Joint Industry Call for a Transitional Regime for the implementation of Article 24 of the ESPR

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21 Mar 2025
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AIM, together with 13 other associations calls on the European Commission to introduce a transitional regime for large companies to comply with the reporting obligations on the destruction of unsold goods under the Ecodesign for Sustainable Products Regulation (ESPR), to ensure compliance until the reporting details are specified in the implementing acts.

We are fully committed to countering the destruction of unsold consumer products and providing comparable data on these practices to support future action. This is crucial for achieving the objectives of the ESPR.

However, we are witnessing a critical mismatch of timelines between the reporting obligations for companies and the adoption of secondary legislation that defines such obligations.

We urge the European Commission to introduce a transitional regime for large companies that grants flexibility in the absence of standardised requirements.

The lack of existing harmonised rules on data reporting makes it difficult for large companies – which are already subject to the obligations following the entry into force of the ESPR – to establish internal data systems for discarding unsold consumer products. Without a harmonised reporting format, disclosures vary and reworking existing data systems is cumbersome. This could lead to unintentional non-compliance.

Against this background, we urge the European Commission to introduce a transitional regime for large companies that grants flexibility in the absence of standardised requirements to be established in the upcoming implementing acts. This regime shall also foresee a deferred date of application for such requirements – that would enable both companies to adjust to the soon-to-establish reporting format, and the European Commission to obtain comparable data on discarded unsold consumer products in the EU.

Read the full statement here.

About AIM

AIM (Association des Industries de Marque) is the European Brands Association, which represents manufacturers of branded consumer goods in Europe on key issues that affect their ability to design, distribute and market their brands. AIM’s membership comprises 2,500 businesses ranging from SMEs to multinationals, directly or indirectly through its corporate and national association members.

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Donata Cagnato Communications Manager Contact Donata