Substantiation and communication of explicit environmental claims (Green Claims Directive)
364 submissions from 320 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 788 submissions on this file. Shown here: the 364 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
CommitteeENVI
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Who showed up
263 submissions from industry — companies and their trade associations — against 62 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 4.2 industry submissions for every one from civil society.
Industry 263Civil society 62Public authorities, academia, other 39
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
184 of 320
in the EU Register
951
full-time lobbying staff
€104.7M+
declared costs a year
633
EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 21 Jul 2023 — it ran from 23 Mar 2023.
Travalyst Position Paper on the European Commission’s Proposal on the Substantiation and Communication of Explicit Environmental Claims July 2023 Travalyst, the international not-for-profit organisation that catalyses sustainability in travel and tourism, supports the European Commission’s efforts to create a harmonised set of criteria for the communication and substantiation of explicit environmental claims.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Paris, le 20 juillet 2023 Retour de l’ITAB sur la proposition de directive Green Claims Nous tenons à remercier la Commission Européenne pour cette proposition de directive, car elle vise notamment à lutter contre l'écoblanchiment, une pratique destructrice de valeur pour les entreprises engagées dans des trajectoires positives pour l’environnement et pour les produits véritablement soutenables.
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Paris, le 21 juillet 2023 CONTRIBUTION SUR LA PROPOSITION DE DIRECTIVE GREEN CLAIMS Nous tenons à remercier la Commission Européenne pour cette proposition de directive, car elle vise notamment à lutter contre le greenwashing, une pratique destructrice pour l’environnement, mais également destructrice de confiance, et destructrice de valeur pour les entreprises engagées dans des trajectoires positives pour…
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Minderoo welcomes the publication of the proposal for a Green Claims Directive as a positive step towards promoting transparent and accurate environmental claims in the European market. Indeed, Minderoo supports the general objective of this initiative, which is to unlock opportunities for the circular and green economy, including fostering the growth of green markets through value chain thinking and ensuring a more…
1. We support the aims of the proposal, the chosen policy options, the list of criteria for substantiation of explicit environmental claims and the requirement for third-party verification. We welcome the separation of claims verifiers from consultants validating ghg emissions quantifications and/or selling carbon credits. 2.
Clear Fashion is a company with a mission to bring transparency to the fashion sector. We believe that environmental labelling can have a strong impact on the sector, which is why it's so important for institutions to look into the subject and promote this information for consumers.
Thank you for this initiative which will help Europeans make the best purchases and promote the virtuous industry. This contribution is written by 4 expert structures that have helped hundreds of companies on environmental claims or eco-design (La Belle Empreinte, Green Score Capital, Clear Fashion and Good Fabric).
Filed in French · English published by the European Commission
Thank you for this initiative which will help Europeans make the best purchases and promote the virtuous industry. This contribution is written by 4 expert structures that have helped hundreds of companies on environmental claims or eco-design (La Belle Empreinte, Green Score Capital, Clear Fashion and Good Fabric).
Filed in French · English published by the European Commission
This is a submission on behalf of the following members of the NGO Coalition Exit Kunststoff: a tip: TAP e.V., Bund für Umwelt und Naturschutz Deutschland e.V., Forum Umwelt und Entwicklung, Heinrich-Böll-Stiftung, HEJSupport e.V., Küsten gegen Kunststoff e.V., Women Engage for a Common Future e.V. (WECF), Zero Waste Germany e.V. and Zero Waste Kiel e.V.
Filed in German · English published by the European Commission
The European Footwear Confederation (CEC) welcomes the adoption of the proposal for an EU Directive on Substantiating Green Claims and the consequent implementation of a science-based approach, which represents a step forward towards harmonisation in the EU single market while allowing certain flexibility to economic operators. Please find enclosed our comments to the proposal.
The European Branded Clothing Alliance (EBCA) welcomes the European Commissions proposal for a legislative initiative on the substantiation and communication of explicit environmental claims (also known as the Green Claims Directive). EBCA would like to make the following recommendations to the Commissions proposal for a Green Claims Directive: 1.
CTCP welcomes the adoption of the proposal for an EU Directive on Substantiating Green Claims and the consequent implementation of an evidence-based approach, a step forward towards harmonisation in the EU single market, while allowing certain flexibility to actors.
UECBV welcomes the proposal for the Directive on Green Claims from the European Commission 22 March 2023. Our sector, livestock and meat traders and producers, wishes to further strive towards environmental criteria and information and is happy to continue working on it. We have the following comments at this stage: 1.
La Fédération de la Maille, de la Lingerie & du Balnéaire accueille favorablement cette proposition de directive sur la justification et la communication des allégations environnementales explicites, convaincue quun encadrement européen des allégations environnementales permettrait de renforcer la confiance des consommateurs dans les allégations environnementales.
The Union des Industries Textiles supports the aim of this text, which is to provide consumers with clear, fair and verifiable information on the products they buy. Greenwashing strongly serves all companies that invest and make real efforts to offer products with less environmental impact.
Filed in French · English published by the European Commission
The adoption of the Green Claims Directive (GCD) is an urgent necessity, and it has the full support of the CircE NGO. While it represents a crucial initial step that can and should be fortified, its implementation will already considerably enhance legal actions against greenwashing. Voluntary environmental claims have become prevalent due to the competitive advantage they offer to those who make them.
The Polish Union of the Cosmetics Industry welcomes the European Commission's proposal for a Directive on the substantiation and communication of explicit environmental claims. The Union supports its overarching objective of tackling greenwashing and the need to develop a harmonised EU legal framework for environmental claims.
Contribution du MEDEF relative au projet de directive sur les allégations écologiques Les entreprises, en proposant des produits et des services plus respectueux de l’environnement, ont un rôle majeur à jouer dans la transition écologique. Mais elles ne pourront le faire seules, sans l’adhésion de leurs clients et consommateurs finaux.
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Overall, Circ supports the EU Green Claims Directive but seeks further information on specific claims and support for small and medium enterprises. As a textile-to-textile recycler and producer of recycled products for the textile and apparel sector, Circ firmly supports the EU Green Claims Directive. Unsubstantiated green claims negatively affect Circ's value proposition.
Good On You was created to provide consumers with easy to use actionable information to support them playing their role in the green transition. Good On You strongly supports the EUs Green Deal and much of the legislation proposed to implement its objectives.
Hello, Please find attached the feedback from Puro.earth, a carbon removal crediting programme and through the Puro Standard we certify durable removal of CO2 from the atmosphere. We issue CO2 Removal Certificates, CORCs, per tonne of CO2 removed and durably stored for at least 100 years. CORCs are issued and retired in the public Puro Registry adding transparency to carbon markets. Kind regards, Marianne and Helen
Comentarios a la Propuesta de Directiva del Parlamento Europeo y del Consejo, relativa a la justificación y comunicación de alegaciones medioambientales explícitas - Julio 2023 - 1. Introducción. Desde la Asociación de Consumidores ModeON (“ModeON”), estamos interesados en participar en el debate normativo sobre la Propuesta de Directiva del Parlamento Europeo y del Consejo, relativa a la justificación y…
Filed in Spanish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
This feedback is presented on behalf of the contributors to this paper representing the ORIENTING H2020 project consortium (with reference Grant Grant Agreement ID: 95823) ORIENTING welcomes the European Commissions proposal to set minimum requirements for the substantiation and communication of (voluntary) environmental claims in commercial practices and the introduction of mandatory requirements for an assessment…
The DUH welcomes the fact that, with the Green Claims Directive proposal (COM(2023) 166), the European Commission has launched comprehensive and cross-sectoral requirements for reconciling explicit and voluntary environmental claims.
Filed in German · English published by the European Commission
Ecoeff Lab is a consultancy firm which has been active in eco-design and LCA for 25 years in France and Europe, which accompanies a wide range of clients in any sector (businesses, professional federations, institutions, universities, NGOs, etc.).
Filed in French · English published by the European Commission
Schneider Electric welcomes the Directive on substantiation and communication of explicit environmental claims (Green Claims Directive). We support the Green Claims Directives ambition to combat greenwashing practices and false environmental claims that are deceiving consumers in the European Union (EU).
FEDIAF Position Paper on Green Claims Directive, July 2023 FEDIAF, the European Pet Food Association, welcomes the European Commissions proposal for the Green Claims Directive. Throughout the Commissions consultation process, FEDIAF has sought to be a constructive partner.
Avis de Green IT Consultation sur la proposition de directive allégations environnementales (Green Claims Directive) 2023-07-21 Le collectif d’experts indépendant GreenIT.fr vous soumet ses observations. Merci de noter que notre collectif a publié un premier avis du 1er mai 2023 (sous le nom de Frédéric Bordage), complété le 21 juillet 2023 (sous le nom de Lise Breteau).
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
This feedback is submitted on behalf of the Swedish industry organisation Plant-food Sweden (Växtbaserat Sverige, https://vaxtbaseratsverige.se/), which is an industry organization representing food producing companies of plant-based food and drinks. The members of Plant-food Sweden are Alpro, Findus, Nestlé/Hälsans Kök (Garden Gourmet) Oatly, Orkla Foods Sweden, Planti, Stockeld Dreamery and Livekindly.
Answer to the Commission feedback on the proposal of environmental performance of products & businesses: substantiating claims Arla Foods welcomes the opportunity to provide feedback on the proposal on Green Claims. Arla welcomes the proposal and agrees with the purpose of the directive to introduce a streamlining of the rules and bring much needed clarity to this complex area.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
TomatoEurope Position Paper on the Green Claims Directive July 2023 TomatoEurope represents the tomato processing industry covering more than 95% of the European business. Active since 1979, it acts as an umbrella organization for national associations, indirectly representing more than 200 tomato processing entities.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The proposal for the Environmental Claims Directive aims to tackle false environmental claims by ensuring that consumers are provided with reliable, comparable and verifiable information in order to make more sustainable choices. The general objective is to reduce the risk of so-called green-washing.
Filed in German · English published by the European Commission
Groupe Rocher welcomes the Commission's initiative to harmonize assessment and reporting requirements set out through the European Union for the various environmental claims without modifying existing and future sectoral rules but by considering it as a safety net for all sectors.
The European Safety Federation (ESF) - representing suppliers (manufacturers, importers, distributors) and service providers of Personal Protective Equipment (PPE) - welcomes this initiative. It is indeed important to be able to substantiate any claim made on products and/or businesses. This not only on the supply side, but also on the demand side (see e.g.
Fresh Del Monte Produce Inc. is dedicated to playing an active role in the legislative process that will lead to the adoption of the Green Claims Directive (GCD), by participating in this public consultation. We firmly support the goal of protecting consumers from deceptive greenwashing practices and empowering them to make informed purchasing decisions based on reliable and verifiable environmental claims.
Humana Spain welcomes the Green Claims Directive proposal of the European Commission. Our organization endorses making transparent and substantiated claims based on data which we see as an important pillar against green washing. The directive will facilitate people to make environmentally conscious, informed decisions about their purchases. Please find our feedback attached.
We welcome the opportunity to provide preliminary feedback on the Proposal for a Directive on Substantiation and Communication of Explicit Environmental Claims. Ecommerce Europe values the European Commissions work on establishing a clear regime for the substantiation of environmental claims and labels.
The Federation of European Manufacturers of Cookware and Cutlery (FEC) and its members fully support the objectives of Green Claim Directive. Too often product labels give vague, misleading, or unfounded information to the customers.
The Spanish Steel Association, UNESID, in representation of the Spanish Steel Industry welcomes the opportunity to give feedback on the initiative which aims to define a framework to regulate and harmonize the environmental claims and, as a result, to boost the participation and empowerment of costumer in the ecological transition through the disposal of accurate and comparable environmental information for their…
Oatly welcomes the opportunity to contribute to the public consultation on the EU Green Claims Directive. Oatly supports the overall objective to make companies responsible for substantiating claims about the environmental footprint of their products. We recognize the need to establish a regulatory framework to hinder greenwashing, and to facilitate for consumers to make informed choices.
The proposal for a Directive on Green Claims is an important advancement in the legal framework launched by the European Green Deal. As a company truly committed to contributing to the green transition, A2A welcomes this European Commissions initiative as a crucial advancement in the European market business environment.
Decathlon strongly supports the Commissions efforts to put an end to misleading communications on the environmental impact of products or companies, through the Green Claims Directive regulating the substantiation and communication of green claims. More specifically, we welcome transparent and reliable environmental claims to support consumers in their purchasing decisions for more sustainable products.
The German Entertainment Technology Association strongly supports European benchmarks and therefore a level playing field in regard to claims of sustainable products, services and organizations. We would greatly appreciate working with the EU Commission on creating valid PEFCR and OEFSR for our sector through the processes described in the methods to measure and communicate the life cycle environmental performance…
Proposal for a Directive of the European Parliament and of the Council on Green Claims Comentários: A necessidade de harmonização de regras para comprovação de claims ambientais é de facto um ponto relevante na medida em que, cada vez mais, existe imposição de regras distintas por diferentes legislações nacionais/entidades privadas.
Filed in Portuguese · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Stellungnahme zum Vorschlag der Kommission für eine Richtlinie über Green Claims Dr. Katja Marx und Clara Allonge, 21.07.2023 Der BVMed vertritt als Wirtschaftsverband über 300 Industrie- und Handelsunternehmen der Medizintechnik-Branche. Im BVMed sind u. a. die 20 weltweit größten Medizinproduktehersteller im Verbrauchsgüterbereich organisiert.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ECTAA is the voice of European travel agents and tour operators in Europe, representing more than 100.000 enterprises in Europe, 99% of which are SMEs according to 2020 Eurostat data. ECTAA welcomes the Commissions proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive).
ASOBIO fully supports the Proposal for a Directive prepared by the European Commission on the justification and communication of explicit environmental claims (hereinafter the Proposal for a Directive). Any legislative action to limit greenwashing is positive to foster consumer protection, promote a fairer and more competitive market, and ensure more responsible and sustainable consumption.
Filed in Spanish · English published by the European Commission
FEBEA brings together and represents more than 300 manufacturing companies selling cosmetics in France and internationally within the meaning of Regulation (EC) No 1223/2009 (perfumes, make-up, hairdressing products, care products and hygiene and toilet products), which are marketed through numerous distribution systems.
Filed in French · English published by the European Commission
The European Association of Chemical Distributors (Fecc) supports the principle of environmental impact information on products being clear, transparent, and comparable, and that such information can help consumers to make more sustainable choices.
European Bioplastics (EUBP), the association representing the interests of more than 80 member companies from the entire bioplastics value chain, welcomes the opportunity to provide feedback to the Commissions proposal for a Green Claims Directive.
Citeo is the French company in charge of the Extended Producer Responsibility (EPR) for household packaging and graphic papers. Citeo welcomes the EC proposal to provide harmonized rules on substantiation, communication, verification of voluntary green claims at European level.
The International Emissions Trading Association (IETA) welcomes the initiative of the European Union to set requirements for high-integrity environmental claims through its recent proposal for a Directive on the substantiation and communication of explicit environmental claims (Green Claims Directive). This is an opportunity to ensure consistency and aligned guidance in a space where practices vary significantly.
The TÜV Association welcomes the EU Commissions proposal on substantiation and communication of explicit environmental claims (Green Claims Directive) to make environmental claims reliable, comparable, and verifiable across the EU. This will reduce greenwashing, increase consumers trust in green labels and help businesses and investors make more sustainable decisions.
Federchimica, the Italian Federation of Chemical Industry, is composed of over 1.450 companies, for a total of over 94.000 employees. Federchimica is grouped into 17 Sector Associations, articulated into 38 Product Groups.
Dear Sir/Madam, thank you for the opportunity to comment on the EU draft directive on environmental claims (Green Claims). The Waren-Verein der Hamburger Börse e.V. (summary: Waren-Verein) represents the interests of importers of dried fruit, nuts, canned vegetables, canned vegetables and fish, frozen fruits, vegetables and fish products, and organic products.
Filed in German · English published by the European Commission
Proposition de directive relative à la justification et à la communication des allégations environnementales explicites (Green Claims) : Contribution de l’ANIA à la consultation publique européenne L’Association Nationale des Industries Alimentaires (ANIA) représente les entreprises alimentaires françaises.
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
As a chemical company supplying into almost all industries and sectors, BASF is committed to create chemistry for a sustainable future and to combine economic success with environmental protection and social responsibility.
Cosmébio was founded as an association in 2002, at a time when consumers were becoming increasingly aware of the dirty underside of the chemical industry. At this time, there were no regulations governing natural and organic cosmetics. In order to protect the consumer from the new marketing tactics of Greenwashing, Cosmébio imposed mandatory certification for its members.
Návrh směrnice nařízení Evropského parlamentu a Rady o dokládání a sdělování výslovných environmentálních tvrzení (směrnice o environmentálních tvrzeních) – připomínky Hospodářské komory ČR Hospodářská komora České republiky (HK ČR) vítá návrh směrnice o environmentálních tvrzeních, která má za cíl eliminovat obchodní praktiky využívající zavádějící environmentální tvrzení, ochránit spotřebitele a životní prostředí…
Filed in Czech · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European Steel Association (EUROFER) fully supports the objectives of having a level playing field and legal certainty on green claims, whilst ensuring consumers can trust and recognise efforts to increase environmental sustainability. In order to meet these objectives, the directive should be more precise on specific requirements to ensure consistent enforcement across member states, including: 1.
The Japanese electric and electronic industrial associations JEMA, JEITA, CIAJ and JBMIA (JP4EE) welcomes this opportunity to offer feedback concerning the European Commissions proposal for a "DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on substantiation and communication of explicit environmental claims (Green Claims Directive)".
The European Carton Makers Association (ECMA) welcomes the Commissions proposal for a Directive for the substantiation and communication of explicit environmental claims. ECMA brings together folding carton converters, cartonboard mills, national associations, and suppliers to the folding carton industry.
Hello, Agricultural Cooperation thanks the European Commission’s teams for this quest to harmonise national and European provisions on environmental claims. After careful review of the draft Directive, Agricultural Cooperation nevertheless wishes to bring the following points to the knowledge of the European Commission services: Article 2: the definition of agroecology refers to Article 2 (o) of Directive…
Filed in French · English published by the European Commission
ADELMA is a business organization that joins manufacturers and distributors of detergents and cleaning and maintenance products, pesticides and biocides, both those used at household and institutional, professional and industrial level. Within our Association there are companies dedicated to the marketing of products for domestic consumption, as well as the industrial and institutional ones.
VF Corporation welcomes the publication of the Commissions proposal for a Directive on substantiation and communication of explicit environmental claims (a.k.a.: Green Claims Directive) and would like to emphasize few concerns and recommendations. 1. Clarification on rules is necessary. The proposal text allows for different interpretations, enforcement, and verification of explicit environmental claims.
The United States appreciates this opportunity to provide comments on the Proposal for a Directive of the European Parliament and of the Council on substantiation and communication of explicit environmental claims (Green Claims Directive).
The World Federation of Advertisers (WFA) welcomes the opportunity to provide input to the European Commissions attempt to regulate the substantiation, communication and verification of voluntary environmental claims and environmental labels. WFA is the voice of marketers worldwide, representing 90% of global marketing communications spend, over 800 billion per year.
GCD will be key for addressing greenwashing and holding business to account for misleading and unsubstantiated claims. Product Environmental Footprint has in some ways been effective for other industries such as appliances, but it is still does not generate accurate results or actually reduce impact.
Environmental claims should be true and sufficiently substantiated. We as an organisation have filed several legal action towards individual actors regarding environmental claims and can confirm that there is a lack of knowledge and enforcement. It is a heavy process to make traders accountable creating disantvantages for both consumers and for companies with well substantiated and relevant claims.
The European Copper Institute (ECI) welcomes the opportunity to comment upon the European Commission's (EC) proposal for a Directive on Substantiation and Communication of Explicit Environmental Claims (Green Claims Directive). ECI stands in favor of the ambition for environmentally superior, net zero products assessed through solid and harmonized, LCA-based methods.
Personal Care Products Council Input to the EU’s Proposal for a Green Claims Directive On behalf of the Personal Care Products Council (PCPC), 1 we are pleased to provide our input to the EU Public Consultation on the Proposal for a Green Claims Directive (Directive). PCPC and our member companies are fully committed to transitioning toward a more sustainable and circular economy.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The EU non-ferrous metals industry, delivering materials for many low-carbon applications needed for the green and digital transitions, sees the proposed directive as a tool paving the way for better-informed choices of consumers on the products available on the EU single market.
With appreciation for the opportunity to provide feedback on the proposed directive on substantiating claims in regard to environmental performance of products & businesses, please find attached the World Travel & Tourism Council's contribution to this public consultation.
The Forum for Sustainability through Life Cycle Innovation e.V. - a global membership-based community organization for life cycle practitioners - welcomes the opportunity to provide feedback on the Draft Green Claims Directive (GCD). We welcome the EU Commission's Sustainable Products Initiative and the introduction of the GCD as a key piece of the overall legislative package.
July 20, 2023 European Commission Brussels, Belgium Subject: Government of Canada Comments on the European Commission Proposal for a Directive of the European Parliament and of the Council on substantiation and communication of explicit environmental claims (Green Claims Directive) To Whom It May Concern, The Government of Canada welcomes the opportunity to submit feedback on the European Commission’s Proposal for a…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
AESGP feedback European Commission’s proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive) July 2023 AESGP, the Association of the European Self-Care Industry, is interested to provide input on the public consultation concerning the published legislative proposal for a Directive on the Substantiation and Communication of Explicit Environmental Claims…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
IMACE would like to thank the Commission to give us the possibility to provide feedback on the legislative proposal on substantiating green claims. We expressed several concerns and suggestions in the document in annex to further improve the current proposal, making it as effective as possible without exessive burden for the companies (in particular for SMEs).
The Global Electronics Council (GEC) welcomes the proposal from the European Commission for a Directive on substantiation and communication of environmental claims (Green Claims Directive). The need for legislation is clear-- the proliferation of both unsubstantiated green claims and untrustworthy ecolabels around the world, including in the European Union (EU), is leading to market confusion, and impacting…
Climate-related claims are one way for companies to attempt to communicate their climate mitigation efforts to their customers. If such claims fail, arent real, and dont stand up to scientific scrutiny, they become a dangerous tool for greenwashing.
The Federation of the European Sporting Goods Industry (FESI) and its members welcome the publication of the European Commission proposal for a Directive on Substantiation of Green Claims. Overall, we believe that the proposal represents a good attempt at balancing the objective of harmonisation and the challenge of lacking a "one size fits all" methodology to assess products' environmental aspects, performance or…
Paris, le 20 juillet 2023 Contribution de la FIPEC à la consultation publique portant sur le projet de directive relative à la justification et à la communication des allégations environnementales explicites (directive sur les allégations écologiques) La FIPEC se félicite de la flexibilité des méthodes de justification des allégations relatives à l’empreinte environnementale.
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ASSUC is the voice of European sugar traders, representing over sixty sugar trading companies across Europe through its membership. We welcome the publication of the Proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive), on 22 March 2023.
Sustainability communication, at product and corporate levels, is essential to drive change. Transparency, through trustworthy, comparable and clear information, can empower customers to make sustainable choices for the environment, people and communities. It also incentivizes companies to track, measure, innovate and take initiatives.
The European Advertising Standards Alliance (EASA) welcomes the initiative and its purpose, while also encouraging policymakers to be mindful of the advertising collective self-regulatory (SR) systems which are an effective and consumer-friendly tool in dealing with misleading environmental claims.
Insurance Europe response to the European Commission’s public consultation on the proposal for a Directive on Green Claims Insurance Europe supports the European Commission’s objective of addressing greenwashing and misleading claims about the environmental merits of products and services.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Hintergrund Durch die ‘Directive of the European Parliament and of the Council on substantiation and communication of explicit environmental claims’ (Green Claims Directive) sollen Unternehmen künftig dazu verpflichtet werden, Angaben zum ökologischen Fußabdruck ihrer Produkte und Dienstleistungen anhand standardisierter Quantifizierungsmethoden zu belegen.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Contribution du Groupe Avril à l’appel à contributions Justification et communication des allégations environnementales explicites (‘allégations écologiques’) Le Groupe Avril accueille favorablement la proposition de Directive européenne relative aux allégations environnementales explicites, estimant que les aspect suivants doivent être dûment pris en considération dans le cadre des discussions prochaines afin d’en…
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
EURATEX welcomes the objectives of the Green Claims proposal to provide a level playing field for businesses, tackle green washing and help consumers to make informed decisions regarding the environmental impacts of products placed on the EU market.
Frankfurt am Main’s Centre for Combating Unfair Competition (shortly: Wettbewerbszentrale) would like to thank you for the opportunity to comment on the proposed Green Claims Directive. It fully welcomes all three aspects of the Commission’s objectives – in particular to protect consumers from greenwashing and to create more transparency in advertising with environmental claims.
Filed in German · English published by the European Commission
The Laboratories Arkopharma wish to respond to the European Commission’s call for input on the Directive on the justification and communication of explicit environmental claims. Arkopharma supports the need for harmonisation at European level in order to protect consumers, encourage businesses to combat greenwashing and facilitate the free movement of goods.
Filed in French · English published by the European Commission
Please find enclosed the opinion of the German Chamber of Commerce and Industry on the proposal for a directive of the European Parliament and of the Council on the justification of explicit environmental claims and the communication thereon (Environmental Claims Directive) COM(2023) 166.
Filed in German · English published by the European Commission
Feedback on the Green Claims Directive Proposal Home Appliance manufacturers have been responding for many years to the environmental challenges and their responsibility towards society to produce sustainable products. It is paramount for home appliance manufacturers that consumer trust in our products is maintained.
Please find attached FRUCOM's full position on the Green Claims Directive proposal. FRUCOM represents European Union importers, and growers, processors, and traders, of edible nuts, dried and processed fruit and vegetables, and processed fish and seafood products.
Impossible Foods response to Green claims directive – July 2023 Introduction Impossible Foods welcomes the publication of the Green Claims Directive as an important step to better inform consumers about the environmental footprint of products, and to help them make more sustainable choices.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The BDE Federation of the German Waste, Water and Circular Economy Management Industry welcomes the European Commission's proposal for a Directive on the substantiation and communication of explicit environmental claims (Green Claims Directive). Combating "greenwashing" is indispensable for strengthening consumer confidence in sustainable products and ensuring fair competition.
ENSA, the European Plant-based Foods Association, representing the interests of plant-based food manufacturers in Europe, welcomes the Commissions Directive proposal on the substantiation and communication of explicit environmental claims (Green Claims).
The Green Claims Directive is urgently needed, and ECOS supports its adoption. It represents a crucial initial step that can and should be strengthened further. Nonetheless, even in its current form, it will significantly enhance legal measures against greenwashing. Voluntary environmental claims are made because they give a market advantage to those who make them.
Preventing greenwashing is crucial to maintain consumer trust in products and claims. It is important that environmental claims adhere to established standards to ensure fair competition and market orientation. Therefore, the German Adhesives Association (IVK) supports the European Commission's efforts in addressing this issue. However, we still see a need for improvement to the draft directive in its current form.
Freshfel Europe welcomes the initiative of the Commission to regulate the substantiation and communication of explicit environmental claims. Fresh fruit and vegetables play a fundamental role in a greener economy and Freshfel Europe supports tools that create trust with consumers in communicating these important assets.
Annex 1 to ENVI/ENV-INFO/012/23E- FoodDrinkEurope position on the proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive) FoodDrinkEurope welcomes the European Commission’s proposal for a Green Claims Directive (GCD).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European Furniture Industries Confederation (EFIC) welcomes the opportunity to provide comments to the ongoing consultation on the Proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive) . The Furniture sector is in favour of actions to protect the market from greenwashing and advocates for harmonized rules at EU level.
ETSA the European Textile Service Association, a business association with membership consisting of laundries, detergents, machineries and national associations would like to express support and outline concerns regarding the EU Commission Proposed Directive on "Green Claims." While we appreciate the intention behind this proposal to promote reliable and verifiable environmental claims, we believe it is crucial to…
A.I.S.E., the European association for detergents and cleaning products, supports the European Commission efforts to address greenwashing via a legislation on green claims substantiation. A.I.S.E. wishes to highlight some key aspects aimed at further strengthening the proposal.
The Polish Association of the Cosmetic and Detergent Industry (PACDI) welcomes the European Commission’s (EC) proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive), and agree with its ambitious approach to address the issue of greenwashing and to develop a harmonised EU legal framework for environmental claims.
Filed in Polish · English published by the European Commission
The German Chemical Industry Association (VCI) is committed to bringing products to market that are both safe and have lower burdens on the environment. Therefore, the VCI welcomes as a matter of principle the EU Commissions approach to create more transparency in the business-to-consumer sector. However, we still see a need for improvement to the draft directive in its current form.
CEPE is strongly committed to bringing safe products to the market that have a reduced environmental impact and wants to collaborate with the European Commission and the entire value chain to make the Green Claims Directive effective.
CIRFS is the association for Europes 12 billion man-made fibres industry, representing the industry to the European authorities and providing the industry with a wide range of services. Its members cover about 75% of European man-made fibres output. It provides for around 20,000 jobs in ca. 250 plants. The European man-made fibres industry, with a total production in 2022 of ca.
As K+S, we see ourselves as pioneers in environmentally friendly and sustainable mining. Our constant efforts to set global standards resulted in several developments of new techniques and processes to better protect the environment and reduce our products footprints and these efforts are on-going.
Japan Business Council in Europe (JBCE), a cross-sector association representing member companies from various industries and supply chain stages, welcoms the oppotunity to provide its feedback on the European Commission's proposal for a Green Claims Directive. JBCE supports truthfulness and transparency in environmental information to protect consumers.
CarbonCloud endorses the Green Claims Directive and the initiative to combat greenwashing in explicit claims. In this spirit, we are compelled to draw the legislators attention to paragraph 19, which currently puts the value delivery of the legislation at risk and reverses the specificity and scientific basis laid out throughout the Directive.
EDANA, the voice of the nonwovens and related industries, represents the entire nonwovens value chain. This includes manufacturers of the materials that go into many different product applications such as absorbent hygiene products, automobiles, agriculture, protective clothing, and medical clothing. These are just some of the many applications for nonwovens in todays economy.
In the 88 pages of the Directive, we have not seen the word reciprocity. We have not seen proposals for the consumer to receive information on the very different production standards that third countries do have. In the attached document we provide proposals related to consumer information.
Better Cotton welcomes the proposal for a directive on substantiation and communication of explicit environmental claims (Green Claims Directive), to ensure that consumers are protected and empowering them to contribute actively to the green transition by tackling false environmental claims. There is a strong need for clear guidance on how claims can be made in a credible, accurate and relevant manner.
AIM, the European Brands Association, welcomes the European Commissions proposal for a Directive on the Substantiation and Communication of Explicit Environmental Claims (Green Claims Directive). Together with the one on Empowering Consumers for the Green Transition, this proposal will be key to eliminating greenwashing practices, while defining clear rules and creating a level playing field for businesses and truly…
The Foundation for Environmental Education (FEE), is a leading CSO in Education for Sustainable Development and Sustainable Tourism, representing over 100 member organisations in 80 countries. We have members in all EU member states except Hungary, as well as in most EU candidate countries.
The BAH welcomes the EU Commission’s aim to act against green washing and to strengthen consumer rights through better protection against unfair practices. This overarching goal is in the interest of both consumers and companies. At this point, it should be explicitly emphasised that it is not about misleading and untruthful statements.
Filed in German · English published by the European Commission
- SEE FULL VERSION ATTACHED - EDA welcomes the proposal on substantiation and communication of explicit environmental claims. We support the ambition to harmonise the requirements for communicating green claims and create a level-playing field on the EU market. We believe that there is a need for a harmonised approach.
Green Claims Directive: Open Consultation Carbon Market Watch’s response to the Green Claims Directive public consultation Introduction Carbon Market Watch welcomes the opportunity to provide feedback on the proposed Green Claims Directive (GCD).1 Misleading and unsubstantiated green claims are widespread and must be addressed.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Alliance for Beverage Cartons and the Environment (ACE) and its members Billerud, Elopak, SIG Combibloc, Stora Enso and Tetra Pak acknowledge and support the European Commission's efforts to promote sustainability and combat greenwashing through the proposed Green Claims Directive.
The European Ventilation Industry Association (EVIA) welcomes the Commission proposal for Substantiating Green Claims and appreciates the opportunity to provide feedback. We support the Commission proposal, as it is an important initial step towards addressing greenwashing as well as for addressing the fragmentation of the Internal Market that is the result of the proliferation of environmental/sustainability…
BirdLife Europe and Central Asia welcomes this Directive as it sets to address the greenwashing we are currently attesting in every sector. Although the general direction of the law is the right one, we think that some aspects are either overlooked or need to be improved. Today there is a profusion of different labels, competing and adding more confusion to the consumer .
Orgalim, representing Europe's technology industries, thanks the European Commission for the opportunity to comment on the proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive).
The Material and Product Taskforce welcomes the Commissions proposal which sets concrete tools to tackle Greenwashing. To facilitate the implementation of this directive on green claims, it is crucial to have measures that simplify it, make it more practical and ensure its transparency. One key aspect is the use of robust and up-to-date indicators that guarantee the relevance of green claims.
The Trade Alliance is the main representative organisation of the person’s equipment sector. It comprises the Union du grand commerce de Centre-Ville (Printemps, Bon marché, MonoPrix, etc.), the Fédération des Enseignes de l’Habillement (Petit Bateau, Kiabi, Jules, H, M, Father, Sons, SMCP, Grain de Malice, Damart, etc.) and the Fédération des Enseignes de la Chaussure (CHAUSSEA, Arc, Paraboot, La Halle, Eram…
Filed in French · English published by the European Commission
The European Commissions efforts to ensure adequate substantiation of green claims by creating a minimum level of evidence and harmonising different legislative interpretations in the EU through the proposed Directive on Green Claims are welcome.
18 July 2023 DIGITALEUROPE feedback on Substantiating Green Claims’ public consultation Executive summary The proposed Green Claims Directive (GCD) is a positive step toward combating greenwashing. However, its effectiveness will depend on enforcement and the establishment of clear methodologies.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
eu travel tech welcomes the European Commissions efforts to develop EU-wide criteria for the substantiation and communication of explicit voluntary environmental claims. As environmental sustainability becomes a crucial factor in shaping consumer choices, it is indeed important to have a framework that can guide businesses in their environmental communications.
Feedback from ARDEX GmbH regarding the initiative: "Environmental performance of products & companies - substantiated statements" The ARDEX Group is of the opinion that all statements regarding the environmental impact of a product must be based on transparent, comparable, and trustworthy information.
Bioenergia ry the Bioenergy Association of Finland supports the objectives of the Directive on substantiation and communication of explicit environmental claims. It is important to clarify the rules for environmental claims in the EU and to prevent greenwashing of products and services.
ecoinvent welcomes the proposal from the Commission for a directive on the substantiation and communication of explicit environmental claims (Green Claims Directive). Addressing the issue of greenwashing and deceptive marketing practices is crucial in assisting both customers and companies to play an active role in the ecological transition.
Novamont S.p.A is a global leader in the production of biodegradable and compostable bioplastics and in the development of biochemicals from renewable sources. Novamont welcomes the considerations of the Green Claims proposal and wishes to provide comment on this topic.
Textile Exchange is a global non-profit driving positive action on climate change across the fashion, textile and apparel industry. We guide and support a growing community of brands, retailers, manufacturers, and farmers towards more purposeful production right from the start of the supply chain. We support the objectives of the Green Claims Directive and welcome the opportunity to provide feedback.
Reliable and factual environmental claims are key for both consumers who have the right to receive accurate and truthful information and businesses wanting to communicate their product traits or organisational efforts. We recognize the challenges to making, substantiating, and comparing certain environmental performance claims as the rules today are not always clear.
First of all, COSMED supports overall objectives of the Green Claim Directive to protect consumers and companies against greenwashing. However, we alert on the need to maintain a rationale balance to avoid disproportionate burden on companies and especially on SMEs and to leave the possibility for SMEs to make voluntary environmental claims in an accessible way.
Cepi is the European association representing the interest of European pulp and paper manufacturers. Through its 18 national associations, Cepi gathers 500 companies operating 895 mills across Europe and directly employing more than 180,000 people. Cepi welcomes the Commissions proposal for a Directive for the substantiation and communication of explicit environmental claims.
The TIC Council, the global trade association representing the independent Testing, Inspection, and Certification companies, welcomes the European Commissions proposal on Substantiation and Communication of explicit Environmental Claims and strongly supports this timely effort against greenwashing.
Essity aspires to be the undisputed global leader in hygiene and health. With headquarters in Stockholm, Sweden, sales are conducted in approximately 150 countries under the leading global brands TENA and Tork, and under other strong brands, such as Actimove, JOBST, Knix, Leukoplast, Libero, Libresse, Lotus, Nosotras, Saba, Tempo, TOM Organic, Vinda and Zewa.
Stockholm Exergi has submitted a response to the invitation to provide comments on the draft EU Green Claims Directive. The full response is provided as a public PDF-document, also available at https://beccs.se/about-beccs-stockholm/documents/. In the response, we propose Ten Principles for Claiming and Accounting of Net-zero and Permanent Negative Emissions (PNEs). The ten principles are: 1.
European Aluminium is the voice of the aluminium industry in Europe, actively engaging with decision makers and the wider stakeholder community to promote the outstanding properties of aluminium, secure growth and optimise the contribution our metal can make to meeting Europes sustainability challenges.
AIG response to the EU Commissions call for evidence on the Green Claims Directive SUMMARY 1. The Advertising Information Group (AIG) (transparency number: 11220347045-31) welcomes the opportunity to respond to the European Commissions call for evidence on the Directive on substantiation and communication of explicit environmental claims (Green Claims directive) published in March 2023. 2.
The advertising industry supports the Commission’s overall objective of empowering consumers 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 promote truthful environmental claims.
Filed in German · English published by the European Commission
German "Industrieverband Büro und Arbeitswelt e.V." (IBA) and "European Office Furniture Federation" (FEMB) as umbrella organisation represent a large share of the office and school furniture sector in Europe. We support the comment by EFIC (European Furniture Industries Confederation) on chapter 7.2.
The Bundesverband der Deutschen Süßwarenindustrie e.V. welcomes the European Commission’s intention, with this Directive, to create a set of rules to avoid greenwashing and to enable consumers to be made even more transparent with regard to sustainability and environmental labelling.
Filed in German · English published by the European Commission
Dear European Commission, Japan Chemical Fibers Association (JCFA), who consists of 41 members including chemical fiber manufacturers and chemical fiber spinning firms in Japan, would like to express our comments and concerns towards the proposed directive of the European Commission (19), particularly in its suggestion that explicit environmental claims surrounding textiles produced from collected PET bottles may…
The trade association supports in principle the harsh objective of the Directive, but in its current form the proposal creates additional administrative burdens and legal uncertainty for businesses without effectively resolving a problem. Please find attached our detailed position.
Filed in German · English published by the European Commission
Pierre Fabre welcomes the initiative to harmonize, compare and verify more strongly the various environmental claims found in the market and especially in cosmetic market. Pierre Fabre, as part of cosmetics and personal care manufacturer, has proved its commitment to sustainability and circularity, being evaluated as exemplary by AFNOR Certification regarding the label Engagé RSE / Committed to CSR based on ISO26000…
Bitkom e.V. (Germany's digital association) welcomes the efforts of the European Commission to create more transparency in competition when it comes to environmental claims and to avoid greenwashing. However, in our view, the present proposal for a directive on substantiation and communication of explicit environmental claims (Green Claims Directive) does not appear to be suitable for achieving the objectives…
Cosmetics Europe welcomes the European Commission proposal for a Green Claims Directive and supports its overarching goal to tackle greenwashing and develop an EU-harmonised legislative framework on green claims. This would help creating a level playing field for businesses and truly empower consumers to make more sustainable choices.
Minviro welcomes the Green Claims directive, however, some clarity and further consideration around certain topics could be worth considering. The topics are outlined below: Need for a clear distinction between substantiation and communication of environmental claims: Overall, there seems to be a lack of distinction between substantiation and communication.
For consumers seeking reliable information for their consumption choices, the variety of different eco-labels and schemes may be misleading. The Association of the German Lack- und Printing Ink Industry (VdL) therefore welcomes in principle the European Commission’s efforts to create more transparency in competition with regard to environmental claims and to avoid greenwashing.
Filed in German · English published by the European Commission
DI believes that it is crucial for the green transition and consumers' role in it: 1. That companies can commercially communicate about all the measures they take to improve their green footprint and sustainability. 2.
FEIQUE, the Spanish Chemical Industry Business Federation (www.feique.org), represents the Spanish chemical industry, a sector that generates 13.8 % of the gross industrial product in Spain and is highly cross-cutting in nature, as it is active in virtually all manufacturing industries’ value chains.
Filed in Spanish · English published by the European Commission
With more than 730 facilities generating an annual turnover of 8.7 B, offering an installed capacity of 11.3Mt and employing more than 30,000 persons, the EU plastic recycling industry is a key player on the global scale. Moreover, recycling plastic waste greatly contributes to lowering GHG emissions and reducing pollution from the (mis-)management of plastic waste.
The EEB welcomes the long-awaited proposal for a Green Claims Directive. Please see our attachd position paper and the summary below: 1) Why this legislation is important - The proliferation of misleading and unsubstantiated claims as well as greenwashing are hampering the green transition.
Consumption Research Norway (SIFO) welcomes the EC's efforts to halt greenwashing and the opportunity to provide feedback on the proposal. SIFO is a non-profit, transdisciplinary research institute at the Oslo Metropolitan University. Our research aims to understand the role of consumption and consumers in society and to provide the knowledge basis for public consumer policies.
The Round Table on Responsible Soy Association (RTRS) welcomes the opportunity to provide feedback on the European Commissions proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive).
NATRUE AISBL is an international non-profit association representing pioneering producers from global natural and organic cosmetics sector, and welcomes the opportunity to provide input to the publication of the EU Commissions proposal of a Green Claims Directive (GCD).
The Policy Hub Circularity for Apparel and Footwear supports the efforts of the European Commission to set up the EU's first detailed set of rules on how companies must substantiate reliable, comparable, and verifiable claims about the environmental impact, aspect and performance of products and services they offer across the EU.
The U.S. Cotton Trust Protocol welcomes the opportunity to comment on the European Commissions Public Consultation on the "Proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive).
Swedish Forest Industries Federation (SFIF) welcomes the European Commission´s objective to set a baseline for requirements for substantiation of environmental claims to mitigate greenwashing. The proposal constitutes an important and needed piece of legislation which complements other legis-lation related to consumer protection.
UL Solutions welcomes the possibility to comment on the European Commissions legislative proposal on environmental claims with the aim to require companies to substantiate claims they make about the environmental footprint of their products/services by using standard methods for quantifying them.
Expedia Group position on the Directive on the substantiation and communication of explicit environmental claims On 22 March 2023, the European Commission published its proposal on a Directive on the substantiation and communication of explicit environmental claims. The proposal requires companies making green claims to assess their environmental impacts using a standard methodology.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The International Chamber of Commerce (ICC) is grateful for the opportunity to provide feedback on European Commissions Directive on substantiation and communication of explicit environmental claims (Green Claims Directive) and extends its appreciation for allowing this key process to be held in an open, transparent and inclusive manner.
BEUC, the European Consumer organisation, very much welcomes the publication of the Green Claims Directive as an important step in fighting greenwashing and ending misleading unsubstantiated claims from being displayed on products and services. Consumers are confronted with a systemic greenwashing problem.
Agroecology Europe (AEEU)the European association promoting agroecology as a set of practices, a science, and a movement across Europewelcomes the opportunity to give feedback on the Commissions legislative proposal on green claims. AEEU calls on the co-legislators to reinforce the legislative proposal on the following points to stop the proliferation of greenwashing of food and agricultural products. 1.
The unregulated use of environmental advertising claims, so-called green claims, poses problems for consumers: they cannot rely on environmental claims and labels to reliably certify environmentally friendly production. Green claims without substantiation - meaning claims without scientific foundation of the accuracy of the claims - thus prevent a change to sustainable consumption patterns.
FEVE representing the European Container Glass manufacturing industry supports the intention of the European Commissions Green Claims proposal to ensure that consumers and businesses have access to reliable, comparable, and verifiable information to make sustainable decisions and avoid the proliferation of misleading green claims.
Cefic welcomes the European Commission proposal on the Green Claims Directive and supports the overall objectives of this ambitious initiative. We want to collaborate with the European Commission and the entire value chain to make the Green Claims Directive effective in product differentiation and providing accurate information to consumers while ensuring a level playing field for all players across the industry…
EACA is the voice of Europes communications agencies and associations, promoting the economic and social contribution of commercial communications to society. Our members comprise advertising, media, digital, branding and PR agencies as well as their national associations together they represent more than 2,500 organisations from nearly 30 European countries that directly employ over 120,000 people.
FEFAC represents the European compound feed & premixes production industry. FEFAC regrets that the EU Commission missed a unique opportunity to propose the PEF method as preferred option for the determination of the environment footprint of goods in a harmonised way.
RSPO Feedback to the European Commission on the proposed directive on substantiation and communication of explicit environmental claims (Green Claims Directive). The RSPO welcomes the proposal for this directive as an important step to tackle misleading claims and greenwashing and as an opportunity for legitimate, robust and scientifically supported claims and voluntary schemes to distinguish themselves and to…
ASEFAPI fully supports the regulation on green claims, which can serve as a tool to eliminate all forms of ‘green washing’ and enable consumers and market participants to make informed choices based on reliable, comparable and verifiable data rewarding higher environmental performance.
Filed in Spanish · English published by the European Commission
EuroCommerce welcomes the Commissions proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive). We agree that consumers should be able to rely on properly verified environmental claims. We, therefore, support further action on green claims to protect consumers and ensure fair competition in the Single Market.
Environmental claims are playing an increasingly important role in shaping consumers' opinions and purchasing decisions. The sustainability of products and services has become a competitive factor. Products declared as "green" or sustainable are now experiencing greater growth in the EU domestic market than other products.
To ensure the practicability of the regulation, the German insurers would like to make the following remarks: Consistency with other existing or currently under development regulations (e.g., the CSRD/ESRS) needs to be ensured.
The Federation of Finnish Enterprises (FFE) supports the reasons and objectives of this proposal to make better informed choices in the ecological transition and to tackle false environmental claims. We also support the aim of the directive proposal to set up equal standards for the companies operating in the EU market. Some of the provisions of the proposed directive are however problematic.
The Green Building Council Denmark welcomes the proposal for a directive on substantiation and communication of explicit environmental claims (Green Claims Directive). It is of high importance to limit greenwashing and misleading marketing to help consumers and companies navigate in the green transition, and the proposed directive can be an important driver in this case.
Proposal for Green Claims Directive On behalf of the producers of wood-based products we would like to give following feedback: At this stage the proposal looks complicated and regulations intertwined on with another. At the moment the Construction Products Regulation is under revision and the ESPR is taking shape. Furthermore some of our products are used in the packaging sector and fall under PPWR.
ChemSec welcomes the proposal from the Commission on Green claims. If the legislation is to be useful and trustworthy there are two elements that need to be fulfilled; the information on green claims must be both truthful and actually beneficial for the environment.
Danish Fashion & Textile (DM&T) is the industry association for Danish fashion and textile companies in Denmark. In general, we welcome the high ambitions of the EU Commission when it comes to transitioning the industry into being more circular and sustainable as described in the EU textile strategy.
We welcome the parts of the Commissions proposal that allow reputable companies who make a tangible effort to reduce their environmental impact stand out and distinguish themselves from their competitors. The proposal should enhance consumer trust in environmental claims. Consumer interest and awareness has steadily grown over the past years.
We, Laboratoires M/L of the LOccitane Group, responsible for and placing cosmetics and dambiance on the market, are aligned with the objectives of this Directive on environmental claims, as they are in line with current environmental, economic and societal needs, but also in line with the European Union’s action plan for a circular economy.
Filed in French · English published by the European Commission
Stockholm, 6. July 2023 Nordic Ecolabelling feedback on the EU Commissions proposal for a directive on Green Claims Thank you for the proposal for a directive on substantiation of explicit environmental claims (Green Claims Directive). Consumers and businesses are powerful forces in the green transition.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Global Ecolabelling Network (GEN) is the leading network of the worlds most credible and robust ecolabels. We have a 29 year history of excellence as a non-profit organisation and together we set the global benchmark for ecolabel excellence.
WKO Position Paper Short Summary - Proposal for a Green Claims Directive: less restrictions for the benefit of consumer orientation more exemptions and support for SMEs, implementation leeway needed substantiation to be simplified radically verification and authority-OK to be deleted national, regional and private labels to be exempted from verification in any case.
As a manufacturer of construction chemical products, we generally welcome the European Commission’s efforts to make environmental claims more transparent in competition, avoid greenwashing and ideally also consolidate the number of different ‘certifications’. Article 3(1) of the proposal for a directive calls for an assessment of environmental claims which are ‘relevant in terms of life cycle’.
Filed in German · English published by the European Commission
It is important to continue developing methods to calculate the life-cycle environmental impacts of products The Green Claims Directive directs companies to use widely recognized scientific evidence to assess the life-cycle environmental impacts of products.
Here are selected inputs from Sweden's largest environmental organization - The Swedish Society for Nature Conservation. For details, please see attached file. The Swedish Society for Nature Conservation's environmental label, Good Environmental Choice (Bra Miljöval), was established in 1990 and has since supported companies, public actors, and individuals in making wise choices that contribute to a sustainable…
The Danish Agriculture and Food Council (DAFC) welcomes the proposal for the Directive on Green Claims from the European Commission. DAFC sees a significant need for harmonized, reliable, and transparent requirements for communicating green claims in the European market, including harmonized calculation methods.
Brussels, 30 June 2023 IFOAM Organics Europe feedback to the Commission’s proposal on green claims IFOAM Organics Europe is grateful for the opportunity to provide feedback to the Commission’s proposal on green claims. First of all, we would like to thank the Commission for this proposal, as it aims to inter alia address greenwashing, a practice that can be deleterious to truly sustainable businesses and products.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
PFP sectors are currently engaged in discussions on sustainability and are therefore wishing to move forward with the development of Product Environmental Footprint Category Rules (PEFCR) to identify, fulfil and communicate improvements in environmental performance.
Visa position on Proposal for a Directive on green claims: — Visita questions about the problem the proposed regulation wants to solve not be addressed with existing, and other Upcoming, legislation. — Visual believes that so-called “greenwashing” should be counteracted in order to, among other things, increasing environmental protection and strengthening the green transition.
Filed in Swedish · English published by the European Commission
Regarding Article 41: This article excludes recognized scientific methods of life cycle assessment. As long as no unified method for aggregation has been prescribed (legal requirement), all scientifically recognized methods of life cycle assessment should be allowed for making green claims.
The Commissions initiative to reduce greenwashing by mandating the substantiation of voluntary green claims (the Green Claims Directive) is a fundamental piece to empower consumers by ensuring that the products environmental information they receive is accurate and transparent.
Feedback from the MSC on the EC proposal on substantiation and communication of explicit environmental claims (Green Claims Directive) June 27th, 2023 The Marine Stewardship Council is an international non-profit organisation that is GSSI1 benchmarked and ISEAL2 accredited. Our mission is to protect the oceans and safeguard seafood supplies for the future using our fishery certification scheme and ecolabel.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Proposal for a Directive of the European Parliament and of the Council on Substantiation and Communication of explicit environmental claims (Green Claims Directive) Docket ID No. COM (2023)166 This comment provides recommendations in response to the European Commission's proposal for a Directive on Green Claims specifically regarding the use of biobased testing (carbon-14 analysis) under methods such as ASTM D6866…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We are pleased to share ANECs assessments and recommendations in response to the Commissions Proposal for a Directive on New rules on substantiating green claims. We do so based on our participation in standardisation over many years and policy discussions on Life Cycle Assessment (LCA), Environmental Performance Declarations (EPDs), carbon footprint, corporate environmental indicators and performance evaluation.
Dokumentnamn Comments on the 2023/0085 Proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive) Sekab Datum 2023-06-27 1(3) Sekabs comments and feedback on the Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on substantiation and communication of explicit environmental claims (Green Claims Directive) Sekab is a green chemical…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Rainforest Alliance welcomes the proposal for a directive on substantiation and communication of explicit environmental claims (Green Claims Directive), as a stepping stone to tackle misleading claims and greenwashing.
1/8 Submitted electronically on ec.europa.eu Deres ref. Our ref. Case no: 23/2318-3 Executive Officer: Mathilde Furunes Dir.phone: 45971625 Date: 21.06.2023 The Norwegian Consumer Authority's feedback on the proposal for a directive on substantiation and communication of explicit environmental claims 1 INTRODUCTION We refer to the Commission’s proposal for a Directive on substantiation and communication of explicit…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We would like to reiterate our longstanding support for the Commissions efforts to introduce more stringent regulations to tackle greenwashing, enabling consumers to make informed purchasing decisions, and we welcome this opportunity to submit our feedback (in attachment).
EuRIC welcomes the publication of the proposal for a Green Claims Directive as a positive step towards promoting transparent and accurate environmental claims in the European market. By setting clear guidelines and standards for eco-labelling, this initiative can help consumers make more informed and sustainable purchasing decisions, while also encouraging businesses to adopt more eco-friendly practices.
The global food system has a tremendous impact on the environment and nature. Food production is one of the main drivers of major environmental problems, and experts from around the world are calling for a sustainable food system. According to the IPCC's land report, dietary changes towards plant-based food will contribute to achieving 12 out of 17 UN Sustainable Development Goals.
2023-06-12 Directorate-General for Environment Submitted via portal RE: DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL erthos Inc., is a Canadian advanced material science company that provides innovative alternatives to traditional single-use plastics.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
IMA-Europe welcomes the opportunity to provide feedback on the European Commission adopted proposal for a Directive on Green Claims published on March 22. The adapted proposal is focused on tackling greenwashing and safeguarding consumers and the environment. The proposal seeks to ensure that environmental labels and claims are credible and trustworthy, allowing consumers to make informed purchasing decisions.
We welcome that 'green claims' are to be linked to objective requirements and must refer to generally accepted standards, so that comparability is ensured. The fact that environmental information must always verified by external verifiers (Art. 11) though is an unjustified burden for many companies and especially a tough restriction for SMEs.
Brussels, 07 June 2023 BeST statement on Green Claims proposal Introduction With the present statement, BeST shares its views and recommendations on the European Commission’s proposed Directive on the substantiation and communication of explicit environmental claims (Green Claims Directive).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Green Claims Directive represents a promising and critical step against the propagation of unregulated claims and labels. A certification framework and verification mechanism will be effective in providing legal clarity and ensuring fairness when it comes to companies marketing activities surrounding the sustainability space.
SMEunited supports addressing a feasible substantiation of green claims and creating a harmonised legal framework. SMEunited calls for simple, workable and proportionate substantiation criteria in the Directive on Green Claims. The Directive must not result in the use of green claims being reserved for financially strong market players. Therefore, SMEunited calls for changing the Directive in several ways.
PhosAgro is the leading producer of environmentally safe phosphate fertilisers. We welcome the occasion to submit our feedback on the initiative aimed at introducing minimum requirements for substantiating and communicating of explicit environmental claims. We appreciate every effort to supply consumers with reliable, verified and exact information.
Comments Dutch Accreditation Council (RvA) Public Consultation Green Claims Directive Uniform substantiation of environmental claims and how this substantiation is verified is of great importance to a level playing field within the market.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Green Claims Directive is a promising and important action against the proliferation of unregulated claims and labels. The introduction of a certification framework and verification mechanism will be effective at providing more legal certainty and levelling the playing field for companies marketing activities in the sustainability space.
The proliferation of unregulated claims and labels is a pressing issue that the Green Claims Directive aims to address. The introduction of a certification framework and verification mechanism, that this directive aims to establish, should provides legal certainty and a fair set or market rules for companies' marketing activities about the sustainability concepts.
This is done on behalf of the Green IT association (GreenIT.fr), which brings together French experts on quantifying the environmental impacts of digital products and services. We do not understand why this European Commission initiative (Green Claims), which aims to frame environmental claims, does not propose a methodological framework for quantifying the environmental impacts and benefits of their products and…
Filed in French · English published by the European Commission
The text adopted by the European Commission presents several dominant areas. We share the vision of ECOS in the following areas: — The Directive delegates a lot of work to the Member States – All the verification will require funding or rely on private providers with the risk of collusion and inequity between small and large companies.
Filed in French · English published by the European Commission
OPTA Europe (www.opta-eu.org) is the membership organization representing the interest of EU organic processing and trade companies. Its membership encompasses 11 EU Member States plus North America and Switzerland. Taken together, the companies represented by OPTA Europe account for a large share of total EU import & export and processing of organic products.
The Biomimicry Institute, an NGO committed to design solutions modeled on nature in support of all life, welcomes the opportunity to provide feedback on this initiative. If Europe is indeed to be a leader in the circular economy and climate neutrality, it needs to lead from a premise of true circularity.
AVEC (transparency number 9803788883-16), representing the EU poultry meat sector, would like to thank the Commission to give use the possibility to provide feedbacks on this public consultation on the upcoming legislative proposal on substantiating green claims.
These comments are submitted on behalf of Fibershed, a U.S.-based NGO focused on establishing healthy fiber and textile systems, representing 34 Fibershed Affiliate organizations across 4 continents, including North America, Europe, Australia and India. The intention of this proposal for accountability in transparent and trusted labeling claims is laudable.
ECOS supports the provision of environmental information to consumers environmentally relevant, reliable, comparable and verifiable, through the development of an EU legal framework requiring companies to substantiate claims via the Environmental Footprint methods.
The Rainforest Alliance welcomes the EU Roadmap on Substantiating Green Claims and recognizes the importance of providing clear and reliable information on sustainability claims. This is an important element of ensuring that consumers, but also buyers and investors, can make more sustainable decisions.
Eurometaux, the European non-ferrous metals industry, has been actively engaged in the European Commission’s Environmental Footprint (EF) project and has developed, during the EF Pilot Phase, the ‘Product Environmental Footprint Category Rules (PEFCR) for Metal Sheets in Various Applications’. Currently, we are also an active stakeholder in the so called Environmental Footprint Transition Phase (2018 – 2021).
This feedback is submitted on behalf of the Swedish industry organisation Plant-food Sweden (Växtbaserat Sverige), which is an industry organization representing food producing companies of plant-based food and drinks. The members of Plant-based Sweden are Fazer, Findus, Food for Progress, Nestlé/Hälsans Kök (Garden Gourmet) Oatly, Orkla Foods Sweden, VegMe – Nordic Lunch and Simple Feast.
Oatly was founded back in the 1990s and is based on Swedish research from Lund University. The company’s patented enzyme technology copies nature’s own process and turns fiber rich oats into nutritional liquid food that is perfectly designed for humans. Oatly actively supports the overall objectives of the Commission’s legislative proposal on substantiating green claims.
Eurima welcomes the Commission’s intention to harmonize and set a baseline for the substantiation of green claims for products and businesses. Our industry shares the concerns raised in the Roadmap regarding the detrimental impact of unsubstantiated green claims on consumers, both on B2B and B2C markets and on the internal market.
Jernkontoret supports the establishment of a common and consistent assessment framework for how companies making green claims should assess their product's or organisation's impacts on the environment. Jernkontoret also find it important that this initiative is consistent with other policy initiatives, such as the sustainable product policy initiative, and takes into account the full product lifecycle.
The Association of Dutch Flower Auctions (VBN) represents cooperatives in the ornamental chain with over 4000 member companies, producers of ornamental products, and 2500 associated buyers/wholesalers. Yearly 12 billion products (flowers and plants) are being traded at the auction market places. These products regard over 30.000 different varieties.
Union Fleurs is the international umbrella organisation for national associations and companies active in the floricultural trade (cut flowers and potted plants) and represents the interests of operators involved in the trade of these products (importers, exporters, wholesalers and distributors) in the EU and in 20 countries worldwide.
The Liaison Centre for the Meat Processing Industry in the European Union (CLITRAVI), the professional organisation whose aim is to represent the interest of the European Meat Processing Industry, appreciates the initiative of the EU set in the Green Deal and supports the efforts to issue a EU-wide harmonized methodologies for substantiating green claims.
The Apparel and Footwear Cluster pools together representative players of the textile, apparel, leather & footwear value chains for the specific purpose of giving expertise and advice to the European Commission on activities related to the Environmental Footprint transition phase.
The European Green Deal with its Circular Economy Action Plan and its Farm to Fork Strategy announced actions to empower consumers to make informed, healthy and sustainable food choices, including an action to examine ways to harmonise voluntary green claims for food products.
PU Europe, representing the European polyurethane insulation industry, has been following the debate on the Single Market for Green Products for many years and welcomes the opportunity to provide input to the European Commission’s Inception Impact Assessment on a legislative proposal on substantiating green claims.
The ZDH has so far been critical of the European product and organisational eco-balances project. The reason for this was, firstly, the fear that the LCAs will entail significant costs and costs, thereby placing small-scale production at a structural disadvantage compared to industrial production.
Filed in German · English published by the European Commission
When it comes to the empowerment of consumers to play their part in the Circular Economy and the Green Deal, simple, understandable and EU-harmonised information about the sustainability features of a product is key. Any such information needs to be ‘actionable’ by consumers. Brands inform and connect with consumers through product packaging, and can even nudge them towards more responsible behaviour.
Institut Bauen und Umwelt e.V. (IBU) agrees that all environmental claims must be based on transparent, comparable and trustworthy information. Particularly in the construction sector, where individual products can only be evaluated in the context of the complete building, the consistency and reliability of all data is of utmost importance.
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.
COTANCE represents the leather industry in Europe. European tanners supply leather to the most demanding value customers in the luxury, fashion, automotive and home decoration sectors. Leather products play an essential role in consumers’ every-day lives.
Citeo strongly welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission to propose a new legislation on substantiating green claims, aiming at enhancing environmental performance of products and businesses.
This is a great initiative and as sustainability consultants, we strongly support the initiative. As we regularly consult clients on how to make credible claims, we feel that legislation to properly enforce this type of communications would greatly help.
APEAL welcomes the EC public consultation initiative on substantiating green claims. We support the EC establishing legal framework that provides a level playing field, limits the proliferation of methods to measure and assess environmental impacts, limits the proliferation of labels and claims related to environmental information and ensures that the environmental impact of the products placed on the EU market…
CEI-Bois fully supports the ambition of the EU to reduce significantly the environmental footprint of products consumed in the Union and to attain the carbon neutrality target by 2050. CEI-Bois also agrees with the aim of moving towards a more harmonised approach for providing reliable product environmental information.
APPLiA Home Appliance Europe represents the home appliance industry in Europe. Home Appliance manufacturers offer better lifestyles to Europeans, investing over EUR 1.4 billion in R&D and creating nearly 1 million jobs in Europe. The growth of our industry is directly linked to our freedom to innovate for our consumers.
CEPE contribution on the roadmap for a Legislative proposal on substantiating green claims CEPE welcomes the opportunity to comment on the European Commission's roadmap for a legislative proposal on substantiating green claims. The paint, printing ink and artists' colours manufacturers are committed to working towards greater sustainability and gladly share their experience and expertise in light of this initiative.
General comments: The BAK welcomes the intention of the Green Claims Initiative: Consider the introduction of an EU @-@ framework for assessing the environmental performance of products and businesses. Promote the sustainability of goods, services and business models within the EU and make them the standard in the long term. — to focus on the whole life cycle of products.
Filed in German · English published by the European Commission
Aurubis, a world’s leading manufacturer of non-ferrous metals, welcomes the opportunity to provide feedback on the Inception Impact Assessment of the legislative proposal on substantiating green claims. Our recommended options are Option 1 and Option 2.
RUSAL’s input to the European Commission’s public consultation Environmental performance of products & businesses – substantiating claims 1. Expression of support to the EC’s work on the societal ambition to address climate urgency: A common approach to declaring environmental performance of actors in the European market is key to facilitate the removal of barriers to net-zero ambition.
FEFAC, the European Feed Manufacturers’ Association, is an early supporter of the PEF methodology & harmonisation initiative at European level. FEFAC coordinated the Technical Secretariat on the PEFCR Feed for Food-Producing Animals which was published in April 2018.
ACEA welcomes LCA analyses as they are important procedures that can help to reduce a motor vehicle’s impact on the environment and believes that the studies made should be scientifically sound and compare equivalent systems. LCA can be a useful tool to address environmental issues and is applied as internal environmental system for systematically managing environmental improvements in the automotive industry.
MedTech Europe - the European trade association for the medical technology industry including diagnostics, medical devices and digital health - welcomes the opportunity to contribute to the initial roadmap consultation regarding the legislative proposal for substantiating green claims.
PFP, the association representing European primary food processors welcomes the intention of the European Commission to improve the regulatory framework for the use of green claims. In this regard, we would like to highlight the following points: 1) Product Environmental Footprint Category Rules are available for six food and drink sectors only.
ISEAL feedback to the EC roadmap on ‘Substantiating green claims’ 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.
We support the need for reliable and transparent environmental assessment procedures as a foundation for environmental claims and appreciate the possibility to give feedback to this initiative. First, we would like to suggest that clear terms for the various types of Green Claims should be developed. One possibility would be to distinguish: - Single criteria claims (any aspects e.g.
SolarPower Europe response to Legislative proposal on substantiating green claims SolarPower Europe welcomes this legislative initiative and its objective to further harmonise, and bring coherence to green claims on the EU Single Market.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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.
Filed in French · English published by the European Commission
The Consumer Directorate-General contributes to the development, definition and implementation of consumer policy in Portugal, with the aim of ensuring a high level of protection. In recent years, there has been a growing interest of consumers in environmental issues, due to the climate crisis.
Cefic welcomes the opportunity to provide feedback on the initiative undertaken by the European Commission about a new regulatory initiative on substantiating green claims regarding Environmental performance of products & businesses in line with Better regulation principles and criteria (effectiveness, efficiency, relevance, coherence, EU-added value) The European chemical industry represented by Cefic, is highly…
FEAD, the European Federation for Waste Management and Environmental Services, welcomes the European Commission’s initiative to substantiate green claims in order to empower the consumer and business partners for the green transition. Private waste management companies are major operators in this service, operating in 60% of municipal waste markets in Europe, and in 75% of industrial and commercial waste.
Glass for Europe welcomes the European Commission’s initiative on Environmental product performances’ claims and supports the objective to limit the number of methods to evaluate the environmental impacts of the products. The roadmap highlights the central role of the Product Environmental Footprint (PEF) methods to reach this objective.
EuroCommerce welcomes the opportunity to provide feedback regarding the Inception Impact Assessment on substantiating green claims. The attached statement aims to summarize key points from the retail and wholesale sector on green claims and the Product Environmental Footprint (PEF) and support the Commission’s work to assess whether a legislative proposal on substantiating green claims is needed.
GALA srl, natural and organic cosmetics producer, welcomes the new legislative proposal of the Commission for better substantiating green claims. Common approach and methodology could be the key to measure and communicate clear and reliable information on the environmental performance of products.
The EEB welcomes the inception impact assessment for the initiative “Legislative proposal on substantiating green claims”. The EEB actively participates in the Product Environmental Footprint (PEF), its Technical Advisory Board (TAB), as well as the pilot and transition phase projects. The EEB supports the need for standard methodologies to assess the impact on the environment of products on the European market.
The European Copper Institute (ECI) welcomes the European Commission’s efforts to establish positive rules to substantiate environmental claims as a tool to unlock opportunities for a green and circular economy.
Eurogypsum represents the interests of gypsum product manufacturers and believes in the benefits of gypsum for sustainable and comfortable living and working spaces and promotes its contribution to Europe’s built environment.
ADVANSA is a leading European manufacturer of polyester fibres as a raw material to the textile value chain. We are committed to sustainability and fully support the EU initiative about substantiation of environmental claims. In its capacity as a manufacturer in the textiles value chain, our company has already implemented and explores future solutions for sustainable resource use.
FNADE, the French association of environmental services companies, welcomes the commission's new initiative to improve product performance as well as the information on this performance and thus help consumers make a reliable choice.
Verband der deutschen Lackund Druckfarbenindustrie e.V. VdL-Position zur Initiative: Umweltleistung von Produkten & Unternehmen – Nachweise Der Verband der deutschen Lack- und Druckfarbenindustrie e.V. (VdL) unterstützt jede sinnvolle und wirtschaftlich tragfähige Initiative zur Verbesserung der Nachhaltigkeit.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We welcome the EU’s approach to providing information on sustainability and environmental footprint for businesses. If consumers are to become a more sustainable product, it must also be ensured that the information provided is transparent and correct and that greenwashing is prevented as far as possible. We would like to take the opportunity to draw attention to one aspect.
Filed in German · English published by the European Commission
Danfoss input to the European Commission’s roadmap on Substantiating Green Claims Ref. Ares(2020)4509060 - 31/08/2020 August 2020 Danfoss welcomes the European Commission’s inception roadmap on Substantiating Green Claims.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
UECBV sees the upcoming legislative proposal on substantiating green claims as the basement for allowing businesses to go to carbon neutrality. It is of the utmost importance to go towards scientifically based, fair and “harmonised claims” so that efforts are comparable, looking for the same goals and no one is left behind but creating incentive to move forward.
Vattenfall welcomes the EU Commission’s ambition to increase the quality and validation of environmentally green claims. There is a strong need to streamline and concretize claims on environmental performance. We firmly believe this leads to better grounds for decision-making, both in terms of end-customer consumption and in terms of addressing environmental impact throughout the product lifecycle.
Methodology FoodDrinkEurope supports a credible and EU-harmonized environmental footprint methodology based on PEF. The harmonized PEF methodology should be the basis for identifying hotspots, promoting continuous improvement and provide product information to other businesses or consumers.
Lubin, 31 August 2020. ZPPM/89/VII/2020 Komisja Europejska Directorate-General for Environment Unit B1 — Sustainable Production, Products and Consumption 1049 Brussels Belgium Public Consultation — Roadmap — Proposal for a regulation: Ref. Ares (2020) 3820384: Legislative proposal on substance Public consultation — Preliminary Impact Assessment (action plans): Ref.
Filed in Polish · English published by the European Commission
Lubin, 31 August 2020. ZPPM/89/VII/2020 Komisja Europejska Directorate-General for Environment Unit B1 — Sustainable Production, Products and Consumption 1049 Brussels Belgium Public Consultation — Roadmap — Proposal for a regulation: Ref. Ares (2020) 3820384: Legislative proposal on substance Public consultation — Preliminary Impact Assessment (action plans): Ref.
Filed in Polish · English published by the European Commission
The cosmetics industry in Poland shares the European Commission views with regards to the impact of climate change by 2050. The Polish Union of the Cosmetics Industry welcomes the European Commission’s European Green Deal announcement and its goals.
The Norwegian Seafood Federation welcomes the Commission's initiative on legislative proposal on substantiating green claims. The Norwegian Seafood Federation (NSA) represents the interests of approximately 680 member companies. Our member companies represent the entire supply chain from sea to dinner table in the fisheries and aquaculture sectors in Norway.
Comments on public consultation on Legislative proposal on Substances ating green claims: The Danish Agriculture and Food Council thanks the Commission for involving the public and relevant stakeholders in the development of a framework for green claims. We are representing the entire Danish food cluster from farm to fork and are actively working to develop the sector in a more sustainable direction.
Filed in Danish · English published by the European Commission
European Federation for Construction Chemicals Environmental performance of products & businesses – substantiating claims The European Commission launched a public consultation including a draft inception impact assessment of the initiative Environmental performance of products & businesses – substantiating claims.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We support the initiative to further develop and implementation of Environmental Footprint (EF) methods to enhance credible market communication of environmental footprint of products. Especially for products in areas not covered by the EU eco-label. We see a common methodology as a key-factor for achieving a future fair competition regarding environmental performance on the European single market.
Position of European Bioplastics Inception Impact Assessment on legislative proposal substantiating green claims Introduction – the role of bioplastics: The members of European Bioplastics are active contributors, investors and innovators involved in the transformation of the packaging sector.
Construction Products Europe shares the views of the European Commission about the delivery of accurate and reliable environmental information from products. Our industry worked during the last years to accomplish these goals under a European approach considering that the environmental performance of construction products only make sense in the context of the building or the construction works (the final "product").
Please find enclosed the joint feedback from two competent bodies for national ecolabels, SMK (Stichting Milieukeur) and VKI - Austrian Consumer Association (Austrian Ecolabel) as well as the Austrian Position Paper on "Handling Green Claims". In our feedback we express our concerns regarding a possible obligation to integrate e.g.
PepsiCo welcomes the opportunity to provide feedback on the Inception Impact Assessment on the legislative proposal on substantiating green claims. PepsiCo strongly supports the EU’s objective to achieve a circular and green economy as well as climate neutrality by 2050.
The International Wool Textile Organisation (IWTO) represents the collective interests of the global wool industry. We are based in Brussels and our goal is to ensure a sustainable future for wool through scientific research, wool textile education and knowledge sharing. Our members come from all stages of the wool textile pipeline, from farm to retail.
Eurovent appreciates the recognition by the Commission of the proliferation of green claims and the related measurement and assessment methods. National legislation regarding green claims exists, supported in cases by the fact that some Member States recognize specific voluntary labels. This proliferation confuses consumers and industry due to the various methods use to substantiate the claims.
Ecopreneur.eu welcomes the European Commission’s initiative for a legislative proposal on substantiating green claims for products and services. We acknowledge the business need for reliable, comparable and verifiable information to make sustainable decisions. We also recognise the mentioned problems including the significant number of misleading claims.
The European Sawmill Organisation of the Sawmill Industry welcomes the new initiative of the EU Commission to substantiate green claims. Keeping track of consumption footprints globally, which requires good supply chain data and accounting, is increasingly recognised as critical to an inclusive transition to sustainability.
RECHARGE, the industry association for advanced rechargeable and lithium batteries in Europe, welcomes the new legislative proposal for better substantiating green claims. RECHARGE promotes a legislative framework that helps establish meaningful environmental impact indicators based on (a) reliable, comparable and verifiable information, and (b) presented in a clear, specific, unambiguous and accurate manner.
EFPRA, the European Fat Processors and Renderers Association, appreciates the initiative of the EU set in the Green Deal. And we agree that results of environmental foot print calculations should be comparable to give consumer a better overview.
Title of the initiative: Legislative proposal on substantiating green claims Feedback from Veerle Van linden (ILVO), member of Agricultural Working Group of the TAB on PEF B. Objectives and policy options “The options will be further identified during the impact assessment … but could include: [Baseline, Option 1, Option 2, and Option 3]” → It is not clear to me whether member states will be able to choose what…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
LightingEurope takes this public consultation as an opportunity to share some preliminary remarks and questions for the consideration of the European Commission ahead of the drafting of the proposal for a Regulation. LightingEurope makes general remarks on the following issues in its detailed paper attached to this consultation: 1. Proliferation of information requirements 2.
The Global Alliance on Health and Pollution (GAHP) is a Swiss foundation and network of 60+ governments, UN and other international organisations, academia and civil society that promotes greater awareness of the fact that although pollution is responsible for 16% of deaths worldwide, almost entirely in low and middle income countries (LMICs), it receives relatively little policy attention and only a tiny fraction…
Based on the current status, as seen from the field of consumption studies, we agree with the identified need to create more clarity within a very confusing area of legislation and labelling. However, it is paradoxical that reducing complexity is often met with a desire to introduce new schemes or strengthen existing schemes, such as in the area of product labelling.
We agree with the problem definition. Reliable and comparable environmental information about products is urgently needed both for eco-design in producing companies (e.g. in Nordic countries: Salo et al. 2019) and for the demand side, i.e. companies as clients, public procurers and private consumers (Nissinen et al. 2019, Suikkanen & Nissinen 2020).
Joint paper value chain reply on the EU Consultation on Green Claims : In December 2019, the European Commission presented its ambitious Green Deal roadmap, a comprehensive strategy aimed at putting Europe on the right track for climate neutrality in 2050 while encouraging sustainable economic growth. In this strategy, the role of consumers is clearly recognized: this transition won’t happen without them.
The European Steel Association - EUROFER, supports the establishment of a common and consistent assessment framework that will, in principle, reduce cost to industry by limiting the proliferation of assessment methods and labels. This should help retain access to a single market without barriers to trade, and also ensure that the environmental impact of imported goods can be properly assessed.
The Policy Hub welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment "Legislative proposal on substantiating green claims". We recommend the European Commission to further explore option 2 “Establish a voluntary EU legal framework enabling companies to make green claims in accordance with the Environmental Footprint methods, as a complement to existing methods (developed by…
The European Expanded Clay Association, EXCA (www.exca.eu) and its members welcome the opportunity to comment on the Commission Roadmap on Substantiating Green Claims. Expanded clay is a well-proven, high quality, efficient and durable lightweight aggregate suitable for a wide range of applications in the construction sector.
Topsector Logistics The European Green Deal has more forcefully put logistics emissions on the policy agenda of the European Commission. As Topsector Logistics in The Netherlands, we applaud this. As we will explain below, we have been active in reducing transport and logistics emissions in The Netherlands and believe we can contribute to the achievement of the ambitious goals set out.
Green claims and sustainability are complex and there is not one way to go about it. For example I could make a 100% petrochemical based cosmetic with very low Carbon impact as the Carbon is ancient, and low water consumption too.
Feedback to EU on the public consultation of ‘Legislative proposal on substantiating green claims’. Legislation in the area of green claims is needed and welcome. Thank you for this important initiative. This feedback is prepared by Professor Kate Fletcher (Centre for Sustainable Fashion, London College of Fashion, UK) and Professor Mathilda Tham (Department of Design, Linnaeus University, Sweden), experts in…
Dear, An EU initiative on “Environmental performance of products & businesses – substantiating claims” could have far reaching unintended consequences for a worldwide operating sector which is highly regulated and already knows various environmental indicators, many of whom determined by the market.
A universal labelling system is a good idea in theory but not currently considering the shortcomings with PEF (and therefore LCA) methodology which does not sufficiently take into account material renewability, end-of-life impacts, such as biodegradability or microplastic shedding risks, resulting in synthetic fabrics obtaining higher scores than natural ones. If it did, the results could be quite different.
Euromines members are committed to facilitating and encouraging the promotion of safe use, recycling and disposal of products through an understanding of their life cycles. Euromines has made significant contributions to the science of Life Cycle Assessment, on which the Environmental Footprint methods are based.
As Board member of Union of Concerned Researchers in Fashion - relevant or not, I would like to point to the following input from a fellow 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/.
We believe that brands have a responsibility to understand and be transparent about the environmental impacts of their products, and that consumers have the right to access information about the materials and supply chains of the products they purchase.
Within the agricultural sector, it is one of the first, measuring the impact of production by means of life cycle analysis, taking into account all the product’s life stages and the related steps, as well as all the externalities — positive and negative — environmental, social and economic, is widespread.
Filed in French · English published by the European Commission
Competere is a research center based in Rome and Brussels that elaborates ideas to improve our lives, producing and promoting policies and business models to foster innovation and develop better human technology design interaction. Competere is a creative platform where citizens come together to think, brainstorm, discuss, research and advocate for a smarter world.
BIBM, the federation of the European Precast Concrete Industry, fully supports the position of Construction Products Europe on this topic. Our industry actively contributed in the past years to the establishment of a framework for the delivery of accurate and reliable information about sustainability of construction works in the field of standardisation (CEN/TC 350).
• In general: EU framework for methodology on PEF and OEF on voluntary basis in a harmonised matter may be useful – mandatory system not first choice, different P(O)EFCRs in Member States to be avoided – therefore WKO proposing to consider option 1 (update of PEFs and OEFs) or 2 (voluntary legal framework), currently not option 3 (legal framework establishing obligation for claims by PEF/OEF) because of costs and…
Consumers are key to a successful and effective green transition. The fresh fruit and vegetable sector endeavours to supply consumers with safe, high quality and fresh products that also meet their environmental, social and sustainability product expectations. The fresh fruit and vegetable sector is fundamental for a greener European economy, whose impact filters to global markets.
A.I.S.E. calls for measures that are: • based on sound science and in consideration of impacts across the full life cycle of the product and its packaging; • developed in a consistent and coherent way with existing legislation. A.I.S.E. recommends to consider “Option 1” (ie. update the 2013 recommendation) as a policy option.
The intention set in the Green Deal to tackle misleading green claims is laudable. So too is the recognition that consumers need reliable, comparable and verifiable information on the environmental performance of products and services. We disagree, however, that the substantiation of claims should be done using the PEF/OEF method.
CEMBUREAU, the European Cement Association, welcomes the opportunity to provide feedback on the Commission Inception Impact Assessment on a legislative proposal on substantiating green claims. Please find attached a position paper which sets out our views. We hope this can serve as a basis for future exchanges and will be very happy to engage.
The European Container Glass manufacturing (FEVE) industry welcomes the European Commission’s ambition to ensure that consumers and businesses have access to reliable, comparable, and verifiable information to make sustainable decisions. FEVE has been an active member of the Product Environmental Footprint (PEF) pilot phase for food and beverages (on Wine, Packed Water, Beer, Olive Oil and Dairy Products).
The amount of sustainability certifications and markers on products and packaging is confusing for brands, retailers, and especially consumers. Environmental Defense Fund is excited to see the EU develop regulation around product claims ensuring such claims be backed by scientific evidence.
Deutsche Bauchemie fully supports the aim to provide consumers and businesses with reliable, comparable and verifiable information to make sustainable decisions. As a sector, we firmly condemn any misleading claims and “greenwashing”. As a basis for achieving these goals, it is useful and necessary to create a consistent evaluation framework.
Pvthin – the international trade body promoting thin-film photovoltaic (PV) technologies - welcomes the European Commission’s initiative on ‘green claims’ and the overarching objective to harmonise these claims in the EU. The thin-film PV industry would support this approach as a continuation of the work on EU Product Environmental Footprint Category Rules (PEFCR) for PV (2013-2018 Pilot).
It welcomes the Commission’s intention to present an ambitious strategy that sets out concrete roadmaps to achieve the 2050 climate targets. The Circular Economy Action Plan – For a clean and more competitive Europe" aims to make a decisive contribution to this. It is undisputed that companies, through their products and services, are and must be key levers for achieving the above objectives.
Filed in German · English published by the European Commission
Vitex SA, a Greek SME paint manufacturer, appreciates the opportunity to comment on the European Commission's roadmap for legislative proposal on substantiating green claims. Seeking for opportunities to improve the sustainability of our products, we fully support an EU legal framework enabling companies to make green claims in accordance with the Environmental Footprint methods, as a voluntary tool towards a better…
Cosmetics Europe represents the cosmetics and personal care industry in Europe. From dermo-cosmetics, fragrances, make-up and shampoos, to soaps, sunscreens and toothpastes, cosmetics and personal care products play an essential role in consumers’ every-day lives. We welcome the opportunity to engage on the legislative proposal on substantiating green claims.
FEP – the European Federation of the Parquet industry – is welcoming the EC Inception Impact Assessment on the “Legislative proposal on substantiating green claims” initiative. This initiative is clearly supporting the recent EU Green Deal, the New Circular Economy Action Plan, and the Renovation Wave for which the European manufacturers of parquet are playing a key role by producing, with a relatively low carbon…
The Swedish Forest Industries Federation represents the Swedish forest industry. Our members refine wood resources to bio-based products. This includes among others pulp, paper, board, packaging material, sawn timber, refined wood products and advanced biofuels. Some members have large forest holdings. The Swedish forest industry is highly trade intensive.
Australian Wool Innovation Ltd believes PEF is a commendable initiative, but it is not yet market ready. Any planned adoption must be voluntary only. This system is not yet suited to handle complex global food and fibre supply chains and further methodological development is required.
I fully support the need for a more harmonised approach for providing reliable environmental information, increasing simplification and reduction of administrative burdens as set out in this proposal. PEF/OEF approaches are commonly used by many businesses in the Capitals community as a foundational element of their work. It is an extremely helpful tool and we advocate its use.
WEW Engineering welcomes this initiative by the European Commission and their intention to standardise the approach to claims made about the effect of a product on the environment. From the indicative options provided WEW Engineering would support option 3 which may see the introduction of a directive to ensure claims are substantiated by Environmental Footprint methods.
Input from the Nordic Swan Ecolabel The Nordic Swan Ecolabel welcomes the initiative to ensure that environmental claims are reliable and are not leading to greenwashing. We also support that any claim should be based on an assessment of the overall life cycle impact of the product or service for which the claim is made.
Fur Europe welcomes the legislative proposal on substantiating green claims and supports in principle the use of product environmental footprint. But some issues need to be considered to make the PEF scheme truly functional and inclusive, which is a prerequisite to ensure the success of the legislation. Many terms may be used to describe products as having reduced environmental impacts.
In the field of plastic reduction and plastics sustainability, the Flustix initiative already provides, what the EU Inception Impact Assessment strives for. The Flustix initiative is dedicated to plastic reduction and the avoidance of plastic waste by recycling to support the responsible use of fossil fuels.
ROCKWOOL Group welcomes the legislative proposal from this inception impact assessment on substantiating green claims. ROCKWOOL Group produce products from abundant raw material, our products contribute to a sustainable built environment and circular economy.
The BDI supports the further development of the Product Environmental Footprint (PEF) method as a voluntary procedure for evaluating the environmental impact of products. The further development should be brought in line with the ISO standards for calculation and reporting or communication. The methods for calculating (eco)toxicity need to be technically revised.
EUROPEN supports the general objective of this initiative, which is to unlock opportunities for the circular and green economy, including by fostering the growth of green markets through value chain thinking and ensuring a more efficient use of resources.
EDA supports the use of the Product Environmental Footprint (PEF) methodology to substantiate green claims in the EU. We support action by the EU Commission to integrate the PEF into existing or new policy instruments, to reward sustainable practices and limit the risk of credibility loss that the proliferation of green claims may cause.
EuroWindoor support to have one harmonized European method of making green claims. For construction products the CEN/TC350 suite of standards (EN 15804, EN 15978 etc.), aligned to PEF methodology, should be preferred with the arguments that: 1) the systems of EPDs for construction products and building evaluations are already somewhat well established 2) intermediate (construction) products and the final building as…
Putting some order in the world of green claims is definitely useful and important. However, there is a big risk that the use of certain methodologies, such as PEF / OEF, could make life much more difficult for craft and SMEs in terms of higher costs and administrative work.
Health Care Without Harm (HCWH) Europe welcomes and supports the European Commission introducing a standard methodology for assessing products’ environmental impacts and requiring companies to substantiate environmental claims.
Green claims are an issue that must be addressed by the UE with priority, many traders are taking advantage of consumers’ growing interest in environmental matters because of the climate crisis and are using green claims to differentiate themselves from their competitors. Many claims are not or cannot be substantiated.
Awareness of the need to live a more sustainable life, including making our consumption patterns more ecologically sustainable, is growing. People can only act accordingly if they have access to reliable and understandable information on the environmental footprint of the products they wish to buy.
Manufacturers of manufactured products do not systematically report all data on the materials and/or substances they use. In addition to the need to inform consumers about the actual potential for recyclability and the composition of the products they buy (necessary conditions for a reasoned purchase), the processing facilities which recover those products for recycling or energy recovery do not know the composition…
Filed in French · English published by the European Commission
Energizer agrees that the provision of reliable, comparable and verifiable information on environmental impacts of different products is essential for making informed purchases and investments. Energizer is thus in favour of a coherent policy framework that empowers consumers to not only make more sustainable choices, but to trust the green claims on the devices they purchase.
The Spanish Ministry for the Ecological Transition and Demographic Challenge considers that consumers and organizations need truthful information to make sustainable decisions and under the framework of circular economy. It is necessary to clarify how this strategy is going to define the existing audit and eco-management system (EMAS) in the EU.
Many traders are taking advantage of consumers’ growing interest in environmental matters because of the climate crisis and are using green claims to differentiate themselves. Many claims are not or cannot be substantiated. This triggers confusion and mistrust among consumers and jeopardizes their active contribution to the transition towards a green economy.
Lean & Green EU Lean & Green EU is a fact-based data-driven recognition scheme for companies in logistics, founded in 2007. Lean & Green EU recognizes companies that realize reduction targets in CO2 emissions in a 5-star scheme. The first 3 stars reward a relative reduction in emissions and improvements in the data position of the company: without good data no recognition scheme can function.
LEAF (Linking Environment And Farming) welcomes the Commission’s intention to support the substantiation of green claims, noting the importance of provision of reliable, verifiable information on environmental impacts. LEAF is a leading global organisation delivering more sustainable food and farming.
We share the opinion that consumers and organisations need reliable and verifiable information to make sustainable decisions, and this is essential in the context of the circular economy, although it’s not clear how this initiative will be aligned with the existing EU Eco-management and Audit scheme (EMAS), particularly in the case of environmental performance of businesses.
European Flour Millers welcome this Commission's initiative, as it aims to increase trustworthiness of environmental claims. The EU pilot phase on Product Environmental Footprint (PEF) was designed as a bottom-up process where industry sectors could apply for voluntary participation. So far, only a few food & drink sectors have participated to this phase.
The Committee of Environmental Verifiers (UGA) strongly supports the Commission’s efforts to present an ambitious strategy with concrete roadmaps for achieving the 2050 climate targets. However, the UGA rejects all the above options as it considers that EMAS already provides a reliable tool for the presentation and validation of environmental performance, in particular with regard to the OEF.
Filed in German · English published by the European Commission
Great initiative! Having at European level a regulation making the LCA practice mandatory when communicating quantified information about the environmental performance of products would be great - something similar is already required by the French law. In those cases, it will be required that the LCA practice be done according to ISO or CEN standards (such as ISO 14044), or PEF guidance.
While the approach to harmonising environmental claims and labels is welcome, the development of the Product enviromental Footprint (PEF) still requires major changes, especially for food, especially organic food.
Filed in German · English published by the European Commission
IFOAM Organics Europe (IFOAM OE) welcomes the Commission's initiative on the "Environmental performance of products & businesses – substantiating claims", as it aims to increase trustworthiness of environmental claims. Similarly, IFOAM OE welcomes that the Farm to Fork strategy stipulates that “the Commission will (…) examine ways to harmonise voluntary green claims”.
We support this initiative. In order to make sustainable decisions, consumers and businesses must have reliable, comparable and verifiable information on environmental impacts of products and services and this information should be presented in a clear, specific, unambiguous and accurate way.
In relation to the proposed options, we favour option 2, with the necessary clarification that only taking into account PEF to substantiate claims is a weak point that risks hindering operators and products for which the EU has long recognized the environmental value and the importance in terms of sustainability, to the point of establishing its own logo and a specific control system for the verification of…
We would like to explicitly support the initiative by the FiBL Germany and refer to the already developed EU standard, the Product Environmental Footprint (PEF). We are working through a research project of the Federal Office for Agriculture and Food (FKZ 28190E008 + E077) to further develop the PEF to allow reliable comparisons in the assessment of conventional and organic products.
Filed in German · English published by the European Commission
The European Carton Makers Association support the European Green Deal and the aspiration to move from a part linear to fully circular economy. We fully support this ‘Substantiating Claims’ initiative as a route for reducing the quantity of misleading claims – so called ‘greenwash’ - and providing consumers and businesses with reliable, comparable and verifiable information to make sustainable decisions.
EDANA developed a Sustainability Vision, giving clear insight into the priority topics on sustainability for our industry. Building Trust, through transparency to consumers and other stakeholders is an essential pillar of this Vision. When making green claims, this transparency allows for reliable and verifiable information on environmental impacts of different products.
The European Panel Federation (EPF), welcomes the Inception Impact Assessment on environmental performance of products and businesses. The wood-based panels industry produces sustainably sourced circular products with a low environmental footprint.
Inception impact assessment: Legislative proposal on substantiating green claims (14 August 2020) The Industrial Minerals Association, IMA-Europe, and its members welcome the opportunity to comment on the Commission Roadmap on Substantiating Green Claims. Minerals' unique properties provide specific functions in a myriad of products and processes.
The Wirtschaftsvereinigung Stahl welcomes the Commission’s efforts to create a single assessment framework for environmental performance of products and services, aiming at cost savings by limiting the number of assessment methods and their communication. An improved evaluation framework could help to achieve a similar assessment for imported products as for products produced in the EU.
Filed in German · English published by the European Commission
FORATOM welcomes the goal of ensuring that consumers receive accurate information about the environmental footprint of products and services available in the EU. In order to be credible, such assessments need to be science-based and applied in the same way. Furthermore they should take account the full life cycle of the product or service both within and outside the EU.
REPLY TO THE CONSULTATION ON THE INCEPTION STUDY ON ENVIRONMENTAL PERFORMANCE OF PRODUCTS AND BUSINESSES – SUBSTANTIATING GREEN CLAIMS ACE contribution to the consultation on the inception impact assessment ACE acknowledges the fact that existing claims are not always reliable and in some cases are greenwashing the reality.
The AöL e.V. supports the Commission’s efforts to harmonise environmental labels. However, calculating and determining the environmental impact along the product value chain in a simple input/output inventory, as has been done so far by pilots on the PEF, is too short.
Filed in German · English published by the European Commission
BBIA represents producers of compostable packaging materials in the UK. We strongly support the Option 3 to establish a binding legal EU wide framework for environmental claims. We are sick of companies announcing their packaging to be "biodegradable" without having supporting scientific evidence, standards or test methodologies to support these claims.
Producers of molluscs in the 6 main EU shellfish producing countries, meeting within the AEPM, have for several years been advocating for clear, precise and unambiguous information on the environmental footprint of their products. They also have long been in favour of “Level Plying Field” and “Green washing”. For all these reasons, the AEPM supports the fourth option proposed by the Commission.
Filed in French · English published by the European Commission
We support this initiative. Consumers and businesses need reliable, comparable and verifiable information to make sustainable decisions. Only this way are they able to make well-informed decisions. Their role is crucial in order to develop sustainable supply chains. Unified and pragmatic solutions are needed to create affordable, comparable answers and to create scale.
I support this initiative, to make reliable and comparable claims. At the same time, the EU will have to support the development of PEFCR, to make sure that the requirements can really be covered. Best Regards, N. Kahil Group Quality, Security & Sustainability Director
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