Finnish Commerce Federation

Recyclable packaging must be an equal alternative to reuse. This is in contradiction with the objective of the EU Circular Economy Action Plan that all packaging must be either reusable or recyclable by 2030. In the proposal for a regulation, the demonstration of the environmental benefits of reusable packaging remains unclear.

Filed in Finnish · English published by the European Commission

Finnish Commerce Federation welcomes the opportunity to contribute to the development of energy and climate policies at the EU level. Investors already prefer sustainable businesses and, like companies, are committed to ESG and carbon neutrality. Time, know-how and money is invested to actions which strongly pursue carbon neutrality.

Position paper Ref. Ares(2022)3821067 - 20/05/2022 1 (5) 29.4.2022 Commerce supports European rules for corporate sustainability due diligence – yet a number of issues still require resolving The Finnish Commerce Federation and its members are focused on advancing corporate responsibility in their own activities.

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

At this point, the Finnish Commerce Federation wish to pay attention to few specific issues regarding the proposal to revise the CLP Regulation. In addition to what is below, we refer and express our full support to the reply of EuroCommerce. The CLP Regulation is in the hard core of EU Chemicals legislation.

The Finnish Commerce Federation welcomes this public consultation. We have followed the process with concern from the beginning. We believe that the consumers would be confused by the proposed labeling for products containing TiO2. Overall, the classification and labelling would be disproportionate in our view.

Finnish Commerce Federation welcomes the Commissions’ intend to harmonize responsibilities and obligations for digital services including online platforms. We also share the view that this should happen on the European level instead of national level to be effective. Online marketplaces such have become very popular among consumers.

1 (2) 6 October 2023 FINNISH COMMERCE FEDERATION – REVISION OF THE UNION CUSTOMS CODE Finnish Commerce Federation is a nationwide lobbying organisation whose mission is to promote Finnish commerce. We work to improve the operating conditions for companies active in wholesale and retail trade, to stimulate co-operation within the sector and to enhance the commercial and employer interests of our members.

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

Call for Evidence 19 September 2022 FINNISH COMMERCE FEDERATION - REVISION OF THE UNION CUSTOMS CODE Finnish Commerce Federation is a nationwide lobbying organisation whose mission is to promote Finnish commerce.

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

Products sold outside the EU must have a digital product passport to prevent the emergence of dual markets. To ensure the competitiveness of businesses operating within the European Union, the EU must begin to strongly monitor cross-border e-commerce with a new EU-level instrument that supports the vital work of national supervisory authorities.

The Finnish Commerce Federation welcomes the opportunity to provide feedback on the rationalisation of reporting requirements. Our proposals for some general principles to take into account in the rationalisation process as well as detailed examples on overly burdensome, redundant and/or ineffective reporting obligations are outlined in the attached paper.