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Joint statement on unsold consumer goods verification approach

Policy papers 10 Jul 2025

APPLiA has co-signed a joint statement together with 11 other trade associations supporting the introduction of a robust and transparent system to disclose information on discarded unsold consumer products and stressing the need to ensure its feasibility for companies.

The signatories acknowledge the Commission’s intention to streamline reporting obligations, but warns that the proposed requirement for mandatory third-party limited assurance could result in unintended consequences for European businesses. Among the concerns raised are the introduction of:

  • Significant administrative and financial burdens

  • Legal uncertainty due to the absence of a defined verification standard

  • Overlapping compliance processes that risk duplicating existing obligations

In light of these considerations, the signatories call on policymakers to adopt a risk-based approach to the verification of the disclosed information, in line with the ESPR text and avoid the introduction of unnecessary administrative and financial burdens for businesses.
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