SFIF welcomes the European Commission´s objective to set a baseline for the requirements for substantiation of environmental claims to mitigate greenwashing.
The proposal constitutes an important and needed piece of legislation which complements related consumer protection legislation. However, although the intended purpose of the proposal is commendable, SFIF would like to highlight some challenges we have identified, and which we believe need to be addressed, to avoid counteracting the intended purpose of the proposed legislation.
- Legislation related to products in the Single Market needs to be harmonized. The addition of a mechanism for how national authorities and commercial stakeholders may contribute to the Commission’s assessment process for determining the implementation and potential need for delegated acts.
- Clarification on how to assess substantiation of environmental claims is crucial. The lack of clarity (or risk of arbitrary interpretation) risks inhibiting serious stakeholders from making green claims due to uncertainty surrounding the consequences of evaluation of the environmental claim.
- Ensure industry involvement related to the development of delegated acts. Industry representation needs to extend across the entire value chain, with a majority of stakeholders having knowledge about specific products or product groups.
