brands Association, 10 Jul 2025

AIM requests removing third-party verification requirements and relying on national authority oversight. They advocate for aligning reporting formats and implementation timelines.
Eliminating audits would reduce administrative expenses and prevent the duplication of reporting tasks.

Cosmetics Europe urges flexible reporting on unsold consumer products

Cosmetics Europe, 10 Jul 2025

The industry recommends a risk-based verification approach instead of costly third-party audits. Companies need discretion when reporting preventive measures to protect confidential business data. They also propose aligning implementation deadlines to allow more time for data preparation.
These changes reduce administrative expenses and safeguard proprietary operational information from competitors.
Regulators and environmental advocates lose access to standardized data on product destruction practices.

Chemical Industry Federation of Finland urges narrower reporting scope

Chemical Industry Federation of Finland (Kemianteollisuus ry), 27 Jun 2025

The scope should initially be limited to durable consumer goods or specific product groups. This gives companies time to prepare for new reporting systems and verification processes.
Limiting the scope would reduce immediate compliance costs and administrative workloads for companies.

ECOS Demands Stricter Disclosure Rules for Unsold Products

Environmental Coalition on Standards, 2 Jul 2025

ECOS calls for granular reporting using 4-digit codes and mandatory verification for all covered companies. They demand specific details on waste treatment destinations and clear links in sustainability reports. Prevention plans must include budgets and KPIs to avoid empty promises.
This provides environmental groups with credible data to push for future destruction bans.
Large retailers would face increased costs for auditing and complex supply chain tracking.

Tyre industry urges reporting exemptions for subscription-based products

European Tyre & Rubber Manufacturers' Association, 10 Jul 2025

ETRMA calls for a clear exemption for products provided under subscription models. They also support using a limited assurance standard to minimize reporting costs.
This would allow companies to avoid the high manual effort of tracking information.

EHPA Urges Heat Pump Exemption From Unsold Product Reporting

European Heat Pump Association, 9 Jul 2025

EHPA requests the Commission exempt heat pumps and air conditioning systems from reporting obligations. They argue the requirements are misaligned with high-value products that are repaired, not discarded.
This exemption would prevent redundant costs and unnecessary third-party auditing requirements for manufacturers.
Environmental regulators lose data and transparency regarding the disposal of large industrial appliances.

Independent Retail Europe seeks central reporting for cooperative groups

Independent Retail Europe (formerly UGAL - Union of Groups of Independent Retailers of Europe), 25 Jun 2025

The organization calls for rules allowing cooperative groups and franchises to report data centrally. They claim that requiring individual reports from independent retailers creates a disproportionate administrative burden. This change would ensure a level playing field with integrated retail chains.
Centralized reporting reduces costs and helps independent retailers coordinate collective waste-reduction solutions.
Integrated retail chains lose their current regulatory advantage over cooperative and franchise business models.

Cleaning industry body urges simpler reporting on unsold products

Association Internationale de la Savonnerie, de la Détergence et des Produits d'Entretien, 8 Jul 2025

A.I.S.E. requests exemptions for products discarded for safety reasons and opposes mandatory third-party audits. They suggest relying on existing national checks and delaying implementation to ensure data consistency.
This would reduce administrative burdens and avoid the costs of hiring external auditors.
Policy makers lose the data necessary to inform future bans on destroying products.

Ecommerce Europe urges simpler reporting on unsold consumer goods

Ecommerce Europe, 10 Jul 2025

The group seeks to minimize administrative burdens and prevent retroactive reporting requirements. They propose that only the product owner making discarding decisions should be responsible. They also suggest using average weight estimates and clear product categories for compliance.
Streamlined reporting and the use of estimates would lower businesses' compliance costs.
Environmental monitoring groups may receive less precise data due to reporting variations.

Toy industry urges flexible reporting for unsold consumer products

Toy Industries of Europe, 10 Jul 2025

TIE requests a 3-month disclosure deadline and guidance on reporting formats. They advocate for risk-based verification to avoid excessive administrative burdens.
This would lower compliance costs by preventing fragmented national rules and simplifying data verification.
Environmental groups may face less precise data if companies use estimates to fill reporting gaps.

IKEA urges flexible reporting rules for unsold consumer products

Ingka Services A.B., 10 Jul 2025

IKEA suggests using estimates to fill data gaps during the initial reporting phase. They also propose aligning verification deadlines with existing sustainability laws to avoid duplication.
This would lower compliance costs and prevent misleading labels on waste handling methods.
Environmental advocates lose access to precise figures if companies report using broad estimates.

Consultation response

EUROPEAN APPAREL AND TEXTILE CONFEDERATION, 10 Jul 2025

EURATEX, the European Apparel and Textile Confederation, appreciates the opportunity to provide feedback to the draft Implementing Act (IA) on the details and format for the disclosure of information on discarded unsold consumer products. Building on our previous input to the development of the…

ZVEI rejects mandatory third-party audits for unsold product reporting

ZVEI e.V. - Verband der Elektro- und Digitalindustrie, 9 Jul 2025

ZVEI rejects mandatory third-party verification and requests clearer product definitions for reporting. They also call for extended transition periods to prepare and publish mandatory reports.
These changes would reduce administrative expenses and prevent excessive reporting burdens on industry.
Environmental monitoring loses the accuracy and reliability provided by mandatory independent third-party audits.

CCIA Europe urges simpler rules for reporting unsold products

Computer and Communications Industry Association, 26 Jun 2025

CCIA Europe recommends using product-type estimates as the standard reporting practice. They also propose a transitional period to provide legal certainty for businesses.
This would reduce technical compliance costs and prevent redundant reporting across different EU regulations.
Regulators lose the granular data needed to monitor waste levels across different industrial sectors.

Clothing brands call for clearer EU unsold goods reporting rules

European Branded Clothing Association, 10 Jul 2025

EBCA recommends that responsibility should lie with the economic operator owning the goods when discarded. They want a specific list of product codes and the ability to combine reporting with existing sustainability audits. They also argue that unknown treatments should be separate from destruction.
This would reduce compliance costs by avoiding redundant reporting and clarifying liability.
Environmental groups lose precise data as separating 'unknown' categories masks actual destruction rates.

FEAD urges waste code inclusion in unsold product disclosure

FEAD, 10 Jul 2025

The organization proposes including waste codes alongside customs codes to match standard industry practices. They also recommend limiting disclosure requirements to the first waste treatment operation.
Waste operators avoid unfeasible tracking requirements while ensuring compatibility with current management systems.
Regulators lose visibility into the ultimate environmental impact of residues from processed products.

IKEA Urges Flexibility in Reporting Rules for Unsold Products

Inter Ikea Systems BV, 10 Jul 2025

IKEA wants to use estimates for reporting during the initial phase and align audit schedules with other EU laws. They also argue that unknown waste results should be treated neutrally instead of as destruction.
This approach would reduce administrative costs and prevent a fragmented compliance landscape for the company.
Environmental protection efforts may be hindered if reporting allows for less precise data collection.

Municipal Waste Europe urges full transparency on destroyed unsold goods

Municipal Waste Europe, 10 Jul 2025

MWE calls for all disposal data to be public and easily accessible on company websites. They want detailed reporting on where products are sent and specific prevention measures implemented. They also demand the removal of 'Unknown' as a reporting option to ensure full traceability.
This improves the investment environment for recyclers by returning raw materials to EU producers.
Companies lose the ability to obscure waste destinations by selecting 'Unknown' in reports.

Portuguese Business Group Seeks Clarity on Unsold Product Disclosure

CIP - Confederação Empresarial de Portugal, 10 Jul 2025

CIP calls for a harmonized list of product categories and the exclusion of safety recalls. They argue that products with unknown destinations should be treated as a neutral category rather than destruction.
Aligning these rules with existing sustainability reporting would reduce unnecessary administrative burdens.
Environmental monitoring groups lose oversight if unknown product destinations are not reported as destruction.

Policy Hub Urges Simpler Reporting Rules for Unsold Products

Policy Hub - Circularity for Apparel and Footwear, 10 Jul 2025

The organization requests that waste treatment data be simplified to only include quantities delivered for reuse and destruction. They also advocate for linking disclosure responsibility to the ownership of products at the time of discarding.
This approach would minimize administrative burdens and help companies avoid unnecessary compliance costs.
Regulators would lose access to granular data on specific recycling and recovery operations.

European heating industry seeks exemption from product destruction reporting

Association of the European Heating Industry, 9 Jul 2025

The association requests the removal of boilers, heat pumps, and water heaters from the reporting list. They argue these are professional equipment, not consumer goods, and are rarely destroyed.
Manufacturers would avoid significant administrative costs and reporting obligations for high-value appliances.
Environmental groups lose transparency regarding the waste and disposal of large industrial systems.

Japanese business council seeks flexible EU unsold product rules

Japan Business Council in Europe, 9 Jul 2025

They argue only goods primarily intended for consumers should be subject to reporting. They also state the limited assurance requirement must be removed to avoid burdens.
This would reduce the complexity of compliance and remove disproportionate burdens for operators.
Public transparency loses out if regulators accept aggregated data or best estimates instead.

Consultation response

SHEIN Group, 9 Jul 2025

SHEIN feedback on the Implementing Regulation on the disclosure of information on unsold consumer products As a global fashion and lifestyle e-retailer, SHEIN welcomes the opportunity to provide feedback on the draft Implementing Regulation on the disclosure of information on unsold consumer…

Lighting industry opposes mandatory audits for unsold goods reporting

LightingEurope, 10 Jul 2025

LightingEurope calls for the removal of mandatory third-party auditing for reporting unsold consumer products. They propose a risk-based, ex-post verification approach by national authorities to ensure cost-effective enforcement.
Removing mandatory audits prevents significant financial burdens and reduces administrative complexity for businesses.
Auditing firms lose guaranteed revenue if third-party verification is no longer mandatory for companies.

EPEE seeks clarity on B2B exemptions for unsold product reporting

European Partnership for Energy and the Environment, 10 Jul 2025

EPEE requests that only the economic operator holding ownership at the time of discarding be responsible for disclosures. They recommend clarifying that products predominantly sold in B2B channels are not in scope. They also seek to resolve confusion regarding the application date.
This would prevent manufacturers from being held liable for waste they cannot control.
Regulators will have less visibility into the disposal of commercial and industrial equipment.

Czech Chamber of Commerce Urges Collective Reporting for Franchises

Hospodářská komora České republiky, 7 Jul 2025

Allow cooperative retail groups and franchise networks to report data jointly. Central organizations should handle disclosure on behalf of independent member retailers. This would respect the unique structure of decentralized business models.
Centralized reporting would lower administrative costs for medium-sized businesses and cooperative groups.
Integrated retail chains would lose the regulatory advantage they currently hold over franchises.

Polish cosmetics industry seeks delay in product disposal reporting

Polski Związek Przemysłu Kosmetycznego, 10 Jul 2025

The Union calls for aligning reporting start dates with the finalization of the data format to ensure regulatory certainty. They also demand the removal of mandatory third-party verification and stronger protection for commercial secrecy.
This would reduce administrative expenses and prevent the leakage of sensitive commercial data.

Consultation response

ANIMA CONFINDUSTRIA MECCANICA VARIA, 10 Jul 2025

The proposed reporting requirements under Article 24 of the ESPR Regulation (EU) 2024/1781 are set to be implemented across industries. Anima Confindustria wishes to express its concerns regarding the potential impact these obligations may have on the sectors it represents. You can find in the…

SPECTARIS urges medical device exemptions from product destruction reporting

SPECTARIS Deutscher Industrieverband für Optik, Photonik, Analysen- und Medizintechnik e.V., 9 Jul 2025

SPECTARIS requests exemptions or specific rules for medical devices like eyewear and bandages. They argue these products are discarded based on safety standards rather than commercial reasons.
This allows companies to maintain strict safety protocols without facing public pressure regarding disposal.
Environmental transparency suffers if large volumes of medical waste remain unreported to the public.

Consultation response

Polish Association of Cosmetic and Detergent Industry / Polskie Stowarzyszenie Przemysłu Kosmetycznego i Detergentowego, 10 Jul 2025

Polskie Stowarzyszenie Przemysłu Kosmetycznego i Detergentowego (PSPKD) w pełni popiera cele rozporządzenia 2024/1781 ws. ustanowienia ram ustalania wymogów ekoprojektu w odniesieniu do zrównoważonych produktów (ESPR), w tym odpowiedzialnego zarządzania niesprzedanymi produktami. W związku z…

Consultation response

European Cultural and Creative Industries Alliance, 10 Jul 2025

Please find in attachment ECCIA's detailed comments on the draft Implementing Regulation on details and format for the disclosure of information on discarded unsold consumer products.

Consultation response

European Power Tool Association, 10 Jul 2025

The European Power Tool Association (EPTA) welcomes the opportunity to provide feedback on the Draft Implementing Regulation laying down rules for the application of Regulation (EU) 2024/1781 of the European Parliament and of the Council as regards the details and format for the disclosure of…

Consultation response

Techniek Nederland, 10 Jul 2025

Techniek Nederland is the Dutch employers' organization representing approximately 6,000 companies in the technical service and installation sector, the repair and refurbish sector and the technical retail sector. Techniek Nederland has expressed its support for a ban on destruction of unsold goods…

Consultation response

European Refurbishment Association, 9 Jul 2025

EUREFAS - the European Refurbishment Association - welcomes the opportunity to provide high level comments on the draft Act. Our association gathers actors of the refurbishment sector interested in ensuring long-term sustainability of the consumer electronics industry by allowing devices to get…

Consultation response

Bundesverband E-Commerce und Versandhandel Deutschland e.V., 10 Jul 2025

Der Bundesverband E-Commerce und Versandhandel Deutschland e.V. (bevh) repräsentiert als die Interessenvertretung der Branche der in Deutschland aktiven Online- und Versandhändler Unternehmen aller Größen und aller denkbaren Handelsformen (Online, Multichannel, Katalog, TV-Shopping,…

Consultation response

Fédération de la Haute Couture et de la Mode, 10 Jul 2025

Founded in 1973, the Fédération de la Haute Couture et de la Mode (the Federation or the FHCM) represents over a hundred of the most recognized French and other international brands. As a founding member of the European Fashion Alliance, which contributes as an expert to the Ecodesign Forum, the…

Consultation response

Syndicat national de l'industrie des technologies médicales, 10 Jul 2025

Snitem supports Medtech Europe's position : MedTech Europe welcomes the European Commission public consultation on the draft Implementing act according to Art. 24(3) to lay down the details and format for the Art. 24- disclosure of information requirement and possibility to comment on the…

Consultation response

The Restart Project, 10 Jul 2025

The Right to Repair Europe coalition welcomes this opportunity to share feedback on the draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) 2024/1781 as regards the details and format for the disclosure of information on discarded unsold consumer…

European furniture industry urges flexibility in reporting unsold products

European Furniture Industries Confederation, 10 Jul 2025

EFIC requests flexibility to use estimates when data on discarded products is unavailable. They also call for removing third-party verification requirements to avoid heavy financial burdens.
Removing verification requirements would save furniture manufacturers from significant and disproportionate administrative costs.
Market surveillance authorities lose data precision because companies would be allowed to use estimates.

Consultation response

Alliance du Commerce, 10 Jul 2025

L'Alliance du Commerce est la principale fédération professionnelle du secteur de l'équipement de la personne en France, représentant les grands magasins, magasins populaires et enseignes d'habillement et de chaussure (plus de 150 000 emplois et 16 000 magasins implantés en France). En France, la…

Consultation response

Institut National de l'Economie Circulaire, 9 Jul 2025

LInstitut National de lEconomie Circulaire (INEC) appelle à soutenir les modèles économiques du réemploi et du don. Ce soutien est indispensable pour faire de linterdiction de destruction des invendus non alimentaires un véritable levier de transition écologique. Linterdiction de destruction des…

Consultation response

HKI Industrieverband Haus-, Heiz- und Küchentechnik e.V., 30 Jun 2025

You can find the statement from the German Industry Association of House, Heating and Kitchen Technology (Industrieverband Haus-, Heiz- und Küchentechnik e.V.) in the attached PDF document.

Consultation response

EUROMCONTACT, 10 Jul 2025

The European association representing manufacturers of contact lenses and lens care products, EuromContact, welcomes the opportunity to comment on the draft Commission implementing regulation developed under Article 24 of the Ecodesign for Sustainable Products Regulation (ESPR). Given the specific…

Consultation response

Camera Nazionale della Moda Italiana, 10 Jul 2025

CNMI welcomes the opportunity to provide comments to the draft implementing regulation adopted under Article 24 ESPR. This contribution sets out CNMIs main concerns and related recommendations regarding the disclosure obligation mandated by Article 24 ESPR and further detailed under the…

Consultation response

GermanFashion Modeverband Deutschland e.V., 10 Jul 2025

Please find attached the statement by the GermanFashion Association.

Consultation response

figawa, 10 Jul 2025

figawa would like to thank you for the opportunity to submit our comments on the draft implementing act under the ESPR Unsold Consumer Products. Please find enclosed our feedback as pdf-file.

Consultation response

I&P Europe - Imaging and Printing Association e.V., 9 Jul 2025

See attached/uploaded comments.

Consultation response

, 8 Jul 2025

EU Commission July 8, 2025 LOBU DI-2021-23557 Danish Industry (DI) response on disclosure requirements regarding unsold con-sumer products Danish Industry (DI) thanks the EU Commission for the opportunity to respond to this consultation. DI represents more than 20.000 companies within numerous…

DigitalTrade4.EU urges automated digital passports for unsold products

DigitalTrade4.EU, 21 Jun 2025

The organization requests that reporting on discarded goods use machine-readable formats and automated data submission. They propose integrating this information directly into Digital Product Passports to streamline the process. They also recommend using digital tools and verifiable credentials for the verification of discarded products.
Switching to automated digital systems would significantly lower administrative costs and simplify complex reporting.
Large tech platforms would lose market dominance if forced to allow interoperability with third-party apps.