Independent Retail Europe

Independent Retail Europe highly welcomes the Call for Evidence regarding the Circular Economy Act that is due to be published in 2026. A harmonized overarching framework in the form of a Circular Economy Act can bring consistency in the circular strategy of the EU. Sustainability and circularity bring opportunities but also many challenges for the independent retail sector.

Please find attached our suggestions for the recognition and inclusion of independent retail in the right to stay strategy. Independent Retail Europe is the European trade associations that represents the interests of the independent retail sector. Independent retailers play an important role in the liveability of rural areas and therewith make an important contribution to the right to stay.

Independent Retail Europe welcomes the possibility to reply to the Commissions call for evidence on the Geoblocking Regulation (Regulation (EU) 2018/302), which is a fundamental piece of legislation for both consumers and retailers. Overall, we consider that the Geoblocking Regulation strikes the right balance in B2C relations on the retail market.

We welcome the parts of the Commissions proposal that allow reputable companies who make a tangible effort to reduce their environmental impact stand out and distinguish themselves from their competitors. The proposal should enhance consumer trust in environmental claims. Consumer interest and awareness has steadily grown over the past years.

Independent Retail Europe welcomes the Call for Evidence regarding the Directive on Single-Use-Plastics. Collecting information on the implementation of the Directive is not only relevant for the evaluation that the Commission has to publish by 3 July 2027, but also in order to align the Directive with cross-cutting issues in upcoming legislation under the Environment Omnibus and the Circular Economy Act.

Independent Retail Europe supports initiatives to improve product transparency and consumer information through the Digital Product Passport (DPP), but we stress that the system must remain practical, proportionate, and manageable for retailers, especially SMEs. The DPPs should be linked by default to product models.

Independent Retail Europe welcomes the call for evidence on the Digital Fitness Check, which represents the second stage of the European Commissions efforts to simplify the EUs digital regulatory framework following the adjustments introduced through the Digital Omnibus.

Independent Retail Europe generally views positively measures to strengthen the position of farmers since groups of independent retailers are dependent on a competitive and resilient agricultural sector for a sustainable and resilient food supply chain.

Independent Retail Europe welcomes the European Commissions commitment to simplify rules and reduce the administrative burdens placed on EU businesses. We welcome the measures proposed in the 4th Omnibus simplification package concerning a new definition of small mid-cap companies (SMCs) and the introduction of targeted regulatory exemptions for SMCs (even though, overall, we consider the impact of these measures on…

Independent Retail Europe welcomes the possibility to comment on the call for evidence on the revision of the Directive on Unfair Trading Practices. As pointed out in the Commissions report on the evaluation of the Directive itself, the short period since completion of the transposition process, coupled with various external shocks and the complexity of isolating the Directives effects, does not allow to draw…

Independent Retail Europe welcomes the European Commissions commitment to simplify rules and reduce the administrative burdens placed on EU businesses. We welcome the measures proposed in the 4th Omnibus simplification package concerning a new definition of small mid-cap companies (SMCs) and the introduction of targeted regulatory exemptions for SMCs (even though, overall, we consider the impact of these measures on…

We are concerned that the specificities of cooperative/associative retailer groups and franchise groups are not taken into account, particularly in regard to the reporting obligations. Under the proposed implementing act, a central organization of a group of independent retailers operating as one brand cannot report on behalf of its member retailers because they are not subsidiaries, while an integrated retail chain…

Independent Retail Europe welcomes the measures proposed in the 4th Omnibus simplification package concerning a new definition of small mid-cap companies (SMCs) and the introduction of targeted regulatory exemptions for SMCs even though, overall, we consider the impact of these measures on the retail sector to be limited.

Independent Retail Europe welcomes the European Commission's proposal for a Directive amending the Directive on alternative dispute resolution for consumer disputes. To ensure that this revision delivers an optimal level of modernisation whilst respecting the nature of ADR entities, and without creating legal uncertainty that would discourage traders from joining ADR schemes, we invite the co-legislators to consider…

Our members generally support the alternative dispute resolution mechanism (ADR) as well as online dispute resolution (ODR). It is a service that some of our members offer to their respective members and customers. After the Regulation entered into force in 2016, our members additionally intensified internal procedures for customer complaint handling, to solve conflicts rapidly and to prevent them from escalating.

Independent Retail Europe takes note of the proposal and concludes after thorough examination that further clarification of certain legal provisions is needed to ensure the Regulation does not risk undermining the European single market.