AIM - European Brands Association

AIM, the European Brands Association, represents manufacturers of branded consumer goods in Europe in the food, beverage, personal care, home care, luxury, toy and apparel categories. Our members are all intent on delivering trusted and high-quality goods to consumers across Europe.

--- EXECUTIVE SUMMARY --- Around 276billion worth of consumer goods is traded within the EU annually. This represents 61% of all EU-produced consumer products, meaning most goods produced in the EU stay within the EU. The remaining 39% is exported globally, accounting for 33% of the EUs overall trade surplus.

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…

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.

FMCG supply chains are central to the EU economy, supporting 276bn in intra-EU trade, 182bn in exports, 99bn in annual investment and 4.8 million jobs. They also purchase around 70% of farmers output, meaning downstream trading conditions directly shape upstream income stability, resilience and investment. Unfair trading practices (UTPs) remain widespread and impact the EUs competitiveness.

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.

AIM, the European Brands Association, fully supports the Commissions intention to develop an action plan to combat online fraud. One key modus operandi of online criminals must be addressed in any such action plan: fraudsters (mis)use of brand, company and well-known individuals names to gain the trust of their unwitting victims. Please find attached our comments.

AIM, the European Brands Association, thanks the Commission for appreciating that the current Regulation on market surveillance and compliance of products should be updated to better protect European consumers, businesses, environments and markets from illegal, dangerous and non-compliant goods. Please find attached our comments.

AIM, the European Brands Association, welcomes and supports the European Commissions proposed Regulation to enhance cross-border enforcement against unfair trading practices (UTPs) in the EU. This initiative marks a significant step towards ensuring greater fairness and transparency in the consumer goods supply chain.

AIM, the European Brands Association, thanks the Commission for this consultation. Regulation 608/2013 is a cornerstone in customs and intellectual property right holders fight against the ever-increasing tide of illegal items entering the EU, serving as our primary means to protect European consumers, environments and businesses.