Sustainable products - disclosure of information on unsold consumer products

The European association representing manufacturers of contact lenses and lens care products, EuromContact, welcomes the opportunity to comment on the draft Commission implementing regulation developed under Article 24 of the Ecodesign for Sustainable Products Regulation (ESPR).

The Alliance du Commerce is the main professional federation of the personal equipment sector in France, representing department stores, popular shops and clothing and footwear stores (more than 150 000 jobs and 16 000 stores based in France).

Filed in French · English published by the European Commission

A more complete analysis was not possible, as the draft delegated act setting out derogations from the prohibition of destruction of unsold consumer products was not accompanying the draft Commission implementing regulation regarding the details and format for the disclosure of information on discarded unsold consumer products.

CONAI, the Producers’ Organisation (PRO) designated in Italy to achieve the national recycling targets for all packaging placed on the market, refers to the harmonisation of legislation, accounting consistency and transparency in the monitoring of material flows, in particular with regard to the provisions of Regulation (EC) No 2025/40 on packaging and packaging waste (PPWR) and the EU own resource mechanism based…

Filed in Italian · English published by the European Commission

Eurochambres welcomes the opportunity to provide feedback on the draft implementing act under the Ecodesign for Sustainable Products Regulation (ESPR), concerning the disclosure of information on unsold consumer products. We appreciate that demands, such as the establishment of a harmonised reporting format and a deferred application date, have been addressed.

Verification of the disclosed information should rely only on an ex-post, risk-based verification by national authorities, based on Article 24(2) of the ESPR. The proposed verification requirement through third-party limited assurance for companies subject to the Corporate Sustainability Reporting Directive (CSRD) should be removed.

The Bundesverband E-Commerce und Versandhandel Deutschland e.V. (bevh) represents companies of all sizes and types of trade (online, multichannel, catalogue, TV shopping, platform traders and operators) active in Germany. The members of the bevh account for more than 75 % of total industry turnover. In addition, more than 130 service providers from the e-commerce sector are affiliated to the association.

Filed in German · English published by the European Commission

Founded in 1973, the Fédération de la Haute Couture et de la Mode (the Federation or the FHCM) represents over a hundred of the most recognized French and other international brands. As a founding member of the European Fashion Alliance, which contributes as an expert to the Ecodesign Forum, the FHCM welcomed with great interest the public consultation.

The European Environmental Bureau welcomes this opportunity to share feedback on the draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) 2024/1781 as regards the details and format for the disclosure of information on discarded unsold consumer products.

Please find attached feedback prepared by Irish Manufacturing Research, a Research and Technology Organisation (RTO), in its role as the secretariat of CIRCULÉIRE the National Platform for Circular Manufacturing and Irelands first industry-led public-private partnership dedicated to scaling circular innovation and on behalf of its industry network members.

The European Power Tool Association (EPTA) welcomes the opportunity to provide feedback on the Draft Implementing Regulation laying down rules for the application of Regulation (EU) 2024/1781 of the European Parliament and of the Council as regards the details and format for the disclosure of information on discarded unsold consumer products. Please find our comments in the enclosed position paper.

Ecommerce Europe warmly welcomes the publication of the draft Implementing Regulation and the related Annex providing common details and disclosure format, specifying Article 24.1 of Regulation (EU) 2024/1781. We especially appreciate the European Commissions decision to set a deferred entry into application of the Implementing Regulation, which will contribute to the successful implementation of the new disclosure…

Toy Industries of Europe (TIE) welcomes the opportunity to provide feedback to the Draft Implementing Regulation laying down rules for the application of Article 24.1 of Regulation (EU) 2024/1781, also known as Ecodesign for Sustainable Products Regulation (ESPR). Please find our comments in the enclosed document.

We welcome the opportunity to share feedback on the draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) 2024/1781 as regards the details and format for the disclosure of information on discarded unsold consumer products.

ITI welcomes the opportunity to respond to the European Commissions public consultation on the draft implementing regulation laying down the format and details for disclosing information on discarded unsold consumer products, as foreseen under Article 24 of the Ecodesign for Sustainable Products Regulation (ESPR).

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, would like to comment on Annex I, the format for the disclosure of information on discarded unsold consumer products.

CNMI welcomes the opportunity to provide comments to the draft implementing regulation adopted under Article 24 ESPR. This contribution sets out CNMIs main concerns and related recommendations regarding the disclosure obligation mandated by Article 24 ESPR and further detailed under the Implementing Regulation, taking into account and outlining the perspective of the Italian high-end fashion industry.

"The Policy Hub welcomes the opportunity to provide further input on the Commissions work for developing secondary legislation regarding reporting obligations on discarded goods and the establishment of derogations to the prohibition on the destruction of unsold goods.

The European Fashion Alliance is a coalition of national and regional fashion councils, clusters, and industry organizations across Europe. EFA aims to empower a prosperous European fashion ecosystem and serves as a strong common voice advocating for and accelerating the transition of European fashion towards a more sustainable, innovative, inclusive, and creative future.

EURATEX, the European Apparel and Textile Confederation, appreciates the opportunity to provide feedback to the draft Implementing Act (IA) on the details and format for the disclosure of information on discarded unsold consumer products. Building on our previous input to the development of the draft legislation, we would like to provide additional remarks in the enclosed file.

CEPE, The European Council of the Paint, Printing Ink and Artists' Colours Industry would like to submit its inputs to the Commission as part of the consultation on the disclosure of information on unsold consumer products.

Snitem supports Medtech Europe's position : MedTech Europe welcomes the European Commission public consultation on the draft Implementing act according to Art. 24(3) to lay down the details and format for the Art. 24- disclosure of information requirement and possibility to comment on the requirement to disclose information on unsold consumer products.

LightingEurope welcomes the opportunity to provide feedback to this consultation. We support the deferred application date of the Implementing Act, as well as the flexibility granted to companies regarding the format to be used during the transitional period. However, we believe that the final Implementing Act should include improvements concerning verification.

The proposed reporting requirements under Article 24 of the ESPR Regulation (EU) 2024/1781 are set to be implemented across industries. Anima Confindustria wishes to express its concerns regarding the potential impact these obligations may have on the sectors it represents. You can find in the attached document the ANIMA contribution to the call for feedback on disclosure of information on unsold consumer products.

The Right to Repair Europe coalition welcomes this opportunity to share feedback on the draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) 2024/1781 as regards the details and format for the disclosure of information on discarded unsold consumer products.

Istanbul Apparel Exporters Association (İHKİB), representing over 24.000 member companies in Türkiyes apparel sector, welcomes the European Commissions commitment to reducing the environmental impact of unsold consumer products through enhanced transparency. As a major production and export country, Türkiye plays a critical role in the EUs textile supply chain and fully supports the Unions sustainability goals.

The social economy and Solidaire organisations note that the unsold products offered are no longer an act of philanthropy but a gesture to dispose of unsold goods and objects. In France, the AGEC law, which prohibits the non-destruction of unsold goods, has not led to a significant increase in donations to associations, rather than the multiplication of intermediaries and start-ups to offer key solutions for…

Filed in French · English published by the European Commission

IKEA, represented by Inter IKEA Group and Ingka Group, welcome the publication of the draft Implementing Act under the ESPR. We acknowledge the Commissions efforts to establish a workable framework that enables the collection of comparable data, which is essential to support effective measures against the unjustified destruction of goods.

IKEA, represented by Inter IKEA Group and Ingka Group, welcome the publication of the draft Implementing Act under the ESPR. We acknowledge the Commissions efforts to establish a workable framework that enables the collection of comparable data, which is essential to support effective measures against the unjustified destruction of goods.

EuroCommerce welcomes the Commissions Implementing Act on the disclosure of information regarding discarded unsold consumer products, bringing much needed clarity on compliance. We are pleased to see that the Commission has taken into account the feedback provided by the sector, reflecting a balanced and pragmatic approach to implementation.

As the European Commission, is currently consulting stakeholders on the disclosure of information on unsold consumer products, under the Ecodesign for Sustainable Products Regulation, EPEE, appreciates the opportunity to provide feedback. The paper attached answers the Commissions call for feedback, published on the Have Your Say platform.

Unsold consumer goods not only represent a squandering of natural resources (water, energy, labour, raw materials) but also adds to landfill and incineration volumes, overloads recycling needs and reinforces patterns of overproduction. When destroyed, they represent a regrettable failure of our consumer society and a lock in to the linear economy.

ADELMA, representing Spanish detergents and cleaning and maintenance products industry (including biocides), welcomes the European Commissions initiative to clarify disclosure requirements for unsold consumer products.

The Polish Association of Cosmetic and Detergent Industry (PSPKD) fully supports the objectives of Regulation 2024/1781 on establishing a framework for setting ecodesign requirements for sustainable products (ESPR), including responsible management of unsold products.

Filed in Polish · English published by the European Commission

VDMA Statement on ESPR Public Consultation: Concerns Regarding Article 4 Verification Obligations for Discarded Unsold Consumer Products As the representative voice of the mechanical engineering industry in Europe, the VDMA welcomes the overarching aims of the Ecodesign for Sustainable Products Regulation (ESPR) to enhance sustainability, promote circularity, and reduce environmental impact.

The European Furniture Industries Confederation (EFIC) welcomes the opportunity to provide input to the consultation on the draft Implementing Regulation detailing the format and content of disclosures on discarded unsold consumer products under the Ecodesign for Sustainable Products Regulation (ESPR). The attached paper presents our recommendations to address the identified issues.

Cosmetics Europe looks with great interest at the draft implementing act on the details and format for the disclosure of information on discarded unsold consumer products. We note that many comments presented during the last months, including during the Ecodesign Forum meeting in February 2025, were reflected in the draft act.

APPLiA is thankful for the opportunity to comment on the draft Implementing Regulation detailing companies disclosure obligations under ESPR. APPLiA has identified several areas requiring clarification and adjustment within the current draft. This paper outlines our recommendations to address these concerns.

MedTech Europe welcomes the European Commission public consultation on the draft Implementing act according to Art. 24(3) to lay down the details and format for the Art. 24- disclosure of information requirement and possibility to comment on the requirement to disclose information on unsold consumer products.

The Polish Union of the Cosmetics Industry strongly welcomes timely presentation of the draft regulation on the format of reporting of the discarded products according to the ESPR regulation. Also, we appreciate the simple format of reporting, and optimal granularity. Some of our postulates raised within the ingoing discussion were addressed.

Techniek Nederland is the Dutch employers' organization representing approximately 6,000 companies in the technical service and installation sector, the repair and refurbish sector and the technical retail sector. Techniek Nederland has expressed its support for a ban on destruction of unsold goods in the initial decision-making on ESPR (and long before that).

We would like to thank the European Commission for preparing and publishing the draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) 2024/1781 of the European Parliament and of the Council as regards the details and format for the disclosure of information on discarded unsold consumer products.

The Japan Business Council in Europe (JBCE) and the Japanese 4EE industrial associations (JP4EE) appreciate the continued opportunity to engage in dialogue with the European Commission concerning the implementation of the Ecodesign for Sustainable Products Regulation (ESPR), particularly with regard to the draft implementing act on the disclosure of unsold consumer products.

The Federation of the European Sporting Goods Industry (FESI), representing around 1,800 sporting goods manufacturers covering 85% of the European market, welcomes the opportunity to provide feedback on the European Commission's draft implementing act on the regulation and disclosure format on the disclosure of discarded unsold consumer products.

Otto Group is a German family company based in Hamburg. Its business covers the segments of platforms, brand concepts, merchants, services and financial services. Our company is characterised by a high level of corporate responsibility and collaboration. We express our commitment to Germany’s place of business.

Filed in German · English published by the European Commission

EUREFAS - the European Refurbishment Association - welcomes the opportunity to provide high level comments on the draft Act. Our association gathers actors of the refurbishment sector interested in ensuring long-term sustainability of the consumer electronics industry by allowing devices to get multiple use lives.

The National Institute for Circular Economy (INEC) calls for support for business models for re-use and donation. This support is essential to make the ban on the destruction of unsold non-food products a real lever for the green transition.

Filed in French · English published by the European Commission

On 12 June 2025, the European Commission published the draft implementing act under the Ecodesign for Sustainable Products Regulation (ESPR) concerning the reporting of unsold consumer goods. Despite recommendations from industry, Article 4 introduces a requirement for third-party verification through a limited assurance process.

As the proposed reporting requirements under Article 24 of Regulation (EU) 2024/1781 which establishes a framework for setting Ecodesign requirements for sustainable products (hereinafter referred to as the ESPR) are set to be implemented across industries, EHPA wishes to express its concerns regarding the potential impact these obligations may have on the heat pump sector.

As a member of ECOS, CRNI welcomes the European Commissions draft implementation of Regulation (EU) 2024/1781 regarding disclosure of information on unsold consumer products. However, we share our colleagues concerns regarding factors that could undermine its intended impact.

The Austrian Ministry for Agriculture and Forestry, Climate and Environmental, Regions and Water Management welcomes the opportunity to share feedback on the draft implementing act concerning details and format of the disclosure of information on discarded unsold consumer products. The current regulation focuses on discouraging destruction through disclosure.

These new regulations mean a significant amount of additional bureaucracy for companies. However, bureaucratic hurdles are already one of the biggest challenges for German and European companies. In view of the fact that companies do not dispose of products without good reason and the EU Commission has set itself the goal of reducing reporting obligations for companies by up to 25% (up to 35% for SMEs) by the end of…

SPECTARIS ist the German industry association for optics, photonics, analytical and medical technology in Berlin. Many products made by our members - such as spectacle lenses, spectacle frames, contact lenses, medical-surgical belts, and bandages - are regulated under the Medical Devices Regulation (EU) 2017/745 and must meet high safety and quality standards.

KTF focuses on three elements that could be improved to ensure that the IAs can effectively contribute to the environmental objectives of the ESPR and the broader competitiveness agenda of the European Commission: VERIFICATION of the disclosed information: KTF recommends verifying the disclosed information through a risk-based approach carried out by national competent authorities using the tools in Article 24(2)…

ZVEI e.V. represents the common interests of the electrical and digital industry in Germany with more than 1,100 members. We welcome the opportunity to contribute to the consultation on disclosure of information on unsold consumer goods under Regulation (EU) 2024/1781 (ESPR). A critical point from our perspective is the use of limited assurance as verification method.

SHEIN feedback on the Implementing Regulation on the disclosure of information on unsold consumer products As a global fashion and lifestyle e-retailer, SHEIN welcomes the opportunity to provide feedback on the draft Implementing Regulation on the disclosure of information on unsold consumer products.

EHI members are committed to the objectives of the Ecodesign for Sustainable Products Regulation to foster the production of more environmentally sustainable and circular goods, and we welcome the opportunity to express our views on the draft implementing act.

We welcome the initiative of the Commission and have reviewed the documents submitted for consultation on the type of information to be published regarding the disposal of unsold products under the ESPR Regulation. However for better comprehension, we would like to address three comments to the Commission regarding the publication of information for footwear products: 1.

AIC and AISDPCL remain fully committed to supporting the objectives of the Ecodesign for Sustainable Products Regulation (ESPR), including the responsible management of unsold consumer products. We appreciate the opportunity to contribute to the development of the implementing act and trust that our recommendations will support a balanced, practical, and legally sound framework.

EU Commission July 8, 2025 LOBU DI-2021-23557 Danish Industry (DI) response on disclosure requirements regarding unsold con-sumer products Danish Industry (DI) thanks the EU Commission for the opportunity to respond to this consultation. DI represents more than 20.000 companies within numerous industries from production, retail and construction to consulting and tourism.

A.I.S.E., representing the European cleaning and maintenance products industry, welcomes the European Commissions initiative to develop an implementing act detailing the disclosure requirements (details and format, including the delimitation of product groups and how to verify such information) for unsold consumer products.

Dear, please find in attachment the position of the competent authorities in Belgium on the draft delegated Act and its annex. We transmit the position as OVAM (Flemish competent authority) but it is a consolidated position of all competent authorities in BE. Best regards,

We welcome the opportunity to share feedback on the draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) 2024/1781 as regards the details and format for the disclosure of information on discarded unsold consumer products. We look forward to continuing to work with the Commission to ensure effective reporting and a successful Implementing Act.

We welcome the initiative to request greater transparency from companies regarding their unsold products and the management practices applied. The reporting templates provided appear to be comprehensive and relevant. However, we believe it would be appropriate to go further by promoting best practices through a system of incentives.

We believe it is appropriate for the Commission to clarify, for example through a FAQ document, that electronic equipment intended for installation by a professional (e.g. CCTV, PV installations, etc.) should not be included in the definition of "consumer products", even when purchased by a domestic user as part of a service.

The scope of the reporting obligation should initially be limited to durable consumer goods, or for example to the product groups listed in Annex II, in order to give companies sufficient time to prepare for this new and demanding reporting requirement. The obligation is entirely new and will require changes to systems, verification processes, and operational practices.

CCIA Europe welcomes the European Commissions public consultation on improving EU requirements for the disclosure of information on unsold consumer products. The association supports the goal of increasing transparency and reducing unnecessary waste in line with the broader sustainability objectives of the Ecodesign for Sustainable Products Regulation (ESPR).

We are concerned that the specificities of cooperative/associative retailer groups and franchise groups are not taken into account, particularly in regard to the reporting obligations. Under the proposed implementing act, a central organization of a group of independent retailers operating as one brand cannot report on behalf of its member retailers because they are not subsidiaries, while an integrated retail chain…

Finnish Forest Industries Federation supports the prohibition of the destruction of unsold consumer goods. However, there are still unclear points regarding what the implementing acts on the disclosure of information on discarded unsold consumer goods will include. The implementing acts should consider only the products made available on the market, as defined in the ESPR FAQs.

In the last 5 years, Stichting CareCycle has been active in collecting and monitoring excess unused non-invasive medical devices class 1. This is to: — understand the nature and extent of this waste and, if possible, redistribute it.

Filed in Dutch · English published by the European Commission

Our feedback highlights the urgent need for the European Commission to align sustainability goals with digital transformation by accelerating the adoption of Digital Product Passports (DPPs), enhancing interoperability through global standards like MLETR and eIDAS 2.0, and simplifying compliance for businessesespecially SMEs.

We welcome the move towards greater transparency on the destruction of unsold consumer products. However, we would like to offer the following critical observations and suggestions for improvement: 1. Lack of Positive Incentives The current regulation focuses solely on discouraging destruction through disclosure.