APPLiA, together with other industry associations, has issued a joint industry statement expressing concern regarding the implementation of reporting obligations under Article 24 of the Ecodesign for Sustainable Products Regulation (ESPR).
The sectors represented remain committed to ensuring that the ESPR delivers on its objectives, notably avoiding the destruction of unsold products by default. However, companies are facing a mismatch in timelines: reporting obligations entered into force in summer 2024, while the first implementing act, expected by 19 July 2025, will only later define the detailed requirements.
This situation creates legal uncertainty, as companies are required to comply in the absence of clear and harmonised rules.
In this regard, the co-signatories call for the establishment of a transitional regime to ensure a smooth and workable implementation. In particular, they call for:
Flexibility for large companies in the absence of standardised requirements
A deferred date of application for the implementing acts
An explicit reference to this regime in the implementing acts
No retroactive application of the requirements
If unaddressed, this misalignment risks undermining the effective implementation of the ESPR.
The signatories remain available to provide further technical input and to support ongoing discussions towards a timely and workable solution.
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