AIM - European Brands Association

AIM - the European Brand Association's feedback is as follows on this initiative. We call for the alignment of the applicability date for Annex I and Annex II high-risk AI systems to 2 August 2028 in order to avoid conditional timelines linked to future standards and guidance that risk creating legal uncertainty; A clear, predictable and uniform implementation timeline for high-risk AI obligations that provides…

AIM - the European Brand Association's feedback is as follows on Digital Omnibus proposal. We would urge: A proportionate, risk-based application of new Article 88a on storing and accessing personal data in terminal equipment, recognising distinctions between low-risk first-party uses and cross-site tracking; Careful calibration of Article 88b on automated and machine-readable consent signals to ensure technical…

AIMs Key Asks We call for: The prohibition of gold plating and the consistent application of digital rules across all Member States to avoid fragmentation and strengthen the Single Market. The simplification of the EU data acquis (Data Governance Act, Free Flow of Non-Personal Data Regulation, Open Data Directive) to reduce compliance burdens while safeguarding policy objectives.

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.

AIM, the European Brands Association, welcomes the European Commissions proposal on the Packaging and Packaging Waste Regulation (PPWR). The branded consumer goods industry acknowledges the need for change and wants to be a driving force in the transition to a clean, circular and climate-neutral economy.

AIM, the European Brands Association, fully supports the objective of the Green Deal towards a clean, circular and climate neutral economy. Focusing on eco-design for packaging from a holistic point of view has long been a priority for branded goods manufacturers, and at the forefront of many innovative measures and R&D investments in recent years.

--- 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 high-level preliminary comments on CSDD proposal: AIM – the European Brands Association – is supportive of an EU harmonised legislative framework for human rights and environmental due diligence. We welcome the fact that the European Commission finally released its proposal for a Directive on Corporate Sustainability Due Diligence in late February 2022 but have a number of concerns on key aspects of the…

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.

AIM, the European Brands Association's, key points on the DFA: Enforcement must come first: effective implementation of existing rules (DSA, DMA, CRD, UCPD, GPSR) before creating new obligations; Require all traders targeting EU consumers to have a legal presence in the Union, or make platforms liable for third-country traders; Extend the Know Your Business Customer (KYBC) principle to all intermediaries, not only…

AIM, the European Brands Association, is grateful to the European Commission for its considered draft Digital Services Act (“DSA”), which should help to ensure that the European Union remains at the vanguard of protecting online consumer and business trust, safeguarding both rights and citizens.

AIM, the European Brands Association welcomes the EU Commission initiative to consult on the future Digital Services Act. In our view the EU Commission has identified correctly the main challenges and has suggested, both in the Roadmap/Inception Impact Assessment and the Public Consultation, measures (Options 2+3) that would be appropriate and proportionate to address: the Single Market context, the challenge of…

The AIM Anti-Counterfeiting Committee thanks the Commission for the opportunity to comment on this extremely important proposal. In order to protect our consumers, creators, innovators, economies and environment, European intellectual property right holders are actively engaged in the global fight against counterfeiting and piracy, in which customs are an essential partner.

Intellectual property right holders rely on customs officers to target, control and detain shipments of illegal - including counterfeit, sub-standard and non-compliant - goods at the EU’s borders. The AIM Anti-Counterfeiting Committee thanks the EU’s Customs Authorities for their excellent cooperation in fighting this global illegal trade over many years and is grateful to the Commission for consulting European…

Avenue des Gaulois 9 B-1040 Brussels Belgium Tel: [phone removed] TR: 107438267901 AIM FEEDBACK www.aim.be European Commission’s call for evidence on secondary legislation implementing Article 7 of the Packaging and Packaging Waste Regulation September 2026 AIM, the European Brands Association, represents manufacturers of branded consumer goods across the food and beverage, personal and homecare, apparel…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

AIM, the European Brands Association, thanks the Commission for the specific inclusion of domain name registration data in this draft Directive. We fully agree with Recital 59, that “maintaining accurate and complete databases of domain names and registration data (so called ‘WHOIS data’) and providing lawful access to such data is essential to ensure the security, stability and resilience of the DNS, which in turn…

Avenue des Gaulois 9 B-1040 Brussels Belgium Tel: [phone removed] TR: 107438267901 AIM FEEDBACK www.aim.be European Commission’s call for evidence on secondary legislation implementing Article 7 of the Packaging and Packaging Waste Regulation September 2026 AIM, the European Brands Association, represents manufacturers of branded consumer goods across the food and beverage, personal and homecare, apparel…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

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

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.

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.

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.

Joint Statement on Article 16(5) of the ESPR Our associations, representing a diverse range of sectors, are concerned with the current approach the EU Commission is pursuing in relation to the implementation of a label under the Ecodesign for Sustainable Products Regulation (ESPR).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

AIM, the European Brands Association, thanks the Commission for this consultation. We agree that the design system works well overall, but we also agree that it needs to be updated, including consideration of 3D printing issues, and would very much support control of goods in transit by customs in the EU based on designs.

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.