Lobbying by amfori - Trade with Purpose

amfori - Trade with Purpose

amfori

amfori is a business association focused on resilient and sustainable global supply chains.

Focus Areas

2023-2024

2020-2022

2015-2019

Links

Website Transparency Register Profile

ID: 84768556104-35

Lobbying Activity

Meeting with Anna Cavazzini (Member of the European Parliament, Committee chair)

18 Sept 2024 · EU Corporate Sustainability Due Diligence Directive and EU Forced Labour Regulation

Meeting with Lara Wolters (Member of the European Parliament)

17 Sept 2024 · Corporate Sustainability

Meeting with Helmut Scholz (Member of the European Parliament) and EUROPEAN TRADE UNION CONFEDERATION and

18 Apr 2024 · CSDDD

Meeting with Heidi Hautala (Member of the European Parliament, Shadow rapporteur) and Cisco Systems Inc. and

18 Apr 2024 · Multi-stakeholder discussion on CSDDD

Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Rapporteur)

26 Sept 2023 · Forced Labour ban

amfori urges clear guidance on sustainability materiality assessments

6 Jul 2023

Topic — Proposed rules defining how European companies disclose environmental and social performance.

Message — The association requests clear guidance on conducting materiality assessments and determining reporting cut-off points. They call for consistency between reporting standards and due diligence laws.1 2

Why — Consistent standards and liability protections would reduce legal risks and simplify compliance.3 4

Impact — Stakeholders lose the ability to compare businesses if reporting methodologies are too flexible.5

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Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Rapporteur)

11 Apr 2023 · Forced Labour ban

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and The Shift Project and Global Network Initiative

13 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

amfori Urges Improvements to Proposed EU Forced Labour Ban

30 Nov 2022

Topic — A legislative proposal to ban products made with forced labour from the EU.

Message — amfori requests including state-imposed forced labour explicitly and allowing investigations into specific factories or regions. They also propose doubling the time for companies to respond to investigations to thirty days.1 2 3

Why — Businesses would avoid unfair prejudice by having more time to prepare high-quality evidence.4

Impact — Factories and regions using forced labour would face broader and more effective bans.5

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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and Amnesty International Limited and

15 Nov 2022 · Corporate Sustainability Due Diligence

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

17 Oct 2022 · Corporate Sustainability Due Diligence

Meeting with Kateřina Konečná (Member of the European Parliament, Shadow rapporteur)

2 Sept 2022 · Deforestation

amfori urges pragmatic alignment in EU forced labour ban

20 Jun 2022

Topic — The initiative targets banning products produced with forced labour within the EU single market.

Message — amfori asks for alignment with international standards and consistency with the Corporate Sustainability Due Diligence Directive. They advocate for an actionable tool that encourages continuous improvement rather than penalizing businesses that discover issues through due diligence.1 2

Why — Harmonized requirements would create a level playing field and reduce complexity for international traders.3

Impact — Suppliers in countries with weak enforcement may lose market access without significant capacity support.4

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Response to Review of the general product safety directive

1 Oct 2021

amfori welcomes the proposed General Product Safety regulation and the goal that it seeks to achieve. It is important that consumers can be assured that the products they buy – many of which will be from amfori retailer members – are safe, and to have recourse to action in the, hopefully rare, occasions that proves not to be the case. The enhanced coherence with other, similar, areas is also appreciated. Similarly, the improvements to coordination and the provisions on enforcement. Although many importer/retailers – including those within amfori membership – already have procedures in place that are compliant with the proposed GPSR (e.g., on information to the consumer, recalls, etc.), we have some concerns that the certain requirements within Article 10 could place an additional burden on some importers – although we accept that this is a necessary consequence of achieving the desired outcome. In particular, we are concerned that the requirement that insists an importer must ensure the manufacturer is in compliance with its requirements within the proposed GPSR is rather onerous – particularly Art.10(1)(ii). It also appears that the requirements placed on on-line marketplaces are less demanding than those placed on importers. This not only gives them an unfair advantage over those importers/retailers but also possibly provides the opportunity for unsafe products to reach the market. Considering the significant volume of business to consumer sales via online platforms this should be addressed. Therefore, we would like to see these requirements brought more into line with those imposed on importers.

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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and ClientEarth AISBL and

15 Mar 2021 · Corporate Sustainability Due Diligence

Response to EU strategy for sustainable textiles

2 Feb 2021

amfori welcomes a strategy to facilitate the transition of the textile sector towards a sustainable and circular economy. Already identified as an economic opportunity in the EU recovery plan, investment in the circularity of the textile industry will have social, environmental as well as economic benefits. amfori has 7 recommendations for the future EU textile strategy which were not visible enough in the roadmap: 1. Make product policy benefit to all life phases of textiles The EU textile strategy is an opportunity to identify specificities of the textile industry that other policies, and specifically the sustainable product policy initiative, need to accommodate such as an implementation for products produced in long, complex and global supply chains. Product policies require a holistic approach of the entire value chain of the product. 2. Encourage a system change by moving forward the entire value chain, including consumers Circular Economy should include more social and economic indicators to the environmental criteria already identified in the roadmap. In the EU textile strategy, this means that industry transition should be parallel to a shift in consumption patterns. Clear and implementable labelling as well as clear and consise information available for a product, will encourage concious consumerism. However, shifting the consumer trends will also require to cheapen sustainable products (through taxation or by removing trade barriers). 3. Provide quality sustainable secondary raw materials The access to a high quantity and good quality secondary raw materials is necessary. EU member states therefore have a strong responsibility to invest in infrastructure to collect, sort and recycle waste. A materials passport if information only destined to B2B could be considered if post-consumer players need to know technical information about the materials. If this information is deemed useful for waste industries, it should be collected at the same time as product passport information but should be only accessible to relevant users. 4. Consider the impact on global supply chains Over half of textiles currently consumed in the EU are produced in third countries, so all policy requirements placed on the textile industry should be assessed against their potential implementation in global supply chains. Involving industry players and encouraging them to share the difficulties to implement sustainability in their supply chain will allow a more realistic and constructive policy making. Involving producers in third countries might also be helpful. 5. Foster a due diligence approach Mainstreaming sustainability in supply chains requires a strong due diligence approach, which is foreseen in the Corporate Governance initiative being developed. Making sure that the EU textile strategy and its transition to a circular economy is coherent with due diligence in the supply chain will facilitate the inclusion of social aspects of the transition. Continuous improvement is for example a strong concept in due diligence in supply chains, and not very present in product policies. The EU textile strategy can provide the opportunity to make these different approaches work together so that supply chains and products improve continuously. 6. Include green diplomacy actions The EU should engage trading partners on sustainable governance in Free Trade Agreements and could encourage investment in sustainable practices. 7. Keep the dialogue with the textile industry The textile sector is very creative and innovative, and the shift towards sustainability is already well engaged in the entire industry. The textile industry has also been very engaged in policy development. Continuous dialogue between policy makers and the textile sector should be maintained throughout the development of policies. amfori members are looking forward to participating more in this dialogue. More information on each points can be found in the document attached.

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Response to Geographical indication protection at EU level for non-agricultural products

10 Dec 2020

amfori believes that it is important intellectual property rights are protected. In this regard, not only are amfori producer members able to defend their rights against illegitimate (counterfeit) products, but amfori retail members are able to use the system to avoid the situation where counterfeit products are mistakenly sold in their stores. Geographic indication protection already provides a high degree of reputation and value on agricultural products – something that is appreciated by consumers. amfori retail members benefit from such appreciation by selling such goods within the EU and in third countries. The same benefits could be achieved if the protection was extended to non-agricultural products. The current, fragmented, system(s) of protection is far from ideal. Harmonising these systems would be burdensome and unlikely to succeed. A single EU-wide system would be easier to control and less confusing for users. This should be implemented by regulation, rather than directive, as the latter could result in discrepancies between different Member States. Also complicated would be a sectorial approach that permits specific protection to be granted. A horizontal approach would allow more products to be protected and be less difficult to implement. Concerning the type of protection, PDO (Protected Designation of Origin) offers a higher standard of link to the geographic area than PGI (Protected Geographic Indication), but is more restrictive. However, amfori believes that the two systems should operate in tandem – as with the system for agricultural products. Geographic names and traditional names should both be permitted to allow more products to be protected and to be in line with the system for agricultural products. amfori considers that IPR actively encourages innovation; the innovators are rewarded for their work by obtaining exclusive rights to their product. The situation is somewhat different with GIs – particularly for non-agricultural products – since the innovation has, for the most part, already been done; the products are ‘traditional’. There is, therefore, some validity to this argument (although traditional products are improved by updated techniques, whilst still maintaining the ‘traditional’ aspects). Equally valid is the argument that protection will reduce competition. However, amfori does not consider that these should be used to prevent GI protection for non-agricultural products. Such protection should afford a certain level of exclusivity to the producer, and there will always be consumers who prefer the lower quality, and more affordable, ‘generic’ versions of the traditional products whilst the market for the protected products would remain. The geographic area for which protection is sought should be defined by local authorities who should also be responsible for ensuring the criteria to obtain protection continue to be met. Traditional names should be registered upon payment of a fee and cancelled if they no longer meet the specific requirements. amfori also believes that the system should be restricted to groups of producers with individual producers allowed protection only under exceptional circumstances.

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Response to Sustainable Products Initiative

16 Nov 2020

amfori, advocating for sustainable trade, welcomes a Sustainable Product Initiative (SPI) that will mainstream sustainable requirements in the EU market. Such an initiative can guide all companies towards their transition towards more circularity and provide a competitive advantage for frontrunners. Here are a few points to ensure that sustainability objectives are not diluted by administrative burden for companies. 1. Sustainability requires holistic approach Sustainability requires to take a holistic approach to measures, and even more when those measures address circular economy. Decarbonisation, as well as waste reduction, protection of biodiversity, human rights, social considerations, and economic resilience are therefore all as important and implicitly included when we talk about durability, reusability, repairability, recyclability and resource efficiency. The legislation should therefore reflect all these angles of sustainability when presenting general sustainable principles for products. 2. Coherence with Due Diligence in Supply Chains Due Diligence is becoming the norm in supply chains and the sustainability principles can be an equivalence for products. It is therefore important that the SPI is in coherence with the Sustainable Corporate Governance Initiative, also under assessment. To ensure coherence, each one could reference the other. Circularity will also only work if the other measures announced under the Circular Economy Action Plan and the Chemicals Strategy for Sustainability are also implemented closely together. The SPI can only require recyclability for example, if a market of secondary raw materials is more trustworthy by removing hazardous substances from the EU market and if the same market gets a boost through public procurement. 3. No One-size-fits-all The SPI intends to address the circularity of products and all of these will not be addressed in the same way depending on short-life or long-life products, or in different sectors. For clear measures on circular economy, amfori therefore recognises that they should be taken with a product-by-product approach, so the revision of the Eco-design directive would be the right tool to do so. However, Eco-design is slow and requires a lot of resources to implement and enforce, so the SPI should also integrate or at least reference other measures as well, (EU Ecolabel regulation or Green Public Procurement requirements). 4. Information requirements to be carefully assessed Although information on products is the key to circular economy, the more the information does not mean the more the circularity. The use and the user of the information should therefore be carefully assessed before the EU requires this information which causes strong administrative burden on companies. Information requirements are proliferating in different legislative initiatives, so measures like a product passport could be useful if they centralise the place to enter the information and where to consult it. All information will not be useful to everyone, so some information requirements should only be shareable between companies, with the waste operators for example, and consumers would not need to have access to all of them. Quality information is understandable, reliable, comparable, and not in the middle of too many other pieces of information. 5. International dimension The SPI will require cooperation of the entire supply chain, including actors in non-EU countries, so the initiative should be as simple as possible to facilitate the communication of the requirements to them. SMEs would benefit from training and guidance to be made available, for them and their supply chain. Sustainable principles will become the norm much faster if they are recognised internationally. The EU should use existing international standards and requirements such as the work done by ILO as much as possible, and all new sustainability principles should be backed by international cooperation.

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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Elina Melngaile (Cabinet of Executive Vice-President Valdis Dombrovskis)

12 Nov 2020 · Trade and sustainable development

Response to A new Circular Economy Action Plan

20 Jan 2020

amfori welcomes the renewed commitment of the European Commission to promote the transition to a circular economy. amfori members are importers, brands and retailers striving to deliver social, environmental and economic benefits all along their supply chain through open and sustainable trade. To achieve a truly circular economy which has no geographical borders, taking into consideration the complexity and reality of international supply chains is essential. Although Circular Economy is all about maintaining a material to its highest value possible for as long as possible in the economy, it is important to take a holistic approach and consider the environmental impacts, the energy constraints, and the social consequences of a drastic transition. 1. Facilitation of a circular environment for businesses For this reason, policies should start by encouraging consumer demand for circular products and providing incentives for circular business models (through taxation and green public procurement for example) rather than regulating. Giving flexibility for companies to implement circularity in their strategy will make innovation easier and at the same time reward those who already have a circular strategy in place. In cases where regulation is necessary, like when tackling policy incoherencies, it should be proportionate and give time for companies to adapt their strategy. The roadmap touches upon the importance of reliable information on products’ sustainability to encourage conscious consumer choices. amfori calls for greater transparency in supply chains, whilst ensuring that confidentiality of business information is preserved. Any information provisions should be meaningful for the target audience and proportionate to desired objectives. Information requested from the supply chains should be collected in a user-friendly way to avoid administrative burden, especially for SMEs who have little leverage over the factories in their supply chain. 2. The potential of international trade for a circular economy When looking at the Circular Economy, it is important to consider the impact of international trade. In particular, amfori encourages the European Commission to negotiate harmonisation of high standards with its trading partners. In a global value chain, the difference of standards complicates compliance and when the standards are too different, they create a risk of accentuating environmental risks in some countries (when trading waste for example). 3. Benefit of existing practices and collaboration amfori is willing to be involved in the process to develop the New Circular Economy Action Plan. By including the concerned sectors, especially resource-intensive sectors, in all steps of the process, the action plan could build on existing sustainable practices and give a competitive advantage to companies already implementing those strategies.

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Response to Towards the future Generalised Scheme of Preferences legal framework granting trade advantages to developing countries

7 Jun 2019

In principle, the current GSP system is effective – and its development (e.g. of tariff rates) is followed closely. If it were removed, the less productive factories in GSP countries would likely be no longer competitive. This would not be in the interest of GSP countries nor of the EU wishing to favour these countries. It would also not in the interest of EU importers as it would lead to a concentration process which could reduce the number of factories with competitive prices. However, a general problem is the effectiveness of the GSP system for the EU importers. In recent years the responsibility for the correct declaration of origin has shifted more to the EU importer. The REX system has removed the protection of legitimate expectations – as proof of preferential origin can no longer be issued by the local authorities. The consequence is that the EU importer must either enhance his controls on the preferential origin in GSP countries or incur major risks. In our opinion, it would be better to implement a system in which the beneficiary countries are involved in the control of preferential origin as this would provide better protection for the EU importer. In addition, we believe that the impact of the GSP system would be improved greatly by an expansion of the goods covered and a further reduction to the tariff rates. For example, the actual duty reduction rate for apparel is only 20% (i.e. 9.6% instead of 12%). This alone is not enough to motivate EU importers to buy from beneficiary countries instead of non-GSP countries, particularly if those countries (e.g. China or India) have better sourcing conditions such as quality, organization and IT, transport infrastructure, CSR, etc., or from LDCs with a 0% duty rate. The competitiveness of those countries could be improved if they were granted a higher deduction rate (e.g. at least 30%). The latest report by the WTO Committee on Rules of Origin concerning the utilisation rates under preferential trade arrangements (G/RO/W/185 of 09.05.19) concludes that the direct transportation rule is a major reason for low utilisation. This covers the exporting GSP-countries – especially those which are landlocked – but also markets such as Switzerland where goods are shipped and stored in the EU before being allocated and exported to CH. A complete cancellation of this requirement – or at least a more flexible administrative approach – would definitely increase the utilisation rates. We would also support the idea that additional benefits (a reduction to, or the removal of duties) for sustainable products. Not only would this encourage more sustainable production, but the economic benefit could compensate for higher production costs and make those products more competitive to other, less sustainable, products.

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Response to Proposal for a Regulation on Enforcement and Compliance in the Single Market for Goods (Goods package)

19 Mar 2018

See attached document

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Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)

16 Mar 2018 · SDGs implementation and CSR

Meeting with Cecilia Malmström (Commissioner)

12 Mar 2018 · Sustainability in EU commercial policy

Response to Restriction of CMR substances in textile articles and clothing for consumer use under REACH

2 Mar 2018

See attachment