APPLiA, together with a broad coalition of European business organisations, welcomes the common understanding adopted by the Consumer Protection Cooperation Network on legacy stocks under the Empowering Consumers for the Green Transition Directive.
The common understanding provides much-needed guidance on how competent authorities will assess products and packaging already placed on the market before the new requirements on environmental claims and sustainability labels start applying.
Developed in response to industry concerns calling for a swift and pragmatic EU-wide approach, the CPC common understanding acknowledges the practical challenges traders face in implementing the new rules, despite their reasonable and proportionate efforts to be fully compliant by 27 September 2026.
The guidance also recognises that disproportionate and unreasonable measures should be avoided, in particular where these would create disproportionate costs or environmental harm, such as the destruction or recall of products. This approach helps avoid unnecessary waste, supply chain disruptions and additional burdens, while supporting the broader objectives of the circular economy.
However, concerns remain around possible private enforcement actions that may not sufficiently take into account the practical challenges of achieving full compliance by 27 September 2026, as recognised by the CPC Network and the European Commission.
APPLiA remains committed to working closely with the European Commission and national authorities to support a smooth and coherent implementation of the Directive across the Single Market.
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