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Kaupan liitto ry - Finnish Commerce Federation

Finnish Commerce Federation is a lobbying group that promotes wholesale and retail trade in Finland, negotiates labor agreements, and advocates for better business conditions for its members.

Lobbying Activity

Meeting with Mika Aaltola (Member of the European Parliament) and Alliance4Europe gGmbH and Oulun yliopisto

3 Dec 2025 · EU affairs

Meeting with David Boublil (Head of Unit Taxation and Customs Union)

2 Dec 2025 · Revision of the Tobacco Taxation Directive

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

22 Oct 2025 · EU trade policy

Meeting with Kamil Kiljanski (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

15 Oct 2025 · Discussion of the future policies in IP for the new mandate

Meeting with Dirk Gotink (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

10 Jun 2025 · EU customs legislation, e-commerce

Meeting with Aura Salla (Member of the European Parliament)

28 May 2025 · Current issues in the retail sector. Exchanging views on growth policy and ensuring fair competition conditions in e-commerce (e.g., Temu / Shein)

Meeting with Katri Kulmuni (Member of the European Parliament)

20 May 2025 · Kaupanalan asioita EU näkökulmasta

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

20 May 2025 · Corporate legislation

Meeting with Eero Heinäluoma (Member of the European Parliament)

20 May 2025 · Verkkokaupat ja digitaalinen euro

Meeting with Maria Blassar (Head of Representation Communication)

10 Mar 2025 · Finnish Commerce Federation wished to brief on their EU agenda.

Meeting with Maria Guzenina (Member of the European Parliament) and Kuluttajaliitto ry

14 Feb 2025 · E-commerce

Finnish Commerce Federation urges fair rules for online marketplaces

31 Jan 2025
Topic — The consultation seeks views on deepening the single market and removing regulatory barriers.
Message — The Federation demands that third-country players follow the same rules as European companies. They also call for 24-month transition periods and the removal of customs exemptions.12
Why — Restoring a level playing field would eliminate unfair price advantages held by foreign competitors.3
Impact — Non-EU online platforms would lose their competitive edge from duty-free sales to European consumers.4
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Meeting with Isabelle Perignon (Director Justice and Consumers) and The Danish Chamber of Commerce and Swedish Commerce

29 Jan 2025 · presentation of their vision re responsibilities of 3rd country online marketplaces and support for Consumer Protection Cooperation review; Commission briefly mentioned e-commerce communication and updates re product safety - Safety Gate website.

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

29 Jan 2025 · Retail trade

Meeting with Isabelle Perignon (Director Justice and Consumers) and The Danish Chamber of Commerce and Swedish Commerce

17 Jan 2025 · Exchange of views with the Nordic Commerce Coalition on the responsibilities of third-country origin online marketplaces

Response to Digital Product Passport (DPP) service providers

9 Dec 2024

Products sold outside the EU must have a digital product passport to prevent the emergence of dual markets. To ensure the competitiveness of businesses operating within the European Union, the EU must begin to strongly monitor cross-border e-commerce with a new EU-level instrument that supports the vital work of national supervisory authorities. The European Union did not create the ESPR legislation for IT-companies to make large profits but to ensure that the circular economy functions within the Union's territory and empower the consumer. Especially considering that most companies operating within the European Union are small and medium-sized enterprises, whose IT expertise and financial situation vary significantly, the transition must be implemented within a transitional period and with strong support for businesses. The costs must also remain accessible for SMEs. The Digital Product Passport (DPP) represents a radical transformation in production, logistics, commerce, and regulatory processes. To ensure a successful transition and minimize risks associated with such a complex shift, it would be essential to adopt a gradual and structured approach that allows stakeholders to adapt progressively to the new requirements. KNOBS S.r.l.I (Feedback reference F3498127) is proposing a three-phase model spread over biennial implementation cycles for each initial sector obligated to adopt the DPP, which we strongly support. This approach would enable testing and refining the system before full deployment, preventing operational disruptions or challenges.
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Meeting with Eero Heinäluoma (Member of the European Parliament) and CMI - Martti Ahtisaari Peace Foundation

2 Dec 2024 · Ajankohtaisaiheet

Meeting with Elsi Katainen (Member of the European Parliament)

2 Dec 2024 · Kaupan alan ajankohtaiset asiat ja näkymät tulevalle EU-kaudelle

Meeting with Katri Kulmuni (Member of the European Parliament)

2 Dec 2024 · Kaupan alan näkymät ja ajankohtaiset EU-asiat

Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis)

21 Nov 2024 · Discussion on ecommerce communication

Meeting with Aura Salla (Member of the European Parliament)

17 Oct 2024 · Finnish Commerce Federation's policy views

Meeting with Maria Ohisalo (Member of the European Parliament)

1 Oct 2024 · Ajankohtaiset asiat, tuleva kausi

Meeting with Pirkko Ruohonen-Lerner (Member of the European Parliament)

1 Dec 2023 · Kaupan alan kannalta ajankohtaiset EU-asiat

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

1 Dec 2023 · Relevant current legislation

Meeting with Petri Sarvamaa (Member of the European Parliament)

1 Dec 2023 · Topical issues in EU commerce politics

Meeting with Eero Heinäluoma (Member of the European Parliament)

29 Nov 2023 · Näkemykset digitaalista euroa ja eurokäteistä koskevaan komission esitykseen, tavoitteet seuraavalle vaalikaudelle

Finnish Commerce Federation Urges EU to Cut Reporting Burdens

24 Nov 2023
Topic — The EU initiative aims to reduce legislative reporting requirements by 25 percent.
Message — The federation recommends a broad 'one in, one out' principle to prevent administrative growth. They advocate for digital-first reporting and removing redundant requirements for physical documentation provided to consumers.123
Why — Standardizing rules across the EU would reduce compliance costs and simplify cross-border operations.45
Impact — National authorities would lose the power to set specific country-level reporting rules.6
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Meeting with Sirpa Pietikäinen (Member of the European Parliament)

23 Oct 2023 · Green Claims Directive

Meeting with Nils Torvalds (Member of the European Parliament, Shadow rapporteur for opinion)

12 Oct 2023 · PPWR &GCD

Response to Revision of the Union Customs Code

6 Oct 2023

Finnish Commerce Federation, representing the Finnish retail and wholesale sector, is pleased to submit the attached contribution related to revision of the Union Customs Code.
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Meeting with Sirpa Pietikäinen (Member of the European Parliament, Shadow rapporteur for opinion)

23 May 2023 · Corporate Sustainability Due Diligence Directive

Meeting with Taneli Lahti (Cabinet of Commissioner Jutta Urpilainen)

10 May 2023 · retail and wholesale sector for the next Commission

Finnish Commerce Federation urges equal status for recyclable packaging

21 Apr 2023
Topic — The European Commission is reviewing rules to minimize packaging waste and reuse.
Message — The federation requests that recycling remain an equal alternative to reusable packaging. They propose delaying new reuse targets until 2028 to gather scientific evidence.12
Why — This would prevent the loss of significant investments made in Finnish recycling.3
Impact — Mandatory reuse targets would impose unreasonable financial costs on consumers and producers.4
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Meeting with Henna Virkkunen (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE

14 Apr 2023 · EU Cyber Resilience Act

Response to VAT in the Digital Age

4 Apr 2023

Please find attached Finnish Commerce Federation's comments regarding the public consultation on VAT in the digital age.
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Finnish Commerce Federation Urges Alignment With Global Chemical Standards

29 Mar 2023
Topic — Revision of EU legislation for the classification and labelling of chemicals.
Message — The federation advocates for maintaining alignment with global systems instead of introducing unique EU hazard classes. They seek to remove the new multi-constituent substance definition to prevent regulatory confusion. They also request more manageable deadlines to avoid unnecessary relabelling of existing stock.123
Why — This would reduce compliance costs and administrative burdens for distributors and retailers.4
Impact — Environmental groups lose faster implementation of stricter chemical safety and classification standards.5
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Finnish Commerce Federation seeks end to non-EU duty relief

19 Sept 2022
Topic — The consultation proposes revising the Union Customs Code to address modern e-commerce challenges.
Message — The federation calls for removing the customs duty relief on low-value imports. They argue current exemptions provide an unfair advantage to companies outside the EU.12
Why — Ending the exemption would ensure Finnish companies can compete fairly on price.3
Impact — International marketplaces would lose the competitive edge provided by duty-free small shipments.4
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Meeting with Isabelle Perignon (Cabinet of Commissioner Didier Reynders)

14 Jun 2022 · sustainable consumption and consumer protection law’

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

14 Jun 2022 · Data Act, AI Act.

Meeting with Elina Laurinen (Cabinet of Commissioner Thierry Breton)

14 Jun 2022 · Digital trade and sustainable consumption

Finnish Commerce Federation urges clearer limits on corporate due diligence

20 May 2022
Topic — The EU is consulting on rules for corporate sustainability due diligence and accountability.
Message — The federation requests that rules align closely with international standards to ensure flexibility. They advocate limiting responsibility to the direct supply chain instead of the entire value chain. They also argue for prioritizing guidance and administrative sanctions over civil liability.123
Why — Narrowing the scope would reduce legal uncertainty and complex information gathering costs.45
Impact — Victims of abuses in distant supply chain tiers would lose legal protection.6
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Meeting with Elsi Katainen (Member of the European Parliament)

12 May 2022 · digitalisaation ja verotuksen säätely

Meeting with Sirpa Pietikäinen (Member of the European Parliament, Shadow rapporteur for opinion)

12 May 2022 · Consumer Credit Directive

Response to VAT in the Digital Age

5 May 2022

Finnish Commerce Federation, representing the Finnish retail and wholesale sector, is pleased to submit the attached contribution to the call for evidence related to VAT in the digital age.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

Finnish Commerce Federation welcomes the opportunity to contribute to the development of energy and climate policies at the EU level. Investors already prefer sustainable businesses and, like companies, are committed to ESG and carbon neutrality. Time, know-how and money is invested to actions which strongly pursue carbon neutrality. In Finland regulation is already moving in this direction, aiming at the most appropriate and cost-effective actions at national level, using local strengths and involving different stakeholders, and taking into account the existing building stock and its location. We undeniably need some new legislation in the EU, but we definitely must have wisdom to avoid over-regulation and unnecessary administrative burden. Companies also need time to adapt to the current regulations that were just put in place though the national implementation of EPBD and EED revisions of 2018. Technology neutrality and a holistic view on energy systems, in order to reflect varying conditions on local, regional and national levels, are crucial and have to be taken into account when new legislation is planned. It's important to highlight that not only regulation, but also non-regulatory policy instruments and capacity building provide are equally important tools. Such as technical assistance, guidance, awareness raising information campaigns, training, research and development, standards, and project financing. A good example of voluntary non-regulatory measures are the Energy Efficiency Agreements in Finland. They are an important part of Finland’s energy and climate strategy and the principal method by which the efficient use of energy is advanced. Energy efficiency has been promoted with voluntary agreements between the government and various industries since the 1990s and they cover more than 60% of Finland's total energy use. Energy efficiency measures implemented by participating companies and municipalities in 2008-2016 reduced carbon dioxide emissions by 4.7 million tonnes per year and energy costs in total by more than 560 million euros per year. We strongly support expanding the use of this voluntary agreement model to all Member States. It is a workable and strong alternative to regulation.
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Meeting with Salla Saastamoinen (Director-General Justice and Consumers)

22 Nov 2020 · Meeting at request of Finnish Commerce Federation (Chief Policy Adviser on EU affairs and Corporate Law) to discuss New Consumer Agenda and incoming online shopping directive and Corporate responsibility regulation

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

12 Nov 2020 · DSA and DMA

Response to Chemicals strategy for sustainability

18 Jun 2020

Finnish Commerce Federation response to the Commission roadmap for chemicals strategy for sustainability is in the attached pdf-file.
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Meeting with Jutta Urpilainen (Commissioner)

5 Mar 2020 · European commerce and EU Digital package

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

18 Feb 2020 · Digital services act

Response to A new Circular Economy Action Plan

14 Jan 2020

Circular Economy is an opportunity to rethink the way we design, produce, manufacture, sell, use and discard our products. Finnish retail and wholesale sector recognize the lead that the EU takes to respond to increasing environmental challenges in terms of resources scarcity, access to materials, human rights and resources efficiency. To ensure that the circular economy model works in practice, the quality and safety of recycled materials needs to be high enough. One must be able to control product requirements (e.g. chemical content) of the products entering the Single Market. This is not the case today, and chemicals banned in EU may reenter into the market. This is a substantial threat to recycling of materials in circular economy. The multinational online marketplaces have opened the European market to sellers from 3rd countries whose products many times do not comply with EU rules on chemicals or product safety. European surveillance authorities do not have jurisdiction to hold companies outside the EU liable. In practice the online marketplaces (as intermediaries) and non-EU e-retailers cannot be held liable or have no legal liability for the products they sell to EU consumers. EU and national legislation also require companies that put products on the market to contribute to producer responsibility schemes. The aim of these is to collect and recycle used products and ensure that they do not cause littering or pollute the environment. In theory this is a requirement also for sellers from non-EU countries, but the lack of controls makes this impossible to enforce. Since the products still end up in the collection systems, European companies end up paying the collection fees for their non-EU competitors. The current legal framework affects the competitiveness of European companies, especially SMEs. Much of the current legal framework originates from time prior to the digital and platform economy. It relies on the supply chain with clear legal responsibilities for manufacturer, importer and distributor in the EU. When goods are sold to European consumers via an online marketplace from a supplier, which is not established in the EU, a legal loophole occurs. The responsible actor is not established in the EU and there is therefore no possibility to hold them liable. During the upcoming review of the EU waste legislation this issue must be addressed. We strongly support setting minimum requirements to prevent environmentally harmful products from being placed in the EU market.
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Response to Amendment of Regulation (EU) 2019/1021 on POPS as regards the entry of PFOS in Annex I

19 Dec 2019

The current process to amend Regulation (EU) 2019/1021 on POPS as regards the entry of PFOS in Annex I should take properly and fully into account the existing REACH restriction no. 68 on PFOA. Especially the current proposal is unsatisfactory with regard to exemptions. Where the REACH restriction would exempt articles already on the market before 4 July 2020, the restriction according to amended POP Annex I would allow only six months transition period to the same articles before becoming waste. From the perspective of supply chain dynamics and complexity a half year time is absolutely too short time to adapt to a new and considerable changing situation. The POP proposal brings in an unexpected legal situation with no prewarning to those concerned. This is clearly against the important principle of legal certainty because companies have made there business decisions in good faith in line with the REACH restriction. They should be allowed to keep their acquired right, and instead, a new legislation should be set in a way that it takes into account and respects their legitimate expectations. In addition, industry from producers down to wholesale and retail should be treated equally, in a way that the consequences of changes in legislation do not cause disproportionate harm to any actor, irrespective of sector or company size. We think that simply putting into waste the already produced articles which would suddenly become illegal as non-compliant is not wise even sustainability-wise in the big picture. The fair and right thing to do would be to include the exemptions of REACH restriction no. 68 as they are in the amendment of Annex I of POP regulation with PFOS.
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Meeting with Timo Pesonen (Acting Director-General Internal Market, Industry, Entrepreneurship and SMEs)

16 Oct 2019 · Courtesy meeting to introduce themselves and present their priorities

Response to Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669

6 Feb 2019

The Finnish Commerce Federation welcomes this public consultation. We have followed the process with concern from the beginning. We believe that the consumers would be confused by the proposed labeling for products containing TiO2. Overall, the classification and labelling would be disproportionate in our view. It will not help consumers in any way but rather confuse them on the nature of the product they intend to buy. We think that a state-of-the-art study should be performed before making any final decision regarding the classification and labelling of TiO2, i.e. the on-going process for harmonised classication and labelling (CLH) should be put on hold until new data is available. RAC itself in its opinion states that “relevance of lung overload in animals to humans is currently not clear and is subject to continued scientific debate”. Especially based on this fact RAC could have come to a different conclusion regarding the classification of TiO2. We are convinced that the need to manage risks related to TiO2 is limited to industrial environment where it is handled in dusty form. It is indeed stated in the RAC opinion that the TiO2 classification (carcinogenic if inhaled, Carc. 2) is not based on substance-specific toxic properties but on its dust form. Consequently, we see that the case is out of the scope of CLP but should instead be managed under occupational safety legislation where we have more suitable tools available for this kind of cases. For decades, occupational safety has been based on the principle of avoiding dusty materials. If the use of dusty materials cannot be avoided, exposure to them is prevented. CLP classification based on dusty nature of a material would not increase the safety of use of such a substance at any stage of the supply chain. We also encourage further discussion on how the overall chemical safety and good risk communication could be taken into account in the CLH process. Risk communication and the instructions for safe use are key factors in ensuring the chemical safety of consumers and workers. Risk communication is challenging already now, as the regulations require so much text on the labels of chemical that all consumers no longer pay attention to them. Hazard information on the label, and in particular warnings about CMR properties, must be taken particularly seriously. It is of paramount importance that we continue using warnings and special instructions only based on sound justification. Otherwise, we see a possibility of weakening of the effectiveness of hazard labelling in the long run and decline of safety as a consequence.
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Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

26 Nov 2018 · European retail sector

Meeting with Marika Lautso-Mousnier (Cabinet of Vice-President Jyrki Katainen)

29 Nov 2017 · E-commerce, platform economy, unfair trade practices in the food supply chain, best practices in the retail sector

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

25 Oct 2017 · exchange of views on EU Food Supply Chain

Finnish Commerce Federation opposes new EU food chain regulations

22 Aug 2017
Topic — Consultation on legislative initiatives to address unfair trading practices in the food supply chain.
Message — The Federation prefers self-regulation and maintaining the status quo over new EU legislation. They argue that targeting retailers' practices will not effectively strengthen farmers' positions.12
Why — This avoids significant administrative burdens and compliance costs for companies at all supply chain levels.34
Impact — Farmers lose by remaining exposed to market difficulties without the proposed legislative protections.5
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Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska) and Kesko Corporation and S Group

1 Feb 2017 · food suply chain

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

1 Feb 2017 · unfaire trading practices in the food supply chain

Meeting with Carl-Christian Buhr (Cabinet of Commissioner Phil Hogan)

13 Jan 2016 · Governance and specificities of the Finnish national Supply Chain Initiative