OpenLobby.EU
Explore

Unilever

Unilever is one of the world's largest consumer goods companies with over 400 household brands available in more than 190 countries.

Lobbying Activity

Meeting with Cristina Maestre (Member of the European Parliament)

20 Jan 2026 · Regenerative agriculture

Meeting with César Luena (Member of the European Parliament)

15 Jan 2026 · Regenerative agriculture

Meeting with Stefan Köhler (Member of the European Parliament)

14 Jan 2026 · Politischer Austausch zu UTPs

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra) and Ahold Delhaize

12 Jan 2026 · Exchange on carbon farming and regenerative agriculture

Meeting with Giulia Del Brenna (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

16 Dec 2025 · Market dynamics in supply chains

Meeting with Dirk Gotink (Member of the European Parliament)

26 Nov 2025 · Unfair Trading Practices

Meeting with Elsi Katainen (Member of the European Parliament)

26 Nov 2025 · Packaging, sustainability

Meeting with Pietro Fiocchi (Member of the European Parliament)

25 Nov 2025 · Omnibus VI

Meeting with Pablo Arias Echeverría (Member of the European Parliament)

13 Nov 2025 · Single Market Strategy and the key concerns of the Fast-Moving Consumer Goods sector, with particular regard to unfair commercial practices

Meeting with Martin Hojsík (Member of the European Parliament, Shadow rapporteur) and Cosmetics Europe

13 Nov 2025 · Chemical omnibus - Cosmetics Regulation

Response to Circular Economy Act

6 Nov 2025

Unilever supports the EUs ambition for a circular economy and is committed to sustainability, innovation, and circularity across its value chains. We are taking voluntary action to reduce virgin plastic use by increasing recycled content, light-weighting packaging, and exploring alternative materials and formats. These efforts align with our Environmental Policy and aim to address plastic pollution, including microplastics. Recent EU legislation, such as the Packaging and Packaging Waste Regulation (PPWR), sets ambitious environmental targets that require substantial investment. To enable industry to meet these goals, companies need legal certainty and predictable measures to guide timely and effective investment. To truly support industrial transition, future policy must be practical, targeted, and investment-grade. It should avoid excessive costs, reduce administrative burdens, and promote speed and flexibilitykey enablers of competitiveness. A coherent and streamlined legislative framework will be essential to ensure the Circular Economy Act delivers tangible impact, accelerates innovation, and strengthens Europes industrial resilience.
Read full response

Meeting with Emmanuelle Maire (Head of Unit Environment)

2 Oct 2025 · Bioeconomy

Meeting with Flavio Facioni (Cabinet of Commissioner Olivér Várhelyi) and FGS Global (Belgium) BV and

18 Sept 2025 · Iodine deficiency in Europe

Unilever urges EU to adopt flexible chemical recycling rules

18 Aug 2025
Topic — The initiative sets common rules for calculating recycled content in plastic beverage bottles.
Message — Unilever supports a technology-neutral approach where chemical recycling complements mechanical processes. They advocate for a mass balance system to handle materials unsuitable for mechanical recycling. The company also suggests digital reporting tools to reduce administrative burdens.1234
Why — This provides an economically viable way for Unilever to meet food-grade packaging targets.56
Impact — Mechanical recyclers could lose feedstock if chemical recycling plants compete for the same plastic waste.7
Read full response

Meeting with Miguel Jose Garcia Jones (Cabinet of Commissioner Wopke Hoekstra)

22 Jul 2025 · Discussion on the acceleration of more sustainable chemicals in cleaning products

Meeting with Gabriele Bischoff (Member of the European Parliament, Shadow rapporteur)

4 Jul 2025 · Austausch mit Eurobetriebsräten

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall), Vita Jukne (Cabinet of Commissioner Jessika Roswall)

4 Jun 2025 · Upcoming Circular Economy Action Plan and Chemicals package

Meeting with Jeannette Baljeu (Member of the European Parliament)

22 Apr 2025 · Territorial Supply Constraints

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

15 Apr 2025 · Energy and energy-intensive industries in Europe, Competition policy (i.e. mergers)

Meeting with Jeannette Baljeu (Member of the European Parliament)

1 Apr 2025 · EU Sustainability legislation

Response to Evaluation of the Cosmetic Products Regulation

21 Mar 2025

Unilever believes that every product we make must be safe for people and for our planet and welcomes the Commissions initiative to evaluate the Cosmetic Product Regulation (CPR). CPR is a consumer-oriented legislation that is fit for purpose and effective. It has positively served the needs of consumers and regulators to ensure safety and compliance. Unilever would like to highlight key measures that are working well, measures to be improved and measures to address existing challenges. In terms of provisions that are working well, CPR is a progressive and effective law that safeguards human safety. It includes well-established pre-market science-based risk assessments of ingredients and products undertaken by company safety assessors and the Scientific Committee on Consumer Safety (SCCS). In addition, CPR is a gold standard at global level. It significantly inspired global cosmetics regulations, including animal testing bans, labelling and transparency requirements, as well as ingredient safety and other restrictions or bans. Therefore, we encourage the EU policymaker to double down on both approaches. Key elements to be improved include ensuring consistent interpretation, implementation and enforcement of CPR rules across all EU Member States. The law should ensure that all other horizontal legislation, including minor changes that may have an impact on cosmetics, are coherent with CPR and fit within the broader policy context. Moreover, we encourage policymakers to better anticipate scientific and technological advancements in the cosmetic industry and meet changing consumer demands and behaviours. We would also like to propose measures to address existing challenges related to the classification of substances, animal testing, and digitalisation. Ingredient restrictions or bans should be based on latest risk-based non-animal assessment approaches incorporating consumer exposure and best science. Restricting/banning ingredients solely on hazard could unnecessarily restrict/ban ingredients with valuable benefits to society and can create a false sense of security e.g. ethanol. On animal testing, we fully support the CPR bans but would like to maximise the regulatory use of NAMs and NGRA approaches under EU REACH and all other European chemical-related laws. Lastly, we believe that the development of digital technologies is an opportunity to provide tailored, actionable, and detailed information to consumers that will also prevent overloading on-pack information as packaging is reduced. In conclusion, the CPR robust regulatory framework must be preserved. New measures to better apply the key principles of the CPR and make it even more consumer-centric and future proof, should be coherent, predictable for industry and introduced in such a way that availability of key and innovative cosmetic benefits for consumers are not put at risk. Overall, we support measures and guidance that lead to simplification, clarification and a reduction in the overall bureaucratic burden of sector and horizontal regulation impacting cosmetics.
Read full response

Meeting with Jeannette Baljeu (Member of the European Parliament)

20 Mar 2025 · Opkomende EU ENVI en AGRI wetgeving

Meeting with Christophe Clergeau (Member of the European Parliament) and Confédération Européenne des Vignerons Indépendants and SEMAE

25 Feb 2025 · ENVI

Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur) and Apple Inc.

4 Dec 2024 · discussions on Green Claims Directive

Meeting with Sander Smit (Member of the European Parliament) and Vereniging Innovatieve Geneesmiddelen

29 Oct 2024 · ENVI

Meeting with Christophe Clergeau (Member of the European Parliament)

17 Oct 2024 · Detergents

Response to Commission Roadmap to phase out animal testing

15 Oct 2024

At Unilever, the safety of our products is our top priority. Each new product innovation is evaluated scientifically and systematically by our Safety and Environmental Assurance Centre (SEAC) scientists to assess the safety risks to the consumer, to the workers who make them, and to the environment. We use a wide range of non-animal New Approach Methodologies (NAMs) and Next Generation Risk Assessment (NGRA) approaches to assess the safety of our products and ingredients. We do not test on animals and believe that animal testing is not needed to make sure that our products and ingredients are safe for people to use and safe for our planet. Therefore, we are strongly in favour of the European Commission Roadmap to Phase Out Animal Testing in Chemical Safety Assessments and call upon the European Commission to maximise use of non-animal NAMs and NGRA approaches under European Chemical Regulations (Fentem et al. 2021). Much work has been conducted in recent years demonstrating the feasibility of using NAMs in decision-making and there is an increasing body of data showing that non-animal safety assessment of chemicals can achieve a similar (or better) level of protection than decisions based on traditional animal test data. It is now possible to apply NAMs as part of an exposure-led, tiered regulatory framework without sacrificing the robustness of the decisions made (see Appendix). Unilever has been jointly evaluating NAMs with the US Environmental Protection Agency (EPA) since 2015 (EPA Press Release) and US National Toxicology Program Interagency Center for the Evaluation of Alternative Toxicological Methods (NICEATM) since 2021 (NICEATM May 2021 newsletter). We believe it is time to work together under the European Commission Roadmap to lead the paradigm shift needed to deliver what European citizens want safe and sustainable chemicals without animal testing. We call upon the European Commission to use the Roadmap to modernise European Chemical Regulations, as follows: - strengthen the European Cosmetics Product Regulation (CPR) animal testing bans to avoid any new animal testing on cosmetic ingredients under REACH - facilitate regulatory use of NAMs and NGRA approaches through maximising use of existing mechanisms in regulatory frameworks (e.g. REACH Annex XI adaptations) - create a mechanism to allow meaningful scientific dialogue between REACH registrants and an independent scientific committee with NAMs/NGRA expertise - update legal and regulatory requirements to enable use of the best scientific evidence and approaches available to protect human health and our environment - uphold the EUs commitment to, and legal requirement for, animal testing as a last resort by obliging REACH registrants to scientifically justify proposed animal testing - evolve chemical regulatory frameworks to enable use of exposure-based, tiered weight-of-evidence NGRA approaches (i.e. in line with SCCS Notes of Guidance) - harmonise regulatory guidance to ensure NAMs and NGRA approaches are applied consistently across European chemical legislation - allocate dedicated funding at the European Commission, ECHA and Member States level to enable the widespread deployment of NAMs & NGRA approaches - adopt a European Validation and Test Method strategy to streamline the evaluation of NAMs and NGRA approaches to address priority regulatory needs - establish the European Partnership for Alternative Approaches to Animal Testing (EPAA) as the collaborative platform for Roadmap implementation In this way, the changes introduced to chemical regulations such as REACH and CLP in the coming years could act as a key enabler for sustainable innovation, whilst also meeting the demands of European citizens for safe and sustainable products and ingredients without animal testing. Thank you for your consideration.
Read full response

Meeting with César Luena (Member of the European Parliament)

3 Oct 2024 · Detergents Regulation

Meeting with Majdouline Sbai (Member of the European Parliament, Rapporteur) and Association Internationale de la Savonnerie, de la Détergence et des Produits d'Entretien

1 Oct 2024 · Révision du règlement Détergents

Meeting with Dimitris Tsiodras (Member of the European Parliament)

1 Oct 2024 · Environmental policies

Meeting with Michael Bloss (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

2 May 2024 · Green Industrial Deal

Meeting with Christophe Grudler (Member of the European Parliament, Shadow rapporteur)

12 Jan 2024 · Règlement pour une industrie à zéro émission

Meeting with Christian Ehler (Member of the European Parliament, Rapporteur)

13 Dec 2023 · Net-Zero Industry Act

Meeting with Manuela Ripa (Member of the European Parliament, Rapporteur)

13 Dec 2023 · Detergents Regulation

Meeting with Clara Aguilera (Member of the European Parliament)

13 Dec 2023 · Green claims directive

Meeting with Francesca Peppucci (Member of the European Parliament, Shadow rapporteur)

30 Nov 2023 · COM(2023)217 - Proposal for a regulation of the European Parliament and of the Council on detergents and surfactants, amending Regulation (EU) 2019/1020 and repealing Regulation (EC) No 648/2004

Meeting with Andreas Glück (Member of the European Parliament)

30 Nov 2023 · Detergents regulations

Meeting with Martin Hojsík (Member of the European Parliament) and ECOLAB and World Resources Institute

28 Nov 2023 · GLOBE EU event

Meeting with Martin Hojsík (Member of the European Parliament, Shadow rapporteur)

17 Nov 2023 · Detergents regulation, feedstock

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur) and Bureau Européen des Unions de Consommateurs

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

Meeting with Catharina Rinzema (Member of the European Parliament, Shadow rapporteur for opinion)

12 Oct 2023 · Detergent regulation

Meeting with Andrus Ansip (Member of the European Parliament, Rapporteur) and Bitkom e.V. and Independent Retail Europe (formerly UGAL - Union of Groups of Independent Retailers of Europe)

27 Sept 2023 · Green Claims

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur) and Confederation of European Paper Industries and Lineage Dutch Coöperatief U.A.

27 Sept 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Meeting with Pascal Canfin (Member of the European Parliament)

21 Sept 2023 · Green Deal

Meeting with Maria Arena (Member of the European Parliament, Shadow rapporteur)

13 Sept 2023 · Detergents

Meeting with Clara Aguilera (Member of the European Parliament)

13 Sept 2023 · Sustainable Agriculture

Meeting with Krzysztof Hetman (Member of the European Parliament)

12 Sept 2023 · Exchange of views on CLP and Green Claims (meeting delegated to parliamentary assistant)

Meeting with Dacian Cioloş (Member of the European Parliament)

12 Sept 2023 · How to better engage farmers in cooperating with food producers on regenerative agriculture practices

Meeting with Manuela Ripa (Member of the European Parliament, Rapporteur) and ALTERTOX

12 Sept 2023 · Detergents Regulation

Meeting with Martin Hojsík (Member of the European Parliament, Shadow rapporteur) and SEC NEWGATE EU and Energizer

11 Sept 2023 · Detergents Regulation

Meeting with Pascal Canfin (Member of the European Parliament) and Nestlé S.A. and

29 Jun 2023 · Green Deal

Meeting with Janusz Wojciechowski (Commissioner) and

28 Jun 2023 · Geo-political importance of food, contribution of agriculture/food to success of the European Green Deal and the EU’s global competitiveness

Unilever urges ambitious 95% EU emissions reduction target

23 Jun 2023
Topic — The European Commission is consulting on setting an emissions reduction target for 2040.
Message — Unilever calls for a 90-95% emissions reduction target for 2040. They recommend separate removal targets and phasing out fossil fuel subsidies by 2025. They also support eco-design measures to limit emissions embedded in consumer products.123
Why — These policies would de-risk green investments and force necessary shifts in chemical supply chains.45
Impact — Fossil fuel companies would lose significant financial support through the proposed 2025 subsidy phase-out.6
Read full response

Meeting with Nils Torvalds (Member of the European Parliament, Rapporteur) and DRUŠTVO SVETOVNO OMREŽJE ZA ZELENO INFRASTRUKTURO WGIN and Gothenburg European Office

5 Apr 2023 · Urban wastewater treatment

Meeting with Deirdre Clune (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and

29 Mar 2023 · Stakeholder Consultation on Urban Waste Water Treatment Directive

Meeting with Margrete Auken (Member of the European Parliament, Shadow rapporteur)

13 Mar 2023 · Recast of the UWWTD

Meeting with Martin Hojsík (Member of the European Parliament)

2 Mar 2023 · Packaging and packaging waste

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and A.P. Møller - Mærsk A/S and

9 Feb 2023 · Revision of the Regulation on CO2 emissions standards for HDVs

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and

26 Jan 2023 · CO2 emission standards for HDVs

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans) and ELECTRICITE DE FRANCE and

6 Dec 2022 · Green Deal state of play

Meeting with Sara Matthieu (Member of the European Parliament, Shadow rapporteur) and Procter & Gamble

24 Nov 2022 · Ecodesign regulation

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

16 Nov 2022 · Framework for setting eco-design requirements for sustainable products

Unilever urges EU to accept non-animal safety testing data

18 Oct 2022
Topic — Revision of EU chemical classification rules to include new hazard categories.
Message — Unilever requests that the EU fully consider the use of non-animal New Approach Methodologies in chemical safety assessments. They argue the law should ensure the most relevant science is used so that animal testing is always a last resort.12
Why — Unilever would leverage their extensive internal expertise in non-animal safety assessment methodologies.3
Impact — Traditional animal testing facilities would lose their status as the primary source for safety data.4
Read full response

Meeting with Adriana Maldonado López (Member of the European Parliament, Shadow rapporteur for opinion)

18 Oct 2022 · Reglamento de Ecodiseño

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

18 Oct 2022 · Circular economy and rules on substantiating green claims

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis) and Dow Europe GmbH and

12 Jul 2022 · Packaging and Packaging Waste Directive

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius), Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius)

8 Jul 2022 · Implementation of the EU Chemicals Strategy for Sustainability, the revision of the Packaging and Packaging Waste Directive, replacing fossil carbon with renewable carbon

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

8 Jul 2022 · Implementation of the EU Chemicals Strategy for Sustainability, the revision of the Packaging and Packaging Waste Directive, replacing fossil carbon with renewable carbon

Meeting with Cyrus Engerer (Member of the European Parliament)

14 Jun 2022 · Circular Economy

Meeting with Pascal Arimont (Member of the European Parliament)

9 Jun 2022 · Revision of the Renewable Energy Directive

Meeting with Malte Gallée (Member of the European Parliament, Shadow rapporteur)

8 Jun 2022 · Ecodesign for Sustainable Products Reg / chemical products

Meeting with Frans Timmermans (Executive Vice-President)

24 May 2022 · European Green Deal and Circularity

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

6 May 2022 · European Green Deal and nature restoration

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans), Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

27 Apr 2022 · European Green Deal

Meeting with Tom Berendsen (Member of the European Parliament, Rapporteur)

21 Feb 2022 · Industry Strategy - Meeting with APA

Meeting with Pascal Canfin (Member of the European Parliament)

18 Jan 2022 · Green Deal

Response to Sustainable food system – setting up an EU framework

26 Oct 2021

Please find Unilever's feedback in the attached document.
Read full response

Response to Food waste reduction targets

25 Oct 2021

Food waste is a missed opportunity to feed an ever-increasing global population, a major waste of resources and a needless source of increased emissions. As one of the world’s biggest food companies, Unilever clearly sees the role we have in protecting and preserving food to feed the world sustainably. Last year we committed to halving food waste across our global operations from factory to shelf by 2025, five years earlier than the ambition put forward by the UN Sustainable Development Goals. Our priority is to prevent food loss, surplus and waste from occurring from the beginning and to drive out resource inefficiency within our supply chains. Where surpluses cannot be avoided, we work to redirect food to feed people in line with the food waste hierarchy. Tackling food waste is a central tenet of the Farm-to-Fork Strategy, therefore Unilever welcomes the European Commission’s initial consultation to provide input to the IIA on a proposal of EU-level targets for food waste reduction, which are expected to be set/adopted Q2 of 2023. Bearing the above in mind, before setting food waste targets we call on policymakers: -To further develop EU guidelines and training tools to help implement the Delegated Act on food waste measurement adopted in 2019. These guidelines could encourage and assist the different actors in the supply chain with interpreting the data and reporting to Member States (MS). -To carefully assess MS data collected from the two first reporting years (2020-2022) since it is the first time MS, alongside organisations in the supply chain, are engaged in such a comprehensive exercise. -To carry out thorough and scientifically based Impact Assessments on the policy measures/options proposed, taking into consideration the various actors in the food supply chain alongside the three pillars of sustainability. The impact assessments should also focus on trade-offs (i.e., packaging v food waste). -To further encourage and build upon, at EU and MS level, the efforts undertaken by the various actors of the food supply chain to reduce and prevent food waste, including by the food and drink industry. It is important to note that some actors might have taken effective waste reducing actions in the past which means further implementing measures need to be even more efficient to effectively tackle the problem. Unilever will continue to share their knowledge and expertise, as appropriate, especially within the new mandate of the EU Platform on Food Losses and Food Waste starting in 2022.
Read full response

Response to Revision of Regulation (EC) 648/2004 on Detergents

19 Oct 2021

The Detergent Regulation provides a platform for advanced protection of consumers and the environment, by enshrining industry’s voluntary approaches (e.g. phosphate restrictions) into a consistent, coherent and progressive sector-specific legislation. Overall, we believe consumer-centric legislation supports consumers to use products safely, effectively, and appropriately, whereas horizontal legislation such as REACH or CLP focus on restricting the use, rather than empowering consumers to make sustainable choices and to use the product safely, effectively, and sustainably. CLP is limited to providing hazard-based information on the product and some of its constituents, linked to precautionary information that consumers can often not act upon nor understand. Therefore, we generally believe that EU consumers’ interests are best served by maintaining sector-specific legislation, in particular the Detergent Regulation, rather than it being absorbed into broader pieces of legislation such as REACH. For this reason, we believe that the current regulation should be maintained and have identified some areas for further optimisation. Biodegradation The Detergent Regulation has been instrumental in environmental protection through its requirement on biodegradation for surfactants, well before REACH came into existence. At Unilever, we aim to use 100% biodegradable ingredients by 2030, globally. We therefore believe that the time is right to expand biodegradation requirement to all organic chemicals used in detergents, of course allowing industry sufficient time to convert. Such biodegradability requirements should typically demand ultimate biodegradability of the molecules within a given time-frame relevant to the different substances used. For example, dedicated methods for polymers might be required. By demanding biodegradability of all organic chemicals used, the Detergent Regulation could again be at the forefront of protection of the environment. Simplification of labelling Different pieces of research have shown that consumers fail to understand some of the labelling information e.g. CLP pictograms, and struggle with the amount of information associated with these. Besides, there are overlaps between labelling requirements under the Detergent and CLP regulations that may further increase confusion and open the door to possible inconsistencies. Therefore, we would propose a simplification of labelling requirements under the Detergent Regulation to focus on consumer relevant safety information that is specific to detergent products, in a way that is easy to understand, and that can actually be used by consumers. Digitalisation of labelling information We believe that the development of digital technologies is an opportunity to provide tailored, actionable, and detailed information to consumers. Not only can it help in preventing overload of information on the packs, it can also be instrumental to meet the demands of specific consumers that are unable to read what’s on pack or need dedicated information quickly (e.g. on allergens). Moreover, future sustainable consumption modes designed to reduce packaging like in-store re-filling and at home refills may even more rely on digital information to correctly inform consumers. As ways of doing shopping continue to evolve, the digitalisation of information is becoming even more important. The Detergent Regulation has been a pioneer in this area, requiring both on-pack and digital information on products since 2005. Further expanding the provision of digitalisation of information to consumers would be a logical step to keep the Detergent Regulation future proof. Concluding, the Detergent Regulation is a consumer-oriented legislation that is fit for purpose and effective. It has positively served the needs of consumers and all stakeholders and can be further optimised in full alignment with the objectives of the EU Green Deal and other upcoming initiatives.
Read full response

Response to Restoring sustainable carbon cycles

7 Oct 2021

Unilever fully supports and agrees with the aim of the roadmap on “Restoring sustainable carbon cycles”: achieving climate neutrality objectives cannot only rely on decarbonising our energy and transport sectors, but also requires solutions for capturing carbon dioxide from the atmosphere and durably storing it or using it in products. We believe that restoring, but most importantly defining, sustainable carbon cycles will support EU climate and circular economy objectives, while providing the right incentives for the industry to further engage on a climate neutrality pathway. At Unilever, we have committed to replacing 100% of fossil carbon derived chemicals in our cleaning and laundry product formulations with renewable or recycled chemicals, since the chemicals used in our cleaning and laundry products contribute >40% to the total life cycle GHG footprints (46%) of these products. We have been investing in various projects using these new technologies in Europe and throughout the world. Based on our experience so far, we agree with the Commission’s conclusion that incentives are lacking to create a competitive industrial market for moving away from virgin fossil carbon sources. Furthermore, the absence of policies tackling embedded carbon or the replacement of virgin fossil fuels in products, as well as incentives offered to the fossil fuel industry such as production subsidies and unpriced externalities, have made it difficult for common technologies and intermediate feedstocks to be cost effective. We need coherent incentives and an enabling legislative framework to discourage the continued use of virgin fossil carbon for the carbon embedded within raw materials/chemicals. In this regard, we believe that the upcoming Communication on ‘Restoring sustainable carbon cycles’ and the subsequent proposal on carbon removal certification, as well as remuneration of carbon sinks under the EU ETS, will help unlock some of the challenges in creating functioning markets for renewable and recycled carbon. This should also be supported by other upcoming policy initiatives, such as the EU Sustainable Products Initiative. Therefore, we would recommend that upcoming EU climate and circular economy policies and initiatives ensure: 1/ The integration of renewable and recycled carbon as a policy tool by (a) Adopting a common, science-based definition of renewable and recycled carbon; (b) Recognising the role of different technologies (such as chemical recycling, carbon capture and utilisation, etc.) as well as clearly identifying potential synergies and trade-offs with other environmental objectives; (c) Establishing a roadmap for sustainable carbon cycles that includes a carbon hierarchy to guide the allocation of carbon; and (d) Developing a clear methodology to determine what qualifies as carbon removal and carbon sequestration, as announced in the roadmap. 2/ The stimulation of the supply and creation of a demand for final products containing renewable and recycled carbon by (a) Pricing energy and non-energy ‘black’ carbon emissions; (b) Integrating fossil fuel-derived content limit on final product; and (c) Driving investment towards forward-looking technologies that can drive down the cost of using renewable and recycled carbon. Diversifying sources of carbon is essential to grow within the limits of our planet. Shifting away from fossil fuels and removing carbon dioxide from the atmosphere through nature-based and technological solutions will be critical to close the gap to climate neutrality. Unilever is committed to these objectives and is looking forward to working together with EU policymakers on defining and restoring sustainable carbon cycles. Please see more details in the paper attached.
Read full response

Meeting with Janusz Wojciechowski (Commissioner) and

27 Jul 2021 · Unilever commitments to the EU Code of Conduct as well as their Regenerative Agriculture Practices Code.

Response to Clarification of requirements for the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)

19 Jul 2021

Unilever believes that every product we make must be safe for people to use and to manufacture and must be safe for our planet. We also believe that animal testing is not the way to ensure that our products are safe. We fully recognise and respect the importance of REACH and other EU chemical regulations to guarantee the protection of EU citizens and the environment. However, the proposed amendments to Annex VII to X of REACH raise some concerns about generation of unnecessary animal testing data, with changes that would go beyond simple clarifications of unclear or inconsistent wording in the annexes, as indicated by the Commission. Furthermore, such changes are also pre-empting the output of the impact assessment associated with the Chemical Strategy for Sustainability (see Unilever’s input to the REACH Inception Impact Assessment: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12959-Chemicals-legislation-revision-of-REACH-Regulation-to-help-achieve-a-toxic-free-environment/F2333019_en). As Unilever we stand ready to work together with EU authorities on the REACH review to ensure the application of the best available science to ensure high standards of consumer, worker and environment protection in Europe. Regarding the proposed changes to the Annexes, we are concerned that mandating registrants to generate animal data when non-animal approaches are available goes against the EU’s commitment to the use of science-based application of non-animal approaches to safety as outlined by Directive 2010/63/EU and Article 25 of REACH. If implemented, these changes will lead to the need for registrants to conduct new, redundant vertebrate animal testing in contradiction with Article 25 of REACH on the minimisation of vertebrate animal testing and the recent European Court of Justice ruling (see: https://curia.europa.eu/juris/document/document.jsf;jsessionid=D70A05AE36DF9FDE77F110D921E5C90F?text=&docid=236724&pageIndex=0&doclang=en&mode=lst&dir=&occ=first&part=1&cid=8810521) confirming that non-animal approaches should be the first consideration and that justification should be needed if an animal test is the only way to fill an information requirement. The proposed amendments also ignore the fact that, in many cases, animal testing is no longer considered a gold standard, and scientifically based non-animal approaches provide robust information for decision-making and to fulfil the ultimate goal of REACH, i.e. to provide high protection for human health and environment. Unilever’s detailed input is summarised in the attached document. We would encourage the European Commission to champion the use of modern, non-animal safety science and reflect it in its proposed amendments to REACH Annexes but also as part of the revision of REACH under the Chemical Strategy for Sustainability, and we stand ready to continue to share our experience in this area with relevant stakeholders.
Read full response

Meeting with Pascal Canfin (Member of the European Parliament) and Société nationale SNCF

29 Jun 2021 · Green Deal

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and Nestlé S.A. and Danone

8 Jun 2021 · EU Code for responsible business and marketing practices

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides) and Nestlé S.A. and Danone

8 Jun 2021 · VTC Meeting - Code of Conduct on responsible food business and market practices

Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

1 Jun 2021

Unilever is committed to making sustainable living commonplace and therefore we welcome the Commission’s initiative to review the CLP Regulation as part of the EU Green Deal (EGD) and the EU Chemicals Strategy for Sustainability (CSS). We have applied a safe-and-sustainable-by-design approach for over 20 years and have a responsibility to ensure that every product we make is safe for our consumers, the workers who make them and for the environment. Therefore, we are fully aligned with the EGD ambition but we are concerned that the proposed new information requirement in regulatory (eco)toxicology will highly increase the need for new animal testing (millions more animals will be required for new tests) with no benefit for protecting human health or the environment. It is our strong belief that we can protect people and our planet whilst still enabling EU innovation, but to do so our safety and sustainability assessments must be exposure-led and use next generation, non-animal approaches based on modern science. This general principle also applies to the definition of new classes and criteria. We are concerned by the Commission’s intention to revise and introduce new hazard classes under CLP – namely Endocrine Disruptors and criteria for immunotoxicity and neurotoxicity as well as for Persistent Chemicals (vPvB, PBT, PMT, vPvM) – without upfront agreement with UN GHS, since none of these classes are defined at UN GHS level. The EU should set the right example on the world stage by proposing hazard classes and criteria first at the UN GHS, to ensure harmonisation and global leadership. We are also highly concerned that new demands in classification & labelling could increase the need for new data based on animal testing, with no benefit for protecting human health or the environment. It is paramount to make safety decisions on ingredients using the best science, considering all available existing (eco)toxicology data without generating new data requiring animal testing. We believe that this is a unique opportunity for EU to lead at UN level on the proposal of new hazard classification criteria that are not based on apical adverse effect endpoints observed on animals, but rather to define new criteria using next generation, non-animal approaches based on modern science. Labelling should be meaningful to and optimised for consumers. We understand an obligation to provide information of some hazards on the label for products currently outside the scope of CLP is being considered. We do not believe CLP hazard communication to consumers is the best way to help them use a product in a safe and sustainable way. Before considering such options, all evidence of consumer relevance and understanding of any proposed measure should be thoroughly considered. We positively acknowledge the plan to improve the implementation/applicability of CLP rules on multilingual labels (e.g. fold outs). We welcome any initiative to facilitate multi-lingual labelling and will be willing to contribute with possible options in this area (including development of new supporting pictograms where feasible). We also believe more ambitious steps should be taken to leverage the benefits of digital communication, in the interests of clearer, simpler, and more targeted information to consumers. We encourage the Commission to make the most of the opportunities offered by technology to differentiate the communication needs of consumers/end users from those needed for enforcement purposes. Finally, realistic transition periods should be foreseen for any newly introduced requirements, for industry to be able to comply without jeopardising other sustainability objectives of the EGD (e.g. waste of stock materials) and considering complexity and timelines of the full supply chains. As Unilever we stand ready to work together with EU authorities on the CLP review to ensure appropriate safety and information of consumers, and protection of the environment.
Read full response

Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

Unilever is committed to making sustainable living commonplace and welcomes the Commission’s initiative to review the REACH Regulation as part of the EU Green Deal (EGD) and the Chemicals Strategy for Sustainability. We have applied a safe-and-sustainable-by-design approach for over 20 years and have a responsibility to ensure that every product we make is safe for our consumers, the workers who make them and for the environment. Therefore, we are fully aligned with the EGD ambition but we are concerned that the proposed new information requirement in regulatory (eco)toxicology will highly increase the need for new animal testing (millions more animals will be required for new tests) with no benefit for protecting human health or the environment. It is our strong belief that we can protect people and our planet whilst still enabling EU innovation, but to do so our safety and sustainability assessments must be exposure-led and use next generation, non-animal approaches based on modern science. Sadly, far too little progress has been made in Europe on regulatory acceptance of non-animal methodologies, despite the huge research investment (est. > €1Bn) by the Commission and industry over the past 20 years. We see the REACH review as a unique opportunity to break free of the belief that animal models are the best experimental tool available to protect citizens or the environment, which is increasingly demonstrated not to be the case, and additional investment in ECHA is needed to ensure they have the resources and scientific knowledge to support an increased use of New Approach Methodologies (NAM) under REACH. Unilever is ready to share the knowledge and expertise it has acquired in this field, and we fully support the EPAA (particularly the new ‘NAM project’) as a multi-stakeholder platform to facilitate this scientific exchange of views and to close the gap between global mechanistic safety science and EU chemical regulatory approaches. Rapid adoption of non-animal methods aligns with the EU’s animal welfare agenda, the REACH regulation and will support sustainable chemical innovation, ensuring the EU’s competitiveness globally. We advocate for a science-based approach, including exposure assessment as the best way to protect consumers, workers and the environment without any need for new animal testing. Chemicals’ safety assessment should reflect both hazard and exposure (i.e. safe use). The rationale for any change to this approach should be properly discussed and justified, and subject to proper scrutiny and impact assessment as regards to their benefits to citizens’ safety and the environment. We agree that the risk of exposure to the combined effects of several substances is an important factor to consider, but the introduction of a Mixture Assessment Factor (MAF) should be based on the latest scientific approaches which will bring more realism in the assessments and be applied on a case-by-case basis. We have concerns over the reform of the restriction process, with the extension of the generic risk approach to new hazard categories simply based on a substance belonging to a hazard class. Should this approach be pursued, a proper process and definition of the criteria for hazard classification as well as an adequate definition and implementation of the concept of essentiality will be critical. Finally, Unilever welcomes the establishment of a more consistent and joined-up approach to enforcement controls, especially on e-commerce and imports, to protect the Single Market. We also believe that the development of a strategic research and innovation agenda for chemicals can be achieved with benefits for all, but only if the most advanced science can be used to facilitate the identification of appropriate solutions. As Unilever we stand ready to work together with EU authorities on the REACH review to ensure appropriate safety and information of consumers, and protection of the environment.
Read full response

Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius) and European Youth Forum and

21 May 2021 · Presentation on radical decarbonisation

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Youth Forum and

21 May 2021 · Presentation on radical decarbonisation

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and Nestlé S.A. and Danone

17 May 2021 · EU code of conduct for responsible marketing and business practices

Meeting with Anouk Faber (Cabinet of Commissioner Nicolas Schmit), Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit)

30 Apr 2021 · Meeting on the Pact for Skills.

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and Nestlé S.A. and Danone

26 Apr 2021 · Dairy denominations

Meeting with Pascal Canfin (Member of the European Parliament)

25 Mar 2021 · Green deal

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans), Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

25 Feb 2021 · Implementation of the EU Circular Economy Action Plan and Farm to Fork Strategy

Meeting with Nicolas Schmit (Commissioner) and

18 Feb 2021 · Pact for Skills roundtable with the representatives of agri-food sector.

Meeting with Thierry Breton (Commissioner) and

18 Feb 2021 · Pact for Skills roundtable with the representatives of agri-food sector

Response to List of composite products exempted from official controls at border control posts

1 Feb 2021

Unilever would like to thank the Commission for the opportunity to provide feedback on this proposal. Since the United Kingdom exited the European Union on 1 January 2021 there has been a surge in composite products entering Border Control Posts from the UK into EU. Many of the importing Food Business Operators (FBOs) historically have primarily operated within the single market and so are encountering the legislation pertaining to composite products for the first time. The new draft regulation as presented will cause a lot of uncertainty about which products are exempt from official controls according to Decision 2007/275/EC. By limiting the exempted commodities to only those listed in the Annex, it will exclude many other commodities not listed in the Annex but which were previously exempt by virtue of meeting the criteria provided in Article 6, paragraph 1 (a) of Decision 2007/275/EC. Yet such previously excluded products would also not fall under Article 4 and Annex I of Decision 2007/275/EC, creating ambiguity and complexity for food business operators and border control posts alike as to their requirements for official certificates and controls. By repealing and limiting only Article 6 and Annex II of Decision 2007/275/EC (which provide the exemptions) and not amending Article 4 and Annex I which provide the rule and refer to Article 6, it creates an unworkable situation for products that do not fall under either. It is also incongruent with the animal health requirements for composite products laid out in Articles 162 and 163 of Commission Delegated Regulation (EU) 2020/692 and the corresponding model official certificate and private attestation for composite products laid out in Commission Implementing Regulation (EU) 2020/2235. The article which causes more uncertainty is article 4.c of this decision because without reference to article 6, it becomes unclear if all the products exempted previously according article 4c of Decision 2007/275 are still exempt or not. Furthermore, we urge the proposed definition of “shelf-stable composite products” to include composite products which are transported, stored and consumed frozen (e.g. ice creams), since such products pose the same low level of microbiological and animal health risk as ambient products. In fact, it is forbidden to add preservatives in ice creams due to their built-in microbiological stability as frozen. Considering the above risks of misinterpretation, in combination with current import delays experienced at the ports due to IT issues, Covid-19 impacts and documentary requirements, may result in an increasing number of loads requiring inspection on previously exempted products which have not shown any special risk. In summary, 1- We ask the Commission to maintain the exemption for composite products according to current Article 4c and Article 6, paragraph 1(a) of Decision 2007/275/EC. 2- We ask the Commission to amend the draft regulation to also indicate the changes required in the parts of Decision 2007/275/EC which currently refer to the Article 6 and Annex II. 3- We ask the Commission to change the proposed definition of “shelf-stable composite products” to include composite products that are frozen and intended to be consumed frozen. 4- We ask the Commission to set up guidance to clarify which composite products need pre-notification procedures, official certificates and private attestations. 5- We ask the Commission for more time to implement all the significant changes in process an documentation for importing composite products into the EU
Read full response

Meeting with Frans Timmermans (Executive Vice-President) and Shell Companies and

13 Jan 2021 · Roundtable on the Green Deal, organised by the Dutch Sustainable Growth Coalition, with the participation of the Dutch Prime Minister and other Dutch Government Ministers.

Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius), Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius)

12 Oct 2020 · To discuss recycled carbon and clean future, the chemicals strategy for sustainability and plastic packaging

Meeting with Thierry Breton (Commissioner) and

16 Apr 2020 · COVID crisis: exit and recovery of the agro-food ecosystem

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

4 Mar 2020 · Sustainable food systems

Meeting with Frans Timmermans (Executive Vice-President) and Ingka Services A.B.

23 Jan 2020 · Opportunities and collaboration on the European Green Deal

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

25 Oct 2019 · discussion on Sustainability and circular economy

Response to Amending Regulation (EC) No 1272/2008 relating to emergency health response

15 Aug 2019

Unilever, as a producer of consumer detergents and cleaners, strongly supports the proposed delay of the implementation of Annex VIII till 1st Jan 2021. It is felt that this is absolutely required in order to adapt our systems to be able to comply with the rather extensive reporting requirements that are being imposed on suppliers. Also, we welcome the opportunity that is now offered under Section 5.2 to print UFI directly on pack, rather than only on the label, as this provides flexibility to print the UFI on the inner pack at the filling and packaging lines. We are concerned that the reference to placing the UFI on inner packaging, that has been proposed earlier for this amendment, has not been retained in the current text. Having to place the UFI on all layers of packaging including the outer case will require much more frequent changes to the outer pack printing as UFI codes will change more frequently than actual CLP label changes, and thus presents an additional burden to the industry. Furthermore, it will not be of use in case of incidents, as the inner packaging with the UFI will always be present in such cases. We would further call on the Commission to use the extra time before the deadline to clarify some of the remaining issues like around Mixture in Mixture reporting and to significantly improve on the IT reporting systems that are being set-up by ECHA.
Read full response

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

4 Jun 2019 · discussion on circular economy and sustainable development

Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella)

4 Jun 2019 · Unilever Sustainability and SDGs

Meeting with Jean-Eric Paquet (Director-General Research and Innovation)

25 Mar 2019 · Corporates and Ecosystems

Meeting with Anthony Agotha (Cabinet of First Vice-President Frans Timmermans)

4 Apr 2018 · Unfair trading practices in the food supply chain

Meeting with Isabelle Magne (Cabinet of Vice-President Cecilia Malmström), Maria Asenius (Cabinet of Vice-President Cecilia Malmström)

6 Jun 2017 · Trade's contribution to the Sustainable Development Goals / sustainability standards.

Meeting with Frans Timmermans (First Vice-President)

6 Jun 2017 · Sustainable Development Goals

Meeting with Vytenis Andriukaitis (Commissioner) and

12 May 2017 · Evolved pan-European nutrition labelling scheme

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and Nestlé S.A. and

4 May 2017 · The Evolved Nutrition Label initiative

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

8 Nov 2016 · Business discussion

Meeting with Robert-Jan Smits (Director-General Research and Innovation)

17 Oct 2016 · Innovation Union

Meeting with Věra Jourová (Commissioner) and

17 Oct 2016 · Consumer protection

Meeting with Julie Fionda (Cabinet of Commissioner Marianne Thyssen), Stefaan Hermans (Cabinet of Commissioner Marianne Thyssen)

17 Oct 2016 · Youth employment, the changing nature of work and skills

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)

23 Feb 2016 · speach on Circular Economy

Meeting with Ivan Prusina (Cabinet of Vice-President Neven Mimica), Maria-Myrto Kanellopoulou (Cabinet of Vice-President Neven Mimica)

4 Feb 2016 · Discussing the role of the private sector in the implementation of Agenda 2030

Meeting with Dermot Ryan (Cabinet of Commissioner Phil Hogan)

9 Nov 2015 · presentation of Unilever’s sustainable sourcing strategy, our Sustainable Agricultural Code and our work with European (and non-European) farmers

Meeting with Maroš Šefčovič (Vice-President) and

30 Oct 2015 · creation of a network of Energy Union Business Ambassadors

Meeting with Frans Timmermans (First Vice-President)

1 Oct 2015 · Circular Economy

Meeting with Karmenu Vella (Commissioner)

30 Sept 2015 · Circular Economy, Sustainable Development Goals

Meeting with Carlos Moedas (Commissioner)

30 Sept 2015 · Circular Economy and Food Research in Horizon 2020

Meeting with Neven Mimica (Commissioner) and

30 Sept 2015 · Outcome of the Addis “Financing for Development” International Conference and New York Post-2015 Summit. Business contribution to the implementation of the Sustainable Development Goals. Perspectives on the implementation of the Sustainable Development Goals in Europe.

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen), Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

5 Jun 2015 · Single market

Meeting with Robert-Jan Smits (Director-General Research and Innovation)

8 May 2015 · State of Play in developments food industry PPP

Meeting with Sandra Kramer (Cabinet of President Jean-Claude Juncker)

7 May 2015 · Political priorities of this Commission

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)

25 Mar 2015 · Circular Economy

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

25 Mar 2015 · Circular Economy

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

25 Mar 2015 · Circular economy

Meeting with Elżbieta Bieńkowska (Commissioner) and

2 Feb 2015 · Introductory meeting: single market legislation & circular economy package

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)

2 Feb 2015 · Investment plan and sustainability

Meeting with Luc Tholoniat (Cabinet of President Jean-Claude Juncker)

8 Jan 2015 · Economic and industrial priorities of the EU