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Tuesday, July 22, 2025Sector

Information on unsold products: an industry position statement

Informations sur les invendus : une prise de position de l'industrie

A collective of several organizations representing all sectors of the industry (including Cosmetics Europe) has just expressed its “strong opposition” to a provision included in the European draft legislation on the terms and format for disclosing information on unsold and discarded consumer products, developed within the framework of the application of Regulation (EU) 2024/1781 (known as the “Ecodesign Regulation” or ESPR). Their target: verification through mandatory limited assurance.

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“The draft act proposes that economic operators falling under the scope of the Corporate Sustainability Reporting Directive (CSRD) shall seek a third-party auditing/assurance service provider’s opinion based on a limited assurance engagement. On the contrary, we recommend that third-party verification should not be mandatory for any economic operator – whether in the scope of the CSRD or not,” begins the joint statement.

According to industry representatives, this approach would introduce significant administrative and financial burdens -described as significant additional expenses and a disproportionate burden- for businesses, directly contradicting the European Commission’s intended objective to reduce administrative complexity and boost EU competitiveness.
Companies would face both one-time costs (such as setting up systems, defining protocols, and acquainting assurance providers with company-specific data) and recurrent costs (like audit preparation and performance reviews), potentially amounting to several hundred thousand euros per company.

And industries add other arguments to justify their opposition to this measure:
• There’s no built-in synergy between ESPR and the CSRD
• The ESPR text already includes other verification tool

We therefore call on the Commission to revise the current verification proposal in the draft implementing act and instead adopt the risk-based, ex-post verification approach by national …

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