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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.

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.

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.

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

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

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

Energizer is in favour of updating the General Product Safety Directive to ensure that it is fit for purpose and continues to protect consumers in the digital era. As integral components in many household devices, batteries have a critical role to play in guaranteeing the performance of consumer products and as such it is paramount to ensure their safety.

APPLiA (Home Appliance Europe) believes that GPSD has been working reasonably well over those almost 20 years and does not require major revision. However, considering time and efforts already invested in possible review, Option 0 ’Status quo’ is probably not realistic anymore.

This document is focusing only on key aspects. APPLiA is happy to contribute to the legislative process with further details at a later stage. 1 - Improved coherence with New Legislative Framework The GPSR is thought as a “safety net” to Union harmonised legislation, therefore coherence with the New Legislative Framework (NLF) is of utmost importance.