The European Commission's proposal for a directive empowering consumers for the green transition is a welcome initiative that supports the goal of promoting sustainable consumption and protecting consumers from unfair business practices.
To ensure that consumers are able to fully participate in the circular economy, policymakers should further improve the proposal by:
• Allowing companies to provide information to consumers digitally.
• Defining ‘common practice’.
• Not mandating third-party monitoring systems for future environmental performance claims.
• Aligning ‘third-party verification’ with the current definition of ‘verification’ outlined in the International Organization for Standardization (ISO) 14050:2009.
• Revising the approach to ‘generic’ environmental claims by prohibiting vague and truly non-specific claims and allowing claims defined under international standards.
• Ensuring software update provisions do not discourage customers from updating their software.
• Maintaining support for industry environmental labels that fulfil high sustainability criteria based on third-party verification.
• Not considering as prohibited ‘per-se’ bans in Annex I but rather subject these to a ‘case-by-case’ assessment to determine whether certain conduct is misleading:
- Omitting to inform a consumer that a software update negatively impacts the products or that a good is designed with limited functionality when using non-original consumables.
- Inducing the consumer to replace the consumables of a product earlier than for technical reasons is necessary.
• Clarifying that the restriction proposed to be added as point 23i of Annex 1 about limited product functionality when using non-original consumables only applies to intentional effect, not unforeseen consequences.
Empowering consumers for the green transition
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