Position Papers

#01.09.2020 APEAL input to EC public consultation on substantiating green claims

APEAL welcomes the EC public consultation initiative on substantiating green claims.

We support the EC establishing legal framework that provides a level playing field, limits the proliferation of methods to measure and assess environmental impacts, limits the proliferation of labels and claims related to environmental information and ensures that the environmental impact of the products placed on the EU market, incl. the imported ones, can be properly assessed.

We believe that the existing 2013 Recommendations (2013/179/EU) should be updated and that establishing a voluntary EU legal framework, without a move towards one accepted method, but that could be used as a complement to existing methods, will not create to a level playing field and will not eliminate misleading claims.We support the EC establishing EU legal framework requiring companies making claims related to the impacts covered by the PEF and OEF methods to substantiate them via these methods. However only when the impact indicators are reviewed, adding indicators is evaluated and supplementary specific PEFCR’s are established, this option could create a level playing field, allowing comparing the environmental impact of similar products.

However, we also believe that the methods themselves needs to be made rendered even more robust, including environmental elements that are not incorporated yet, among others taking into account EoL marine litter and multiple recycling stimulating high-quality recycling.