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
Related items
:focal())
The Circular Economy Act: a silver bullet for harmonisation?
On Wednesday, 27 May, AmCham EU hosted Paulina Dejmek Hack, Head of Cabinet for Jessika Roswall, Commissioner for Environment, European Commission, for a discussion on the upcoming Circular Economy Act. Moderated by Luca Ibelli (Procter & Gamble), Vice-Chair, Environment Committee, AmCham EU, the exchange explored how the Act can support Europe’s wider simplification agenda by reducing fragmentation and strengthening competitiveness. Participants also discussed the importance of a harmonised framework grounded in a clear business case, ensuring circular economy policies help companies operate effectively across the Single Market.
:focal())
Revision of the Classification, Labelling and Packaging Regulation: Following a balanced Report, trilogues must secure simplification
Today, the European Parliament adopted its Omnibus VI report, including the revision of the Classification, Labelling and Packaging (CLP) Regulation, by 540 votes to 60. The outcome supports a more streamlined framework by easing the regulatory burden on value chains that rely on chemicals and sending a positive signal of the EU’s commitment to reducing unnecessary complexity.
With the Council’s position agreed in November 2025, the Parliament’s report marks the final step before trilogues, which will conclude negotiations on the targeted revision of the CLP Regulation.
The report largely aligns with the Commission’s simplification agenda and strengthens the CLP Regulation’s overall workability, especially with regards to:
Transition periods, setting 18 months following classification updates and allowing digital contact information to be updated on the label in line with suppliers’ regular update cycles. This better reflects supply chain realities.
Advertising and distance sales requirements, appropriately excluding business-to-business settings while ensuring consumers remain protected; and
Label legibility requirements, with more proportionate minimum font sizes and rules on background contrast, spacing and overall layout. However, further simplification is still needed to ensure sufficient flexibility for businesses.
While the report represents a constructive step forward, trilogues should address remaining constraints and clarify language that is currently difficult to interpret, including further simplification on font sizes and advertising requirements in business-to-consumer settings. These negotiations should draw on the more proportionate approaches of the Commission and the Council.
Maintaining a strong focus on simplification will be key to further alleviating administrative burdens and strengthening the EU’s resilience and competitiveness.
:focal())
Simplifying the Classification, Labelling and Packaging Regulation: recommendations for trilogues
On 8 July 2025, the Commission presented the Omnibus VI simplification package, reopening key legislation such as the CLP Regulation, which entered into force in December 2024. The Omnibus addresses overlaps and inconsistencies that create practical challenges and, in some cases, make compliance unworkable.
Upcoming trilogues can streamline the framework and reduce unnecessary burdens. This paper sets out targeted recommendations on the positions that can achieve meaningful simplification during the inter-institutional negotiations.
Policy priorities
Insights and advocacy driving Europe’s policy agenda. Our priorities support growth, innovation and a stronger transatlantic economy.
Membership
Connecting business and policymakers to strengthen the voice of American companies in Europe.