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Policy Hub - Circularity for Apparel and Footwear

Policy Hub

Policy Hub – Circularity for Apparel and Footwear promotes sustainable practices through EU-level policy formulation.

Lobbying Activity

Policy Hub urges EU to prioritize textile circularity and harmonization

6 Nov 2025
Topic — The consultation seeks feedback on the upcoming Circular Economy Act for sustainable production.
Message — The group requests textiles be a core priority and that waste management rules be harmonized across Europe. They advocate for financial incentives and dedicated funding to support the transition to circular business models.123
Why — Standardized reporting and registration would lower compliance costs for companies operating in multiple countries.45
Impact — Groups seeking immediate bans on waste exports or incineration may see delayed action.67
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Response to Revision of the 'New Legislative Framework'

2 Sept 2025

The Policy Hub Circularity for Apparel & Footwear welcomes the opportunity provided by the European Commission through the Call for Evidence for the upcoming revision of the New Legislative Framework (NLF). We consider it both timely and appropriate to undertake this revision, given that the legislative landscape has changed significantly since the original framework was adopted. The Policy Hub has been actively engaged from the outset in supporting ambitious legislation, such as the Ecodesign for Sustainable Products Regulation (ESPR). While we are fully aligned with its objectives, we stress the need for an efficient, practical, and enforceable framework to ensure that these objectives are achieved and progress is sustained. On this basis, we recommend that the European Commission consider the priorities outlined in the attached document.
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Policy Hub urges flexible derogations for unsold textile destruction

11 Aug 2025
Topic — New rules specifying when companies can legally destroy unsold clothing and footwear.
Message — The group requests a broader interpretation of voluntary standards and clearer definitions for product reuse. They also propose reducing the documentation retention period from ten years to five years.12
Why — The changes would lower administrative costs and simplify compliance for textile companies.3
Impact — Non-profit organizations may lose access to donations due to narrow eligibility criteria.4
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Policy Hub Urges Simpler Reporting Rules for Unsold Products

10 Jul 2025
Topic — New EU rules regarding disclosure requirements for the destruction of unsold consumer products.
Message — 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.12
Why — This approach would minimize administrative burdens and help companies avoid unnecessary compliance costs.3
Impact — Regulators would lose access to granular data on specific recycling and recovery operations.4
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Meeting with Giulia Del Brenna (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Cascale

9 Jul 2025 · Textiles strategy implementation

Meeting with Jessika Roswall (Commissioner) and

2 Jun 2025 · Textiles

Meeting with César Luena (Member of the European Parliament)

13 Dec 2024 · Circular Economy

Meeting with Pierre Jouvet (Member of the European Parliament)

27 Nov 2024 · Textile durable

Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur) and European farmers

17 Oct 2024 · discussion on Green Claims Directive

Meeting with Alice Kuhnke (Member of the European Parliament, Shadow rapporteur)

15 Oct 2024 · Sustainable textiles

Meeting with Alice Kuhnke (Member of the European Parliament) and Svensk Handel

27 Sept 2024 · Sustainable textiles

Meeting with Jeannette Baljeu (Member of the European Parliament, Shadow rapporteur)

26 Sept 2024 · Waste Framework Directive

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur) and Grakom

9 Feb 2024 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur) and EuroCommerce and Siemens AG

29 Jan 2024 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)

5 Jan 2024 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Meeting with Susana Solís Pérez (Member of the European Parliament)

5 Dec 2023 · WFD meeting held by parliamentary assistant

Meeting with Pernille Weiss-Ehler (Member of the European Parliament)

30 Nov 2023 · Proposal for a targeted revision of the Waste Framework Directive

Response to Waste Framework review to reduce waste and the environmental impact of waste management

21 Nov 2023

The Policy Hub Circularity for Apparel and Footwear, uniting more than 700 brands, retailers, manufacturers, and other stakeholders within the industry and representing more than 50% of the apparel and footwear sector welcomes the Commission's efforts to revise the Waste Framework Directive (WFD). The proposed revision of the Waste Framework Directive (WFD) acknowledges several fundamental points for the success of the legislation. These include the call for harmonisation of Extended Producer Responsibility (EPR) requirements, ensuring alignment with other relevant regulations, the inclusion of Research and Development (R&D) investments, and restrictions on the export of products (used and waste textiles). However, the textile industry has identified areas for improvement, such as: 1. proper enforcement, 2. the role of online platforms and fulfilment service providers, 3. re-evaluating the exclusion of micro-enterprises, 4. mandating eco-modulation alignment, 5. harmonising reporting rules, 6. refining PRO reporting requirements, 7. ensuring clear and measurable definitions, 8. harmonising the criteria for sorting in relation to preparation reuse and preparation for recycling. To address these concerns and promote effective implementation, the Policy Hub calls for collaboration between the industry and policymakers to foster an efficient and scalable market for secondary raw textile materials and to meet the objectives of the WFD. We specifically welcome the outlined points below: Harmonisation: We welcome the call for harmonisation of requirements across the EU regarding the Extended Producer Responsibility (EPR) scope, definitions, waste hierarchy operationalisation, and cost coverage. This is a crucial element to ensure the functioning of the single market, improve the effectiveness of EPR schemes, and ease the administrative costs for businesses operating across Europe. The proposal can be strengthened by harmonising fee structures and eco-modulation, reporting (rules and guidelines), Member States targets, and KPIs. Coherence with other files: We support the alignment with other relevant regulations, such as the Ecodesign for Sustainable Products Regulation (ESPR) and Waste Shipment Regulation (WSR). In this regard, implementation timelines should also be considered; otherwise, there is the risk of implementation gaps and loopholes inadvertently causing unstable market dynamics that result in delayed investments in large-scale capital projects crucial to achieving much higher levels of recycling capacity. Cost Coverage: We appreciate the inclusion of Research and Development (R&D) investments in the proposal. However, we emphasise the need for careful implementation to ensure it is fit for purpose and build on a market-driven approach. Export of Textiles: We consider it a positive addition that only actually reusable garments should be allowed to be shipped outside the EU to address better those used garments that will fall outside the scope of the Waste Shipment Regulation (WSR). However, we would like to highlight the sector's suggested areas of improvement concerning the presented proposal. Please find further details in the attached file.
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Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur) and The European Consumer Voice in Standardisation

9 Oct 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Meeting with Cyrus Engerer (Member of the European Parliament, Rapporteur)

4 Oct 2023 · Green Claims Directive

Response to Revision of EU rules on textile labelling

29 Sept 2023

The Policy Hub Circularity for Apparel and Footwear, uniting more than 700 brands, retailers, manufacturers, and other stakeholders within the industry and representing more than 50% of the apparel and footwear sector, welcomes the EU authorities' efforts to harmonise rules on labelling textile products. Over the past years, significant developments have taken place regarding novel fibre materials and new labelling possibilities. Given these developments, the Policy Hub supports the necessity of amending the Textile Labelling Regulation. This involves modernising, digitalising, as well as harmonising the regulation with existing and developing textile-related EU initiatives. However, the impact assessment must focus on dissecting the difference between essential and supplementary information. The incorporation of additional information or labels on the physical label should only occur when there is substantiated evidence demonstrating its capacity to either mitigate a garment's environmental footprint or influence consumer behaviour positively. More specifically, the Policy Hub proposes the following recommendations for the revision of the Textile Labelling Regulation: Encourage the EU Commission to conduct a comprehensive regulatory assessment to provide clarity and simplicity in the classification process for novel fibres outlined in Annex I. This assessment should strive to modernise the method for categorising new fibre composition terms, thereby permitting a more straightforward and technically precise approach for identifying unique innovative materials; Facilitate the implementation of digital labelling and ensure harmonisation with other EU consumer communication initiatives in the textile and apparel sector. Harmonise the Textile Labelling Regulation with global jurisdictions. Simplify the integration of recycled fibres by exploring the potential for increased tolerance levels within Article 20. The current regulation is not adapted to handle labelling compositions involving recycled fibres; Ensure further clarity on labelling requirements for products in the exemptions list in Annex V; We urge the EU authorities to refrain from including the following two points in the Revision of the Textile Labelling Regulation: We do not support the inclusion of social sustainability labelling in this regulation, as risk analysis and mitigation are regulated at the corporate level (under the CSDDD) and not at the product level. We do not support the harmonisation of product sizing at the EU level, as it compromises design specifications and composition materials.
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Meeting with Andrus Ansip (Member of the European Parliament, Rapporteur) and World Travel and Tourism Council

28 Sept 2023 · Green Claims

Policy Hub Urges Simplified Verification for Textile Green Claims

15 Jul 2023
Topic — The EU is proposing rules to substantiate environmental claims using specific footprint methods.
Message — 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.123
Why — Streamlined verification and longer timelines would lower administrative costs and reduce legal risks.4
Impact — Verification bodies could lose revenue if the EU moves away from individual claim-by-claim checks.5
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Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)

19 Dec 2022 · Strategy for Sustainable and Circular Textiles

Policy Hub Urges Harmonised Rules for EU Forced Labour Ban

30 Nov 2022
Topic — EU initiative to prohibit products made with forced labour on the market.
Message — The group requests harmonised implementation across member states to ensure legal certainty. They call for clearer evidentiary thresholds and longer response deadlines for investigations. They also advocate for the recognition of industry-led initiatives and standards.12
Why — Standardised procedures would protect legitimate trade from inconsistent or overzealous customs actions.3
Impact — National authorities would lose the discretion to target specific industries or sectors.4
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Meeting with Delara Burkhardt (Member of the European Parliament, Rapporteur)

24 Nov 2022 · Textiles

Meeting with Alessandra Moretti (Member of the European Parliament, Rapporteur)

28 Oct 2022 · Framework for setting eco-design requirements for sustainable products

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur) and C&A Mode GmbH & Co. KG

22 Sept 2022 · Strategy for Sustainable and Circular Textiles

Response to Sustainable Products Initiative

22 Jun 2022

The Policy Hub – Circularity for Apparel and Footwear, uniting more than 700 brands, retailers, manufacturers, and other stakeholders within the industry, and representing more than 50% of the apparel and footwear sector, welcomes the European authorities' efforts to reduce the environmental impact of products placed on the EU’s market. As an industry, we are supporting the expansion of the ecodesign principles to apparel and footwear products. We specifically welcome the below-outlined points that we consider fundamental for the success of the legislation: • Harmonisation for a single market: The harmonisation of requirements across the EU to ensure the functioning of the single market. • Tailored product-specific requirements: The EU Commission’s approach towards vertical, product-specific requirements to ensure these are tailored and fit for purpose. • Impact-focused LCA approach: The selection of requirements applied per product group that are most relevant/ impactful from a circularity perspective and follow an LCA approach based on the Product Environmental Footprint (PEF). • Comprehensive assessments: Emphasising the need for comprehensive assessments for the development of the Delegated Acts. • Digitalisation of product information: Increasingly sharing product information through digital means e.g., the Digital Product Passport (DPP). However, we would like to highlight the sectors’ suggested areas of improvement concerning the presented proposal, which are outlined in the attachment. The Policy Hub, its partner organisations (Sustainable Apparel Coalition (SAC), Global Fashion Agenda (GFA), the Federation of the European Sporting Goods Industry (FESI), Textile Exchange, and ZDHC Foundation) as well as their members stand ready to support the development of the intended requirements for the apparel and footwear. Please find our full contribution in the attachment.
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Policy Hub warns against product-level forced labour ban

20 Jun 2022
Topic — The European Union is proposing a ban on products made using forced labour.
Message — The group suggests regulating entire companies rather than individual products to ensure feasibility. They request a risk-based approach and significant time to adjust complex global supply chains.12
Why — Extended timelines and entity-level regulation would significantly lower the group's immediate compliance costs.3
Impact — Forced labour victims face delayed protections if trade bans are used only as last resorts.4
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Response to Empowering the consumer for the green transition

27 May 2022

The Policy Hub – Circularity for Apparel and Footwear, uniting more than 700 brands, retailers, manufacturers, and other stakeholders within the industry, and representing more than 50% of the apparel and footwear sector, welcomes the European Union’s authorities’ efforts to protect consumers from unfair commercial practices of greenwashing, early obsolescence, and unreliable and non-transparent information tools. As an industry, we are supportive of the EU Commission’s efforts to introduce measures to provide consumers with trustworthy information and to tackle the proliferation of sustainability labels. We share the EU Commission’s ambitions to steer purchasing decisions in a sustainable direction, enabling consumers to play a more active role in the green transition. We specifically welcome the below-outlined measures: • Avoiding misleading environmental claims: The strengthened requirements set by the EU Commission for companies to communicate the environmental impact of products will enable consumers to access trustworthy and reliable information to facilitate more sustainable consumer behaviour. • Minimum communication standards: Providing guidance on what types of environmental claims can be made and how these should be communicated to consumers. • Prohibiting claims on mandatory legal requirements: Claims that solely address compliance with legal requirements can no longer be advertised as benefits to consumers. This will be important in protecting consumers from misleading information. As we are still reviewing the amending Directive in-depth, we would like to highlight some of the key points for further clarification. 1. Policy Coherence between different EU Legislation; 2. Trustworthy and Credible Sustainability Labels; 3. Repairability and Durability Requirements; 4. Comparative Claims. To read our full contribution please refer to the attached document.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

The Policy Hub - Circularity for Apparel and Footwear welcomes and supports the European Commission’s proposal to revise the Waste Framework Directive (WFD). The ambition of the Policy Hub is to improve the circularity of the textile sector by maintain-ing as much as possible value of resources used in the production of textile products. To support this aim, we advocate for full harmonisation between all EU Initiatives for the textile sector as well as full harmonisation between the Member States’ implementing national ini-tiatives for the textile sector. For the WFD in particular, this means that the revision of the WFD must be completely aligned with the criteria set in other EU Initiatives for the textiles sector, such as the Sustain-able Product Initiative including the Digital Product Passport, Substantiating Green Claims Initiative, Empowering the Consumers Initiative, the EU Taxonomy, the PEF methodology and other upcoming policies that will impact our sector. In light of this, we would like to con-tribute as per below. We see the revision of the WFD as an opportunity to incentivise and accelerate solutions for textiles end-of-life management to enable the circular economy. We expect that the WFD will leverage waste prevention and will boost the market for reused textiles and recycled fi-bers production, especially in light of the mandatory separate collection of textiles obliga-tion applicable as of 2025. To handle these increased volumes of collected post-consumer textiles safely and efficiently, we will need a well-functioning and harmonised policy frame-work. In this regard, the Policy Hub’s key recommendations are as follows: 1. Set relevant definitions and requirements for textiles; 2. Harmonise sorting criteria for both reuse and recycling; 3. Boost sorting and recycling infrastructure dramatically; 4. Harmonise the separate collection of textiles; 5. Harmonise EPR requirements for textiles at EU level; 6. Set targets and other measures for waste prevention; 7. Ensure consistency of other regulatory initiatives, such as the Sustainable Product Initiative, Waste Shipment Regulation, and the end-of-waste criteria. Please see attached our recommendations in full detail.
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Meeting with Alice Kuhnke (Member of the European Parliament) and European Environmental Bureau and World Resources Institute

25 Oct 2021 · Speaker: The EU Sustainable Textiles Strategy - How Do We Ensure Ambitious Climate Action Is Central to Upcoming Legislation?

Meeting with Virginijus Sinkevičius (Commissioner) and

17 Jun 2021 · To discuss the forthcoming EU textiles strategy

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Federation of the European Sporting Goods Industry and

15 Jun 2021 · Green claims, consumer empowerment, Textiles Strategy and EU sustainable product policy

Meeting with Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius) and Federation of the European Sporting Goods Industry and

15 Jun 2021 · Green claims, consumer empowerment, Textiles Strategy and EU sustainable product policy

Response to EU strategy for sustainable textiles

2 Feb 2021

The Policy Hub – Circularity for Apparel & Footwear welcomes the opportunity to comment on the EU Commission’s roadmap for the EU Strategy for Textiles. We endorse the direction developed by the EU Commission in the roadmap, and its objective to support the industry to be-come more sustainable, resilient and competitive. Overall, the roadmap reflects the dialogue the Policy Hub and the EU Commission have been engaged in for over two years. We are pleased to learn that the EU Commission intends to further collaborate with the industry, throughout the development of the EU Strategy for Textiles as clarified in the roadmap. Over the past decades, the apparel and footwear industry has been working on addressing its sustainability challenges through various efforts. Progress has been made over the last years by the industry ranging across multiple subjects of the sustainability agenda, like innovating and using more environmentally friendly materials, implementing resource-efficient production technologies, introducing higher transparency and disclosure standards. Yet, the industry has been facing different obstacles, including legislative ones, to close the material loop of its value chain, e.g., due to the lack of collection, sorting and recycling technologies and infrastructures. Furthermore, the COVID-19 crisis has been a shock to the global economy: apparel and footwear industry is one of the industries that has been hit particularly hard , as recognised by the EU Commission in the current roadmap. The EU Commission should set clear and ambitious objectives for the EU Strategy for Textiles in order to address the current challenges faced by the industry in its journey towards circularity. This should be done in very close collaboration with the industry. The overall target shall be to support the European industry through the right conditions (for instance, investments and funds for infrastructure, and R&D) and incentives to become more circular. In light of the ambitions and the experience of the sector it represents, the Policy Hub – Circularity for Apparel & Footwear recommends the EU Commission to follow three key principles to develop a meaningful and effective EU Strategy for Textiles: 1. Addressing the missing concepts of the EU Commission’s Roadmap: Following a holistic approach considering social and environmental impacts in the value chain. 2. Creating an aligned framework for apparel and footwear: Translating the horizontal EU initiatives for the sector. 3. Developing a harmonised European framework: Coordinating Member States Initiatives. The Policy Hub – Circularity for Apparel & Footwear and the affiliated members of its partners are ready to support and collaborate with the European authorities in the development of the EU Strategy for Textiles. We remain at the EU Commission’s disposal for any inquiries or questions and refer to our previous publications and contributions. Our full contribution can be accessed in the attachment.
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Response to Sustainable Products Initiative

2 Nov 2020

The Policy Hub welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment "Sustainable Products Initiative". The transition towards a circular economy in which materials can be used and reused at their highest potential, is one of the priorities of the apparel and footwear industry. For many leading companies, it is already a key pillar of their sustainability strategy. First and foremost, given the various initiatives currently being launched by the Euro-pean Commission which will be interlinked and will be impacting the apparel and footwear industry at various levels, we urge the European Commission’s services to coordinate, align and harmonise efforts across initiatives targeting sustainable products launched in 2020: o At a product level with DG ENV’s initiatives on Green Claims and DG JUST’s initiative on Empowering Consumers for the Green Transition. o At brand/organisational level with DG ENV’s initiatives on Green Claims, DG JUST’s initiative on Sustainable Corporate Governance and DG FISMA’s review of the Non-Financial Reporting Directive (NFRD). We share with the European Commission the belief that an EU policy framework is needed to promote sustainable products. We recommend the following for this European Policy framework: 1. Identifying appropriate policy tools for the apparel and footwear sector. 2. Clearly defining the attributes of circular and sustainable products and developing a holistic approach for our industry to enable and support innovation. 3. Incentivising the transition to more sustainable products through the development of appropriate infrastructures and the rewarding of better performing products through EU funding. 4. Enabling (digital) infrastructures to share reliable and trustworthy information about products. Please find the Policy Hub's full feedback on the "Sustainable Products Initiative" in the document attached.
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Response to Environmental claims based on environmental footprint methods

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 green claims in accordance with the Environmental Footprint methods, as a complement to existing methods (developed by private or public entities, at national or international level)”. We are convinced that a collaborative effort to support the development of the standardised tools and methodology is needed for substantiating environmental and social claims. Therefore, we are in favor of the Product Environmental Footprint (PEF) methodology to substantiate sustainability claims made on product level. For claims made on brand level we cannot support the Organisational Environmental Footprint (OEF), given its methodological short-comings and issues with scalability. Sustainability claims at product and brand level must be substantiated. This is a matter of trust and creating a level playing-field for the apparel and footwear industry. We believe that any sustainability claims should meet the following principles: • Comparative environmental (sustainability) claims should only be made if they are accurate, clear, complete, easily accessible, reliable, relate to aspects that are significant in terms of the product’s environmental impact, and make explicit what the claim refers to. • Sustainability claims need to be substantiated with an appropriate methodology (e.g. environmental claims specifically about a product will require different methodologies than environmental claims made at the brand level). • These methods need to go through robust stakeholder engagement and should be developed in a public-private partnership where industry experts would be invited to participate and a dialogue with the competent authorities would be encouraged. • The scalability of these methodologies for all actors across the value chain such as SMEs is an absolute necessity to ensure the industry’s support and uptake. • To this end the existing work that the industry has invested in over the years should be leveraged for example the Higg Index suite of tools. Additionally, the Policy Hub recommends that: • The European Commission harmonises its efforts across the various services and initiatives targeting transparency launched in 2020: o On a product level with DG JUST’s initiative on Empowering Consumers for the Green Transition. o On brand level with DG JUST’s initiative on Sustainable Corporate Governance and DG FISMA’s review of the Non-Financial Reporting Directive (NFRD). • Any new initiative should be built on the basis of the better regulation principle. • The baseline for the European Commission’s impact assessment takes into account the outcomes and learnings of the pilot phase of the Footwear Product Environmental Footprint (PEF) pilot. The Policy Hub's full contribution is available in the attached document.
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Response to Empowering the consumer for the green transition

31 Aug 2020

The Policy Hub welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment "Empowering the consumer for the green transition". Addressing the issues of greenwashing (problem 2b) and the multiplication of labels (problem 2c) has always been among the priorities of the apparel and footwear industry. We believe that four principles need to be met in order to enable effective consumer-facing communications: • Trustworthy and reliable data needs to be collected throughout the value chain to allow for comparison; • A common methodology should be available and easily accessible for all companies in order to substantiate green claims they want to make; • A harmonised regulatory framework is needed that allows for the effective communication of sustainability information to consumers; • An economic impact assessment is needed to ensure that the future consumer protection instrument drives change and that it can be applied at scale. Our Recommendations: • In light of this and on the basis of problems identified in the Inception Impact Assessment, we recommend the Commission to further explore option 2 “A new stand-alone consumer protection instrument” to ad-dress problem 2b “vague, misleading or unfounded information” and 2c “proliferation of labels”. At the same time, further clarification and elaboration on what the Commission is envisioning are needed before recommending a course of action to address the other problems raised. • To solve the problem of unfounded claims in the interim and contribute to creating more legal certainty related to problem 3 (“effective enforcement of existing consumer protection rules in these areas is difficult“), we recommend the European Commission to develop a guidance document for the Unfair Commercial Practices Directive (UCPD). This would provide clarity on how to interpret the current directive applying to claims of 'sustainability in the apparel and footwear sector'. In collaboration with the industry, first criteria for communication about product should be set, that are more stringent than todays. Existing tools and labelling schemes that meet these criteria (e.g. the Higg Product Module - Higg PM and Higg Brand and Retail Module - Higg BRM) should be listed in the Annex to the guidance document. Using these criteria in consumer communication have the potential to drive informed decision-making by the consumer and reward companies and products that are truly more sustainable. Impact-oriented transparency can accelerate industry improvement. • Finally, we recommend an overall harmonisation of the European Com-mission’s efforts across the various services and initiatives targeting transparency launched in 2020: 1) At a product level with DG ENV’s initiatives on Green Claims and the Sustainable Product Policy Framework and DG JUST’s initiative on Empowering Consumers for the Green Transition. 2) At brand level with DG ENV’s initiatives on Green Claims, DG JUST’s initiative on Sustainable Corporate Governance and DG FISMA’s re-view of the Non-Financial Reporting Directive (NFRD). The attached document outlines the Policy Hub's views and recommendations.
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