Empowering consumers for the green transition

Pre-contractual information is key to ensure consumers make informed purchasing decisions. The Commission proposal on empowering consumers in the green transition aims to provide those consumers with an additional set of information and protect them from “greenwashing”.

Svenska Handel (SH), the trade association representing 9 000 small, medium-sized and large companies with almost 300 000 employees, would like to make the following comments. Further comments can be found in the Annex.

Filed in Swedish · English published by the European Commission

The Trade Mark Union is aware of the proposed revision of the Unfair Commercial Practices Directive aimed at empowering consumers to act in favour of the green transition through better protection against unfair practices and better information. The Commission would like to comment in the attached document.

Filed in French · English published by the European Commission

We welcome the opportunity to provide preliminary feedback on the Proposal for a Directive on empowering consumers for the green transition through better protection against unfair practices and better information. Ecommerce Europe welcomes the European Commission’s work on harmonising and clarifying how existing consumer legislation applies to environmental claims and sustainable aspects of products and services.

Essity is a leading global hygiene and health company with sales in approximately 150 countries and about 46,000 employees (about 1/3rd in the EU). Through our continued efforts to make more from less, increase circularity and well-being we help customers and consumers make more sustainable choices.

Priority must be given to any impact on Human, Plant, Animal Health whilst considering the climate. Without vital disclosure on labels, whereby should the information have been supplied, the consumer might not have purchased would be illegal. Examples such as when Anti-Biotics are in materials, products, foods, clothing etc.; when plastic as well as re-cycled plastic is in clothing, food etc.

To whom it may concern, Contribution by MPOC The Malaysian Palm Oil Council (MPOC) looks with interest and cooperative spirit to the EU’s ‘feedback period’ regarding the Commission’s Proposal for a Directive of the European Parliament and of the Council amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition through better protection against unfair practices and better…

Back Market welcomes the Commission’s ambition to provide consumers with reliable information on the repairability, durability, and marketing of products sold on the EU market via the Empowering Consumers Initiative.

As part of the new Consumer Agenda launched in June 2020, the European Commission has chosen to revise Directives 2011/83/EC on consumer rights and 2005/29/EC on unfair commercial practices. MEDEF wishes to comment in the attached document.

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ECOS welcomes the European Commission’s proposal on strengthening the role of consumers in the green transition, notably the ban on unsubstantiated generic claims, new information requirements on product durability and repairability, and stronger regulation of labels and information tools.

Right to Repair Europe welcomes the proposed amendments to the Unfair Commercial Practices Directive and the Consumer Rights Directive as a first step to reduce obsolescence and provide information on repairability. However, far stricter rules are needed to prevent business practices which unnecessarily and deliberately shorten the lifetime of devices. Our response to the proposals is as follows: 1.

ASOBIO, the Spanish Association of Ecological Manufacturers and Traders, supports the EC initiative COM (2022) 143 final amending directives on consumer protection. For ASOBIO, there is a need for specific regulation of the term ‘sustainability’ when applied to the food sector. Organic certification in food production should be the starting point for claiming sustainability of a food production or product.

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ISEAL supports ambitious sustainability systems and their partners to tackle the world’s most pressing challenges. ISEAL develops guidance on good practices and brings together a range of multi-stakeholder initiatives that manage sustainability labels or business-to-business claims.

Eurefas - the European refurbishment association - welcomes this initiative which ensures consumers will have more reliable information on product’s reparability, durability and the way it is promoted. To further accelerate the reuse of products - through refurbishment for example - and put them back into the circular economy loop, we suggest adding “reusability'' to the list of the product’s main characteristics…

The proposal is a step forward in promoting the green transition, but falls far short of what is needed to address early obsolescence and greenwashing and consumer protection against such practices. The proposal introduces obligations for traders to provide information on the reparability of their products, making it easier for consumers to seek and choose the most sustainable option.

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Ecopreneur.eu - the European Sustainable Business Federation - and its member organisations welcome the European Commission’s consumer protection initiative aimed at unmasking and inhibiting deliberate greenwashing and early obsolescence practices.

The Halte association with planned obsolescence (HOP) welcomes the European Commission’s intention to promote a new right to information on the durability and reparability of products and to ban greenwashing and planned obsolescence. However, in terms of concrete proposals, HOP believes that stricter and ambitious rules are needed to prevent practices that shorten the lifespan of devices.

Filed in French · English published by the European Commission

EACA welcomes the possibility to provide feedback on the initiative of the Proposal to amend Directive 2005/29/EC (“Unfair Commercial Practices Directive”). We strongly believe that the advertising sector plays a significant role in enabling consumers to make clear and educated choices and see the Proposal as the right approach to enhance consumer protection related to environmental claims.

The European Federation of Jewellery (EFJ) welcomes the European Commission’s proposed Directive on Empowering consumers for the green transition through better protection against unfair practices and better information.

foodwatch Germany welcomes the European Commission’s intention to restrict misleading environmental advertising. Such environmental claims and labels are now widespread in the supermarket. For Verbraucher:innen it is not clear on which statements are based. The draft presented by the Commission partly mitigates this, but leaves great loopholes for further confusion.

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The amendments proposed to the Unfair Commercial Practices Directive (UCPD) and the Consumer Rights Directive (CRD) are a step in the right direction to counter the lack of reliable information on products’ durability and reparability, early obsolescence and greenwashing.

ETNO welcomes the opportunity to comment on the European Commission’s proposal for a Directive on empowering the consumer in the green transition through better protection against unfair practices and better information. The core of our members’ business is the provision of digital infrastructure and connectivity.

In light of Amazon’s strong commitment to our customers and sustainability practices, we welcome efforts to protect and empower consumers against misleading claims and early obsolescence through simple and accessible information.

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.

The Norwegian Consumer Authority is supportive of the proposed changes to the Unfair Commercial Practices Directive and Consumer Rights Directive. It is a comprehensive proposal that is likely to significantly improve consumers' ability to make informed choices, and strengthen the enforcement capabilities of competent authorities in the face of greenwashing.

The Marine Stewardship Council is an international non-profit organisation that is GSSI benchmarked and ISEAL compliant. Our mission is to protect the oceans and safeguard seafood supplies for the future using our fishery certification scheme and ecolabel.

The European Ventilation Industry Association (EVIA) welcomes the opportunity to provide comments to the Commission proposal for a directive amending Directives 2005/29/EC (Unfair Commercial Practices Directive) and 2011/83/EU (Consumer Rights Directive) that was published as part of the Sustainable Products Initiative (SPI) on 30 March 2022.

AkzoNobel, the global paints and coatings company, is leading the path to integrate sustainability in the way we do business. We have set clear and far-reaching sustainability ambitions, made a firm commitment and set carbon reduction targets for our whole value chain, validated by STBi.

It is to be noted that the following comments do not reflect the official Austrian position on the proposal but represent the opinion of the Federal Ministry of Social Affairs, Health, Care and Consumer Protection (BMSGK). The dossier is being negotiated under the leadership of the Federal Ministry of Justice as well as the Federal Ministry of Digital and Economic Affairs.

The European Advertising Standards Alliance (EASA) welcomes the opportunity to provide feedback on the “Empowering consumers for the green transition”, and more specifically on the proposed amendments to the Unfair Commercial Practices Directive. About EASA Established in 1992, EASA represents and coordinates the advertising collective self-regulatory systems across Europe.

Independent Retail Europe welcomes the proposal for a Directive empowering consumers for the green transition through better protection against unfair practices and better information (COM(2022)143 final). We fully support the proposed obligation for a certification scheme for any environmental claim and the provisions on the sustainability information tool.

VIER PFOTEN / FOUR PAWS International welcomes the opportunity to provide feedback to the European Commission’s draft Directive Consumer policy – strengthening the role of consumers in the green transition. As an animal welfare organisation, FOUR PAWS has a genuine interest in empowering consumers to make informed purchasing decisions that contribute to more sustainable consumption, including higher animal welfare.

EUROPEN, the European Organisation for Packaging and the Environment, strongly supports the objective of the European Commission proposal for a Directive on empowering consumers for the green transition, which is to empower consumers through better protection against unfair commercial practices and better information on goods, services or digital contents they purchase.

AIM, the European Brands Association, welcomes the European Commission’s proposal on consumer empowerment for the green transition. It is broadly aligned with AIM’s position on green claims and sustainability information outlined in our Manifesto “No Data, No Claim”. Eliminating greenwashing is key to create a level playing field for businesses and truly empower consumers.

PepsiCo is committed to provide transparent information to consumers as part of its pep+ (Pepsico Positive) strategy and welcomes the Commission’s initiatives on green claims. We would like to offer observations on some possibly unforeseen consequences of the proposed measures and to suggest alternatives: 1.Different national interpretations of the EU provisions are a risk: While we welcome the harmonization that EU…

The International Fragrance Association (IFRA) supports the improvement of a European framework aiming at ensuring that consumers can actively contribute to the green transition, through the delivery of reliable information on consumer products, to make environmentally sustainable consumption choices and is actively participating in the meetings of the EU Ecolabelling Board.

EGMF - the European Garden Machinery Industry Federation, welcomes the opportunity to provide feedback on the European Commission’s legislative proposal on the ‘Empowering the consumer for the green transition’ initiative.

BEUC welcomes the proposal on empowering consumers for the green transition in which the Commissions proposed some targeted amendments to the Unfair Commercial Practices Directive (UCPD) and the Consumer Rights Directive (CRD). However, we still see some need for improvement.

The Trademark Association explicitly supports the proposal’s objective of a sustainable circular economy. Empowering consumers for the green transition through better protection against unfair practices and better information is essential for a sustainable circular economy. Many of the existing consumer legislation and instruments are already well suited to pursuing these objectives.

Filed in German · English published by the European Commission

The advertising industry supports the overall objective of the European Commission, which the present draft also pursues, to empower consumers for the green transition through better protection against unfair practices and better information. It is in the interest of both consumers and businesses to prevent misleading claims and to encourage the exchange of credible information.

Filed in German · English published by the European Commission

The German food industry is committed in particular to increasing transparency on the environmental footprint of food and drink — as a meaningful tool for a holistic assessment of the environmental performance of products — and to provide consumers with clear and reliable information.

Filed in German · English published by the European Commission

ZDH explicitly supports the proposal’s underlying objective of a sustainable circular economy. However, when achieving this objective, various factors must be considered. WE welcome the proposal to amend Directive 2005/29/EC (“Unfair Commercial Practices Directive”) as the right approach to protect against unfair commercial practices related to greenwashing and misleading environmental claims in general.

Filed in German · English published by the European Commission

Thank you for this consultation. L The initiative is commendable but doesn't get the problem right, since, in order to reduce our environmental footprint, the production of manufactured objects should be reduced as a matter of priority and significantly. In short, let’s start with a happy decrease and then make sure that the longevity of use and traceability are valued.

Filed in French · English published by the European Commission

The World Fair Trade Organization-Europe is formed by more than 100 members, among them Fair Trade Enterprises, Fair Trade networks and Fair Trade support organizations. We implement our Guarantee System and offer the WFTO label to assure that Fair Trade is implemented in the whole supply chain and within practices of our members, who are all mission-led social enterprises with built-in purposes for benefiting…

H&M Group applaud the European Commission’s ambition to enable customers across the European Union to choose more sustainable products based on trustworthy, clear, comparable and harmonized information. We share the European Commission’s objective to address a lack of common effective enforcement at European level, as well as customers’ confusion due to a multiplication of labels and claims.

The Swedish Refrigeration & Heat Pump Association (SKVP) are in general positive towards the proposed initiative to empower the consumer in the green transition. We believe the commission have highlighted several of the important areas were the rights and empowerment could be further improved.

Upfield welcomes the initiative to provide consumers with the information they need to make informed, sustainable choices, including through green claims and environmental product labelling. In order for these claims to be meaningful and promote transparency, they must show comprehensively communicated and absolute emissions values, rather than limiting transparency to comparisons within composition-based food…

We welcome the European Commission’s initiative to prevent greenwashing and early obsolescence through empowering consumers. Consumer legislation should support the objective “to make sustainable goods, services and business models the norm”. The overall focus must be on removing unsustainable products from the EU market, in the same spirit of ecodesign regulation.

The Forest Stewardship Council (FSC) welcomes the EU Roadmap and strives to support the EU Commission in enabling consumers to play an active role in the ‘green transition’. FSC is committed to give consumers reliable information on sustainable products across the EU, thus FSC calls the EU Commission to: 1.

EGMF welcomes European initiatives aiming to encourage more sustainable consumption patterns and empower consumers to participate in the Circular Economy and European Green Deal agenda. Quality, safety, and environmental performance are key priorities driving manufacturers of garden machinery and outdoor power equipment.

Please see attached pdf document - Bar Council of England & Wales feedback, Green Transition, in which we express our support for the Commission's objectives in the Green Transition, and make some preliminary remarks and suggestions regarding specific policy plans.

The European furniture industries embrace EU circularity objectives and are already transitioning to and promoting circular business models based on reuse, repair, refurbishment and remanufacturing of products. A true circular economy can only be achieved through collaboration and requires the involvement of many actors, including policy makers, industry, experts, academia and consumers.

The focus must be on removing unsustainable products from the EU market - not simply improving information provision and placing the burden on consumers to choose sustainable products. More direct attention should be given to products’ repairability. More specifically: 1.

EuroHealthNet is a not-for-profit partnership of organisations, agencies and statutory bodies working on public health, disease prevention, promoting health, and reducing inequalities. Between 2016-2019, it coordinated the Horizon 2020 INHERIT project, which looked at initiatives and policies that simultaneously improve health, the environment, and health equity – a “triple-win”.

The Rainforest Alliance welcomes the EU initiative on Empowering the Consumer for the Green Transition and recognizes the importance of providing clear and reliable information on sustainability claims. This is an important element of ensuring that consumers can make more sustainable choices.

ACEA, the European Automobile Manufacturers' Association, welcomes the opportunity to contribute to the initial roadmap consultation regarding the consumer policy and how strengthening the role of consumers in the green transition. In particular ACEA welcome policy option 2: a new stand-alone consumer protection instrument.

RREUSE welcomes the release of the inception impact assessment “Empowering the consumer for the green transition”. Tackling greenwashing and premature obsolescence is essential to improve the quality of products placed on the EU market and, in the long run, of second-hand products.

ISFE shares the European Commission’s conviction that achieving a more sustainable economy by tackling climate change is one of the most critical challenges of the 21st century and welcomes the opportunity to contribute to the roadmap consultation on the review of the consumer policy.

Thanks for the opportunity to give input. The Fair Trade Advocacy Office (FTAO) is a joint Fair Trade movement political advocacy initiative. Our goal is to make Fair Trade the norm in supply chains. More information> www.fair-trade.website and www.fairtrade-advocacy.org General remarks ● EU Consumers not only lack reliable and relevant information on the environmental performance of articles.

We welcome the European Commission’s initiative to prevent greenwashing and early obsolescence through empowering consumers. Consumer legislation should support the objective “to make sustainable goods, services and business models the norm”.

Please, find attached FEAD’s full feedback to the EC Roadmap on Empowering the Consumer for the Green Transition FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the European Commission’s initiative to empower the consumer for the green transition.

For 25 years, eBay has enabled millions of consumers and businesses to give a second life to goods. Whether through individuals selling items online that they no longer need, or by facilitating online access to spare parts for repair, eBay can be considered a key player in the circular economy.

Most important in the near future: The durability, reparability and recyclability of products should be promoted primarily through technical standards or industry self-commitments. If comprehensive labelling requirements are to be imposed on the durability or reparability of products, there is a risk that small and medium-sized enterprises in particular will be further restricted in their opportunities to innovate…

Filed in German · English published by the European Commission

The EEB welcomes the initiative “Empowering the consumer for the green transition”. Preventing greenwashing and early obsolescence are necessary priorities in the Green Deal, as well as Europe’s post Covid19 recovery. Consumer legislation should support the forthcoming sustainable products initiative, and its objective “to make sustainable goods, services and business models the norm”.

The European food and drink sector supports the Green Deal ambitions to make Europe the first climate-neutral continent by 2050 and to move towards more sustainable production and consumption. Consumers play a key role in this transition.

The European Cement Association CEMBUREAU welcomes the opportunity to provide feedback on the Commission inception impact assessment on empowering the consumer for the green transition. CEMBUREAU agrees with the consumer law initiative announced in the Green Deal to provide consumers the ability to make sustainable choices based on trustful environmental information and green claims.

Fashion Revolution welcomes the Commission’s initiative to prevent ‘greenwashing’ and provide consumers with useful and reliable sustainability information. Founded in the wake of the Rana Plaza disaster in Bangladesh, Fashion Revolution has become the world’s largest fashion activism movement, having mobilised millions of citizens, industry professionals and policy makers through research, education and advocacy.

1. GENERAL COMMENTS PepsiCo welcomes the opportunity to provide feedback on the Inception Impact Assessment on empowering consumers for the green transition. PepsiCo strongly supports the EU’s ambitions to reach climate neutrality by 2050 and towards a more sustainable food system.

iFixit welcomes the initiative to empower consumers for the green transition. Consumers wanting to purchase sustainable products and extend product lifetimes are dissuaded by a lack of reliable information, greenwashing and premature obsolescence.

Cefic welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission about a new legislative proposal on strengthening the role of consumers in the green transition in line with Better regulation principles and criteria (effectiveness, efficiency, relevance, coherence, EU-added value).

ENGIE welcomes the European Commission's initiative to enhance the empowerment of consumers in line with the Green Deal action plan. ENGIE Group is dedicated to supporting its clients' commitment to the green transition in many ways by helping our customers to use energy more efficiently and reducing their CO2 emissions through a broad range of solutions for energy and beyond.

A. Problems: 1 Consumers often lack reliable and relevant information at the point of sale on: • sustainability of products, e.g. environmental characteristics, expected or expected useful life, etc.; • the availability of repair services, spare parts and repair manuals; And • software updates/updates.

Filed in Spanish · English published by the European Commission

The testing, inspection and certification (TIC) sector welcomes the European Commission’s intention to strengthen the regulatory framework that will help consumers choose products with a full understanding of their environmental characteristics. In this respect, it is critical that the citizens can easily assess the validity of the environmental claims described on a product.

The European Advertising Standards Alliance (EASA) welcomes the opportunity to provide feedback on the Inception Impact Assessment on “Empowering the consumer for the green transition”, more specifically where it refers to issues of “greenwashing” or “environmental claims”. EASA strongly believes in the effectiveness of the advertising self-regulatory system in ensuring responsible commercial communications.

ISEAL feedback to the EC roadmap on ‘Strengthening the role of consumers in the green transition' ISEAL Alliance is the global membership organisation for credible, collaborative, and transparent sustainability systems. ISEAL currently brings together a range of different voluntary sustainability standards which manage reliable labels or b2b claims.

Feedback on the consumer policy – Empowering the consumer for the green transition FNADE, the french association for waste management welcomes this essential initiative that will invite each consumer to fulfill a role in the implementation of the Green Deal thanks to reliable and environmental sustainable information.

Please find enclosed the contribution of the Confederation of Small and Medium-sized Enterprises. SMEs are the French employers’ organisation for small and medium-sized enterprises in all sectors: Industry, services, trade, crafts and the professions.

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Edenred welcomes the European Commission’s plan to empower consumers for the green transition. It is urgent to implement a coherent policy action to strengthen offer and demand of sustainable goods and services.

Henkel puts the consumer at the heart of its business and thus supports the European Commission’s ambition to establish a sustainable product policy framework. With more than 185 production sites worldwide and around 20 billion Euros in sales in 2019, Henkel is leading globally in markets for Laundry and Home Care, Beauty Care and Adhesive Technologies solutions.

EMMA, the European Magazine Media Association and ENPA, the European Newspaper Publishers’ Association, together represent tens of thousands newspaper, magazine and news media publishers from across Europe who deliver press content to millions of EU citizens daily on a wide variety of digital platforms, as well as in print.

In order for the green transition to fully take place, consumers will have to play a much larger role in shifting to more sustainable consumption patterns, such as opting for repair over product replacement. With reference to the 2019 Sale of Goods Directive, APPLiA has long been a supporter of repair being first in the hierarchy of remedies to which consumers are entitled.

We want to express our enthusiasm for Empowering the consumer for the green transition initiative. Greenwashing as a marketing strategy, lack of correct information, as well as early and planned obsolescence are important barriers to address in transitioning to a more sustainable production and consumption system. We do however have some comments that we hope will be helpful in the further work, see enclosed file.

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.

The Association of Medical Device Reprocessors (AMDR) appreciates the Commission’s efforts to promote a green transition. We welcome the opportunity to provide feedback to the Inception Impact Assessment on Empowering the Consumer for the Green Transition. AMDR strongly encourages the Commission to amend existing consumer protection legislation OR create a new stand-alone consumer protection instrument.

DECO agrees that is urgently necessary to enable consumers to play a more important role in achieving the sustainable consumption. To make a valuable contribution to reaching the 2050 climate goals, we must all shift our consumption by 2030 at the very latest. Sustainable products and services must become the default choice, which is made easy, affordable, and most attractive for consumers.

A.I.S.E. recommends that the disclosure of environmental impact information should remain voluntary (and focused on internal company eco-design applications as opposed to product comparisons) until the methodology is mature and robust enough. An update of the 2013 Recommendation based on the outcome of the 2013-2018 pilot phase, should help clarify rules and responsibilities for market players.

Cosmetics Europe represents the cosmetics and personal care industry in Europe. The vast majority of Europe’s 500 million consumers use cosmetic and personal care products on a daily basis to protect their health, enhance their well-being and boost their self-esteem.

The TMUEN welcomes the initiative for a proposal for a directive to strengthen the role of consumers in the transition to a green economy. Consumers can make a not inconsiderable contribution to reducing the environmental impact of consumption. The provision of environmental information empowers consumers to make sustainable purchasing decisions.

Filed in German · English published by the European Commission

We support the Commission’s objective of promoting a more sustainable economy and conscious consumption. However, we consider the existing consumer law instruments to be absolutely sufficient for this purpose and do not see any need for a new adaptation of EU consumer law. Many of the regulatory ideas raised would have a far-reaching impact on the day-to-day business of the trading companies concerned.

Filed in German · English published by the European Commission

Health Care Without Harm (HCWH) Europe welcomes and supports the CEAP initiative to strengthen the role of consumers in the green transition by improving the availability of products environmental information and increasing protection against misleading claims. Regardless of which proposed policy option the European Commission agrees on, it is essential that healthcare products are considered.

EU action to improve durability, reuse and reparability of products while combating planned obsolescence is essential and welcome. Consumers are not yet aware of the problems of how to handle waste (packaging and end of life products) and they are unaware of the cost they bear.

Filed in French · English published by the European Commission

Energizer agrees that a clear and long-term perspective on consumer rights is necessary in order to empower consumers to be active participants in the green and digital transitions, to protect vulnerable consumers, to enforce consumer rights, and to ensure international cooperation.

ECOS welcomes the Commission’s initiative to empower consumers to play an active role in the green transition. Despite the clear preference of European consumers for more sustainable products, the absence of reliable information deprives from them of the opportunity to make informed purchasing decisions and fails to translate that preference into market demand and potentially market transformation.

BEUC strongly welcomes the announcement that the European Commission will be taking initiatives to empower consumers in the green transition through new information rights, protecting them from misleading practices and strengthening the enforcement of their rights. Such initiatives are urgently needed to allow consumers to play a more important role in achieving the sustainable consumption.

LEAF (Linking Environment And Farming) welcomes the Commission’s aim to support consumers choosing more environmentally responsible purchasing options based on reliable, robust information. This is increasingly critical with the impact of climate change and Covid-19. LEAF is a leading global organisation delivering more sustainable food and farming.

ELFAC, the European Confederation of LargeFamilies, gathering 26 associations from 23 European countries, represents households with three or more children. For our families, especially those with young children, it is of a great relevance to get easy access to important information such as those related to a product's sustainability.

Repair & Share is pleased that the European Commission intends to counter greenwashing and make it easier for consumers to make sustainable choices. This is urgently needed. Many people want to make sustainable choices, but too often conflict to lack of clarity and practical thresholds. Clear and correct information certainly plays an important role.

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As Board member of Union of Concerned Researhers in Fashion, I would like to point to the following input from a fello Board-member that sums up the main concerns around textiles https://timorissanen.wordpress.com/2020/08/02/land-as-a-defining-limit-for-fashion-production/.

EDANA agrees with the Commission that consumers are key in enabling the green transition. EDANA members, and certainly those downstream of the nonwoven value chain, realise this on a daily basis as they produce and market essential and ever-greener products. EDANA developed a Sustainability Vision, giving clear insight into the priority topics on sustainability for our industry.

On behalf of the European advertising and media associations it represents, the Advertising Information Group (AIG) welcomes the Commission's aim to meet consumer demand for sustainable products and services in the future through better and more uniform information. The provision of accurate, reliable, comprehensible and consumer-friendly information with regard to criteria such as reparability, shelf life, etc.

Independent Retail Europe stresses the importance for EU consumer policy being consistent. Please note that we will respond in more detail to the open public consultation of the New Consumer Agenda (deadline: 6 October) as well as the survey currently undertaken by ICF on this subject of consumer empowerment. We will therefore concentrate on some general comments on this Roadmap on the Inception Impact Assessment.

Fur Europe welcomes initiatives aiming at steering more sustainable consumption patterns and giving consumers an active role in the green transition. Fur Europe agrees to the need for a common set of consumer information requirements.

Enel welcomes the EC’s legislative initiative on empowering consumers in the green transition, as a very relevant piece of the Circular Economy Action Plan and European Green Deal agenda. Improving and promoting the environmental sustainability of products and services should be a strategic priority for both private sector and institutions.

The recent events recall the imperfections of our societies and questions our current consumption model and its limitations. During the recovery period to come, consumers will need more than ever to have durable products, while they might have a restrictive budget. Besides, we cannot ignore the scarcity of our resources any longer.

DIGITALEUROPE’s members have long led the way with environmental progress, and many have put forward ground-breaking commitments and programmes to deliver innovative products and services in a sustainable way. Our members empower consumers to take part in the circular economy through numerous strategies, including providing transparent information on the sustainability credentials of our products and services…

We appreciate the aim to strengthen the role of consumers in the green transition. We encourage policy makers to be aware that there are major differences between the consumer market and the professional (industry) market. When applying new rules, be careful not to impose requirements to the professional market that are not suitable for this sector. For both sectors, clear rules provide for a level playing field.

The inclusion of new digital technologies should be considered in the directive PROVIDING CONSUMERS WITH TRUSTWORTHY INFORMATION AT THE POINT OF SALE Consumers are exposed to the use of many digital systems and devices enabling them to interact with products. Protecting consumers from misinformation and outright counterfeit is of ever-growing importance. The costs associated with this development are staggering.