Independent Retail Europe

Independent Retail Europe represents the interests of the independent retail sector. Our membership consists of over 479.000 independent retailers, who manage more than 708.000 sales outlets and employ more than 6.306.000 persons.

Data and Artificial Intelligence are rapidly transforming Europes independent retail sector, changing how retailers serve consumers and offering new potential to optimize their supply chain, logistics and stores.

Independent Retail Europe welcomes the call for evidence for a digital omnibus for simplification. The rapid growth in the number of EU legislation regulating various aspects of digitalization, data, cybersecurity and platforms over the last years led to a very complex regulatory landscape for companies in 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.

Independent Retail Europe membership supports the stated objectives of the European Green Deal, the Circular Economy Action Plan, as well as the global objectives of the new Packaging and Packaging Waste Regulation (PPWR). We therefore welcome the Commissions objective to gradually harmonise packaging rules across the EU.

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 represents the independent retail sector. Independent retailers are privately owned and operated store-based or multichannel retail businesses. These retailers may function under the umbrella of a larger cooperative or voluntary retail group that ensures entrepreneurial autonomy while offering certain shared resources, such as joint buying and marketing, branding, and infrastructure of…

Independent Retail Europe would favour an approach whereby Member States would have flexibility to set their own sector-specific targets, proportionate to the contribution each sector makes to food waste and invites the EU institutions to consider the following aspects: Food chain operators can only be responsible for waste that is under their control.

Independent Retail Europe welcomes the ambition of the Commission to reduce food waste. With 20% of all food produced in the EU ending up as waste and 88 million tons of food waste generated annually, we fully recognise the need to continue the effort to reduce food waste. Retailers have developed or engaged in numerous initiatives to reduce their actively generated food waste to a minimum.

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.

Addressing the substantial sustainability challenges in the areas of climate change, pollution, loss of biodiversity but also social sustainability and human rights, whilst facing energy and supply insecurities, will be a challenging task for all the organisations present in global supply chains in the next years and decades to come.

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 members believe that the new process to determine ecodesign requirements truly has the potential to change the way products will be consumed in future and that retail will play a pivotal role in this transition to greener products. Retailers’ in-store advisors and experts provide an essential added value to consumers, as they: 1.

We welcome the Commission’s efforts to create incentives for more a sustainable Single Market. We are confident that a solution can be found that achieves greater sustainability without damaging the interests of consumers or businesses. In this context, we appreciate in particular the attention given to SMEs in the Inception Impact Assessment to the Initiative.

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 is the voice of groups of independent retailers in the food as well as non-food sectors at EU level. We generally support the EU’s ambition for companies to include sustainability into their strategies.

Independent Retail Europe welcomes the Cyber Resilience Act, as it will help to achieve a higher level of cyber security for products with digital elements made available in the EU. In this context, retailers have important obligations to fulfil to ensure that they sell to consumers only products with are in conformity with these new cyber security requirements.

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 proposal on a Directive for common rules on repair and reuse. Indeed, since consumers are more and more eager to consume in more sustainable ways, retailers see new business opportunities in providing repair services. Independent retailers are aware of their linking role between manufacturers and consumers by giving valuable customer advice.

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 welcomes the proposal for a Directive empowering consumers for the green transition through better protection against unfair practices and better information (COM(2022)143 final). We fully support the proposed obligation for a certification scheme for any environmental claim and the provisions on the sustainability information tool.

Independent Retail Europe stresses the importance for EU consumer policy being consistent. Please note that we will respond in more detail to the open public consultation of the New Consumer Agenda (deadline: 6 October) as well as the survey currently undertaken by ICF on this subject of consumer empowerment. We will therefore concentrate on some general comments on this Roadmap on the Inception Impact Assessment.

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…

The European Commissions proposal for a revision of the Product Liability Directive (PLD) intends to adapt the liability regime to the digital economy and the circular economy. The Commission proposes to include software and AI in the scope of the Directive, to ease the burden of proof for claiming liability through some rebuttal presumptions. The Commission also proposes to slightly alter the chain of liability.

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 is the European trade association that represents groups of (SME) independent retailers in the food and non-food sectors. We bring together 23 groups and associations and their over 417.800 independent retailers, who manage more than 753.500 sales outlets in Europe, with a combined retail turnover of more than 1.320 billion euros and generating a combined wholesale turnover of 513 billion…

Independent Retail Europe supports the European Commissions ambition to simplify EU energy and tyre labelling rules, provided that the revised framework reduces administrative and compliance burdens while respecting the respective responsibilities of economic operators. Digitalisation should not shift manufacturers obligations onto retailers, who should not be required to print, reproduce or attach labels in stores.

Independent Retail Europe welcomes initiatives that enhance product transparency and strengthen consumer information. At the same time, we stress that any new obligations must be proportionate, operationally feasible, and carefully designed to minimise unnecessary administrative and financial burdens on retailers, particularly small and medium-sized enterprises.

Independent Retail Europe is the voice of groups of independent retailers in the food as well as non-food sectors at EU level. We welcome that the European Commission is consistently prioritising the health and well-being of consumers in all of its actions. The retail sector is its powerful ally in this pursuit.

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 welcomes the possibility to provide comments as part of the call for evidence for the development of new guidelines on exclusionary abuses by dominant undertakings within the framework of article 102 TFEU.Overall, we welcome the proposed publication of a set of guidelines on the application of article 102 TFEU, as this would strengthen the Single Market and raise legal certainty for all…

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.

Please find attached Independent Retail Europe's comments on the Proposal for a Council Directive on ensuring a global minimum level of taxation for multinational groups in the Union. Independent Retail Europe is the voice of groups of independent retailers, bringing together 23 groups of independent retailers and national associations representing them.