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Tuesday, July 7, 2026Ecoresponsibility

Implementation of Directive 2024/825: the "Common understanding" for "old stock situations"

Application de la Directive 2024/825 : la "compréhension commune" pour les "vieux stocks"

Published in March 2024, Directive (EU) 2024/825, which aims to “empower cconsumers for the green transition through better protection against unfair practices and through better information,” is due to come into force on 27 September 2026. The common position on the approach to be taken by supervisory authorities regarding existing stocks that have become non-compliant has just been published.

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Although its transposition into national law (in France and several other European countries), which was due to have been completed by 27 March, has been delayed, as confirmed by Ambroise Pascal, the DGCCRF’s Ecological Transition Officer, during a webinar held on 12 June, the date on which it comes into force has been maintained.
And even in the absence of any formal legal obligation, operators are strongly advised to comply as soon as possible with the requirements of Directive (EU) 2024/825, and in particular to ensure that their environmental claims and sustainability labels comply with these requirements in their relations with consumers.

Against this backdrop, the supervisory authorities have received numerous enquiries from operators facing major transitional difficulties, particularly with regard to so-called “old stock” situations.
A working group of the CPC (Cooperation for Consumer Protection) was set up to establish a common policy on this issue: its “Common understanding on old stock situations” has just been published.

The scope of the document

Although this document does not constitute a legally binding interpretation of the Directive, it sets out a pragmatic approach to situations involving historical stocks, so that the supervisory authorities in the various …

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