EuroCommerce

EuroCommerce, representing European retailers and wholesalers, welcomes the opportunity to provide feedback regarding the consultation on the rules on national registers for producers under the PPWR. We would like to highlight several points that should be taken into account for the final implementing act to ensure that the act achieves simplification and harmonisation of rules for national PPWR producer registers.

As the EU advances its regulatory framework through the Digital Omnibus on AI, retailers and wholesalers stand ready to embrace rules that foster trust, safeguard consumers, and enable innovation to thrive. EuroCommerce has consistently supported a clear, futureproof, and riskbased approach to regulating AI, ensuring that only genuinely highrisk applications face stringent obligations while everyday AIenabled…

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)

Statement 24 April 2023 Feedback regarding the proposal for a regulation on packaging and packaging waste We thank the Commission for the opportunity to provide feedback concerning the proposal for a regulation on packaging and packaging waste. This paper is the EuroCommerce feedback for the consultation about the adopted act.

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

EuroCommerce welcomes the opportunity to provide feedback regarding the Inception impact assessment on the review of the requirements for packaging and other measures to prevent packaging waste. The attached statement aims to summarize key points from the retail and wholesale sector on the essential requirements for packaging and support the Commission’s work in revising the Packaging and Packaging Waste Directive.

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 is the principal European organisation representing the retail and wholesale sector. We welcome the work of EFRAG and the Commission to simplify and streamline the ESRS and adopt the VSME standard. In our feedback, we would like to provide further input and suggestions for the improvement of both standards.

Artificial Intelligence (AI) can offer significant benefits not just to businesses, but also to consumers and society. Retailers and wholesalers are central actors in the supply chain and are in daily contact with Europe’s 450 million consumers.

EuroCommerce is the principal European organisation representing retailers and wholesalers. Our members include national associations in 27 countries, leading European companies and circa 5 million SMEs. Our sector generates 26 million jobs.

EuroCommerce, representing European retailers and wholesalers, welcomes the opportunity to provide feedback regarding the proposal to revise textile-related aspects of the Waste Framework Directive. Retailers and wholesalers experience differences and diverging implementation, especially in Extended Producer Responsibility (EPR) requirements in the Member States.

Statement 22 February 2022 EuroCommerce feedback for the call for evidence for an impact assessment about the revision of the Waste Framework Directive Our sector welcomes the planned revision of the Waste Framework Directive (WFD).

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

Position paper October 2021 Making Retail and Wholesale part of the solution to fight food waste Key messages • • • • Retailers and Wholesalers have been extremely successful in tackling food waste both within their own operations and by working with suppliers and consumers. Retail and Wholesale account for 5% of total food waste.

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

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.

Position Paper 16 November 2020 Contribution to Roadmap on Sustainable Product Initiative Introduction The shift from a linear to a circular economy is both a challenge and an opportunity. Being in daily contact with consumers and handling millions of products per day, retailers and wholesalers have embarked on the challenge to shape this societal change.

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

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…

EuroCommerce welcomes the opportunity to provide feedback on the Commissions proposed revision of EU legislation on hazard classification, labelling and packaging of chemicals (CLP). EuroCommerce is the principal European organisation representing the retail and wholesale sector. It embraces national associations in 27 countries, , sector associations and leading global players.

EuroCommerce is the principal European organisation representing the retail and wholesale sector. It embraces national associations in 31 countries and 5.4 million companies, both leading global players and many small businesses. Retail and wholesale provide a link between producers and 500 million European consumers over a billion times a day.

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.

 EuroCommerce supports the aim of the European Commission to encourage further access and use of data in order to mutually benefit public and private actors. Voluntary contract terms, with the involvement of industry actors are welcomed especially for SMEs which often lack the resources.

EuroCommerce welcomes the opportunity to provide feedback to the European Commission’s Inception Impact Assessment on the Data Act. We welcome the effort of the European Commission to establish legal certainty and to promote more data sharing. It is important to ensure that any future (legislative) framework encourages competition and the development of new business models.

Contribution 30 June 2020 FINAL Comments to the Commission’s roadmap/inception impact assessment on the Digital Services Act package: deepening the Internal Market and clarifying responsibilities for digital services Introduction EuroCommerce welcomes the opportunity to provide input to the roadmap consultation on ‘deepening the Internal Market and clarifying responsibilities for digital services.’ Digital services…

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

EuroCommerce welcomes the opportunity to provide feedback to the roadmap on the review of the Food Contact Material (FCM) regulation and we endorse the stated primary objective of the proposal, ensuring that the regulation policy is based on the most up-to-date scientific evidence and that citizens are fully protected from harmful chemicals.

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.

EuroCommerce welcomes the opportunity to provide feedback to the European Commission’s Inception Impact Assessment for a legislative framework for the governance of Common European Data Spaces (CEDSs). The coronavirus crisis has made the need for a fair and ethical European data ecosystem more pressing than ever.

EuroCommerce welcomes the oppunturity to provide feedback regarding the Inception impact assessment on a revision of the Non-Financial Reporting Directive. The attached statement aims to summarise key points from the retail and wholesale sector on non-financial reporting and support the Commission’s work in revising the Non-Financial Reporting Directive.

EuroCommerce supports the objectives of the Chemicals Strategy for Sustainability to better protect citizens and the environment against hazardous chemicals and encourage innovation for the development of safe and sustainable alternatives, and – as one of its actions – a targeted revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals (REACH) regulation.

(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.

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.

EuroCommerce believes the timing for launching the Customs Reform Package is an exceptional and pivotal moment for the EU Single Market and businesses operating within it. The tone of the reform package is both ambitious and aspirational and advocates fundamental change. But such change must fundamentally enhance the current situation for all stakeholders.

EuroCommerce is a unique blend of 5 million companies, from micro-SMEs to renowned global companies in the retail and wholesale sector. Many depend on the smooth import and export of goods or their transit through their supply chains. Members recognise the advances made by the EU Institutions and Member States since the introduction of the Customs Code in 1993.

EuroCommerce welcomes the opportunity to provide feedback to the roadmap on the revision of EU marketing standards for agricultural products. Ensuring quality of food products, and consumers’ trust in food, is a priority for our sector. While standards are primarily meant for producers, they are important to enable retailers and wholesalers to match the needs of consumers.

EuroCommerce, representing European retailers and wholesalers, welcomes the opportunity to provide feedback regarding the call for evidence on harmonisation of rules for calculating and verifying recycled content in plastic packaging.

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.

Key messages EuroCommerce supports the establishment of a culture of repair and reuse in Europe Make the right to repair the most economically feasible, sustainable and attractive option to consumers, retailers, repair service providers and producers.

Statement 17 January 2022 EuroCommerce feedback to the consultation about the proposal for a regulation on shipments of waste and amending Regulations (EU) No 1257/2013 and (EU) No 2020/1056 Retailers and Wholesalers welcome the proposal to revise the Waste Shipment Regulation, because it should enable more circular business activities.

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

EuroCommerce welcomes the opportunity to provide feedback regarding the Inception Impact Assessment on the revision of the Waste Shipment Regulation. The attached statement aims to summarize key points from the retail and wholesale sector on waste shipments and support the Commission’s work in revising the Waste Shipment Regulation.

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.

EuroCommerce represents the retail and wholesale sector throughout the EU. Retail and wholesale plays an essential role in the lives of everyone and the European economy. Over a billion times a day, it provides an essential service and serves as the link between manufacturers and 450 million consumers across Europe. It is a dynamic, highly competitive and customer-focused sector.

EuroCommerce stands by a culture of prompt payment. Late payments (which negatively affect creditors liquidity management) should not be confused with negotiations of payment terms agreed upon between contracting parties. Removing the possibility to negotiate payment terms restricts freedom of contract and will have numerous adverse effects that are not considered in the Impact Assessment of the European Commission.

EuroCommerce stands by a culture of prompt payments in government-to-business and business-to-business transactions. A key differentiation must be drawn between late payments (which occur beyond the terms agreed by the parties) and business-to-business contractually agreed longer payment terms, which form part of the economic decision of the parties and reflect the financing needs of both sellers and buyers.

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).

Retailers and wholesalers welcome the European Commissions draft on green-listing waste streams for shipments for recovery between Member States, pursuant to the Waste Shipment Regulation (WSR). This initiative presents a significant opportunity to develop a true single market for waste, ensuring smooth and predictable shipments for recovery and thereby boosting markets for secondary raw materials.

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.

Retailers and wholesalers are central actors in the supply chain: they are in regular contact with Europe’s 500 million consumers and they operate sophisticated and efficient systems ensuring the reliable and safe sourcing and distribution of consumer goods. They work with suppliers to meet consumers’ demand and keep them safe . Consumer confidence is a key priority for retail and wholesale.

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.

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.

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.

EuroCommerce, the principal European organisation representing the retail and wholesale sector, welcomes the opportunity to provide feedback to the roadmap for the simplification and digitalisation of labels on chemicals, and specifically the CLP Regulation, the Detergents Regulation and the Fertilising Products Regulation.

EuroCommerce welcomes the Commissions initiative to simplify legislation on energy-efficient products. In this context, we support allowing energy labels to be printed directly on product packaging and to carefully assess the potential impact on businesses before introducing any changes to the current energy-label delivery system.

EuroCommerce, representing the European retail and wholesale sector, are pleased to provide detail comments on the proposal on VAT in the digital age in the attached document. EuroCommerce welcomes the opportunity to provide feedback on the VAT in the Digital Age proposal of the European Commission.

EuroCommerce and its members welcome the proposed regulation and are keen to see instant payments in the retail environment develop into an additional fast and secure payment method. We do have some concerns and suggestions as follows: 1. We call on the Commission and other institutions to promote coherence/convergence between the various European market participants that may offer SCT Inst based payment solutions.

The following comments on the Commission roadmap on standard contractual clauses (SCCs) for the transfer of data to third countries pursuant to Regulation (EU) 2016/679 (Implementing Decision) are being submitted jointly by EuroCommerce, headquartered in Brussels, and the National Retail Federation (NRF), headquartered in the United States, which will be submitting the identical set of comments in parallel to this…

We welcome and support the European Commission consistent prioritisation of health and well-being of consumers in its actions, and we support the Commission work by applying new legal requirements. In view of the ongoing consultation, we would like to point to some concerns related to the recent proposal of the Commission Regulation Amending Annex III to Regulation (EC) No 1925/2006 as Regards Botanical Species…

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.

To make the tax system suitable for the digitalised economy, EuroCommerce calls for the modernisation of existing international tax rules, consistent with the following principles: Fair - A modern taxation system should be channel-neutral and operate equitably across industries and between different forms of business activities and business models.

EuroCommerce, representing European retailers and wholesalers, welcomes the opportunity to provide feedback regarding the proposal to postpone the battery due diligence obligations under the EU Batteries Regulation.

EuroCommerce, the EU association for retailers and wholesalers, welcomes the possibility to provide comments to the European Commission as part of the initial stages of the evaluation of the Directive on unfair trading practices in the agri-food supply chain. As a measure based on the agriculture provisions of the Treaty, the Directive should be assessed against its impact on farmers.

Concerning the recently presented proposal for a new anti-coercion instrument, EuroCommerce would like to share the views from the European retail and wholesale perspective. We acknowledge the proposals’ goal to prevent and alleviate pressure from third countries on the European economy.

EuroCommerce, the principal European organisation representing the retail and wholesale sector, welcomes the possibility to comment on the drafting of new guidelines on the application of article 102 TFEU on abuses of dominance under competition law. We welcome the decision of the Commission to draft guidelines on art. 102 to reflect the Commissions practice as well as caselaw from the EU Courts.

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.