EuroCommerce

EuroCommerce, representing European retailers and wholesalers, welcomes the opportunity to provide feedback regarding the planned Circular Economy Act. Please find our position paper attached, which includes our comments in three sections: Retail and Wholesale key messages for the Circular Economy Act, our key messages for textiles and our key messages for the WEEE Directive revision.

Position Paper 08 July 2025 EuroCommerce feedback on the Industrial Decarbonisation Accelerator Act call for evidence Relevance of the Retail and Wholesale sector The European retail and wholesale sector is a significant energy user and a key player in Europe’s decarbonisation efforts, as demonstrated by its ongoing initiatives to reduce emissions.

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

Without a viable retail and wholesale presence, quality of life declines and depopulation accelerates, undermining the right to stay. Retail and wholesale are indispensable to enabling citizens right to stay in the place they call home.

EuroCommerce, representing European retailers and wholesalers, welcomes the opportunity to provide feedback regarding the consultation on the review of the EU taxonomy environmental delegated act. Our sector broadly welcomes the proposed amendments, as many of the changes are expected to result in simplification and a reduction of unnecessary documentation and administrative requirements.

EuroCommerce, representing European retailers and wholesalers, welcomes the opportunity to provide feedback regarding the proposed changes to the EU Taxonomy Climate and Environmental Delegated Acts. Retailers and wholesalers welcome the proposal to amend the EU Taxonomy Regulation to simplify reporting and the opportunity to share feedback with the Commission.

EuroCommerce, representing the voice of European retailers and wholesalers, welcomes the proposal to reopen the Basic Organic Regulation (EU) 2018/848. We particularly support the proposed extension of the expiry date for the recognition of third countries whose organic production and control systems are deemed equivalent, until 31 December 2036.

EuroCommerce, the voice of retail and wholesale sector, welcomes the opportunity to provide suggestions for updating the Organic Regulation (EU) 2018/848. We support the EUs ambition to promote sustainable food systems and maintain consumer trust in organic products.

EuroCommerce members consider the GBR workable. One of our main concerns during the decision-making process was that an obligation to deliver for retailers to deliver would have been introduced. This would have had numerous adverse effects on retailers operations. As long as retailers are not obliged to deliver to consumers in markets where they are not active we consider the rules balanced and workable.

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.

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.

The European retail and wholesale sector supports the European Commissions ambition to make the transport sector more climate-friendly and sustainable, provided that the right preconditions are in place and the framework allows our sector to contribute effectively to this green transformation. Our general feedback and key requests are the following: 1.

EuroCommerce welcomes the possibility to contribute to the call for evidence on the Cybersecurity Act (CSA). The CSA has provided a strong EU cybersecurity governance framework and increased trust in digital technologies.

We welcome the opportunity to provide feedback on the European Commission's consultation regarding the extension of the Carbon Border Adjustment Mechanism (CBAM) to downstream products. As the principal European organisation representing the retail and wholesale sector, with a large part of the membership being deeply involved in global supply chains and committed to supporting the EU's climate objectives, we…

The retail and wholesale sector is a major energy consumer; the large number of stores and warehouses we operate consume altogether approximately 220-240TWh per year. This Commissions initiative is expected to have a direct impact on our sector. Our sector is highly dependent on energy and remains strongly committed to decarbonisation.

EuroCommerce, representing European retailers and wholesalers, welcomes the opportunity to provide feedback regarding the consultation on the review of the EU taxonomy climate delegated act. Our sector broadly welcomes the proposed amendments, as many of the changes are expected to result in simplification and a reduction of unnecessary documentation and administrative requirements.

Retailers and wholesalers have a unique and strategic position within the value chain. They support their suppliers and foster innovation to meet evolving customer demands. In the past years, the sector has undergone a significant transformation, largely driven by digitalisation and new technologies.

We welcome the proposed delegated act which responds to some of our outstanding queries and provides additional clarity, simplification and legal certainty in support of the preparation for the date of application of the EUDR for the retail and wholesale sector.

Please find out detailed feedback attached. We welcome the consultation for the creation of the DPP registry under the ESPR. Our main recommendation is that the implementing act is designed with the upcoming European Product Act in mind, and particularly the Market Surveillance Regulation, and its potential recommendations to tackle direct non-compliant product imports from non-EU manufacturers.

European retailers and wholesalers welcome the adoption of a new EU Electrification Action Plan. Our sector is a significant energy user and enabler of electrification, constituting a key player in Europes decarbonisation efforts and clean energy transition.

EuroCommerce welcomes this opportunity to provide input to the roadmap consultations on an ex ante platform instrument. The area is of high importance to the future and competitiveness of the retail and wholesale sector in an increasingly digital environment.

EuroCommerce welcomes the opportunity to contribute to the European Commissions impact assessment on the delegated act for Digital Product Passport (DPP) service providers. As a forward-looking tool for enhancing transparency and sustainability, the DPP has the potential to modernize consumer information and improve value chain communication.

European retailers and wholesalers welcome the adoption of a new Heating and Cooling Strategy. Our sector is a significant energy user and enabler of electrification, constituting a key player in Europes efforts to clean transition.

(Summary) We represent the retail and wholesale sectors, which are in most cases users of harmonised standards, not their developers. Nevertheless, our businesses depend on timely, transparent, international and practical standards to ensure legal compliance and interoperability of products.

The retail and wholesale sector is a major energy consumer; the large number of stores and warehouses we operate consume altogether approximately 220-240TWh per year. Energy is mainly consumed for refrigeration, heating and cooling, and lighting in stores, logistics centres and warehouses. Our sector is highly dependent on energy and remains strongly committed to decarbonisation.

Effectiveness In general, the Cosmetics Products Regulation (CPR) provides a solid framework for ensuring consumer safety, which is of the utmost priority. Nonetheless, the absence of clearly defined safe threshold limits for such restricted substances may present challenges in ensuring safety and compliance. (For more details look at Section 5 on Enforcement: Thresholds).

EuroCommerce calls on the co-legislators to preserve the market orientation of the agri-food chain and avoid interferences with freedom of contract The Commissions Vision for the Future of Agriculture and Food of 2025 recognises that agri-food supply chains are complex and one-size-fits-all policies will not work. This is particularly true for contractual relations between actors in the chain.

EuroCommerce warmly welcomes the Commissions initiative on digitalization of paper requirements as an important step toward reducing compliance burdens and modernising EU product legislation for the digital age. Transitioning away from paper-based obligations can unlock cost savings, reduce waste, lower resource use, automatise compliance and reporting, and drastically improve information flow across supply chains.

The 2019 UTP Directive aimed to protect smaller farmers and processors, but its transposition resulted in significant national divergence and has restricted mutually beneficial agreements. EuroCommerce calls for a limited review to bring coherence and ensure the Directive focuses on improving the situation of small farmers and processors as intended.

EuroCommerce warmly welcomes the Commissions initiative on digitalization of paper requirements as an important step toward reducing compliance burdens and modernising EU product legislation for the digital age. Transitioning away from paper-based obligations can unlock cost savings, reduce waste, lower resource use, automatise compliance and reporting, and drastically improve information flow across supply chains.

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.

The Regulations objectives remain relevant but require reframing to address the new realities and challenges introduced by e-commerce and specifically the individual shipments entering the EU market from third countries.

Over a billion times a day, retailers and wholesalers distribute goods and provide an essential service to millions of businesses and individual customers. The sector generates 1 in 7 jobs, offering a varied career to 26 million Europeans, many of them young people. It also supports millions of further jobs throughout the supply chain, from small local suppliers to international businesses.

This submission by EuroCommerce responds to the European Commissions consultation on the Directive on Administrative Cooperation (DAC). Based on practical implementation experience across multiple DAC regimes, EuroCommerce observes recurring structural issues that generate disproportionate compliance burdens without corresponding benefits from enforcement.

Retail and wholesale companies and European consumers have greatly benefited from free trade within the Single Market. Free movement of goods enabled them retailers and wholesalers to provide their customers with a wider choice of products for lower prices.

EuroCommerce supports better enforcement against unfair trading practices, but the co-legislators must ensure there are safeguards to preserve the Single Market for sourcing and legal certainty. We call on the co-legislators to: - Keep the proposed Regulation focused on cooperation between enforcement authorities based on the existing unfair trading practices and thresholds in Directive (EU) 2019/633 (UTP…

EuroCommerce, representing the retailers and wholesalers in Europe, would like to thank the European Commission for the opportunity to provide again feedback regarding the review of energy labelling for household washing machines and washer-driers.

EuroCommerce appreciates the European Commission's proposal for targeted measures in the wine sector, amending Regulations No. 1308/2013, 2021/2115, and 251/2014. We recognise the importance of adapting the regulatory framework to evolving consumer preferences and market trends, particularly concerning low- and no-alcohol products, aromatised wines, and digital labelling.

Retailers and wholesalers welcome the Commissions objective to tackle regular employment relationships disguised as traineeships. Retailers and wholesalers strongly oppose all forms of exploitation of trainees, regardless of whether they are undergoing their traineeships as students or workers. However, the pursuit of that goal should be proportionate and ensure it remains desirable to offer traineeships.