15 Industry Associations Call for Review of ESPR Article 16(5) to Avoid Premature Labelling Requirements

A coalition of 15 European and international industry associations, including AIM – the European Brands Association, has issued a joint statement expressing concerns about the current approach to implementing a new labelling system under the Ecodesign for Sustainable Products Regulation (ESPR).

The associations reaffirm their support for the overall objectives of the ESPR, which aims to improve the sustainability of products placed on the EU market and provide consumers with reliable and transparent information. However, they warn that the implementation of Article 16(5) risks introducing horizontal labelling requirements before the necessary metrics, methodologies, and product-specific rules are clearly defined.

We thus call on the European Commission to suspend the adoption of implementing acts under Article 16(5) and consider its amendment. Proceeding without a solid methodological framework could increase regulatory complexity, create confusion for consumers, and contradict the EU’s broader objectives under the Single Market Strategy. Sustainability labels should rather be addressed through product-specific delegated acts, allowing policymakers to assess the most relevant information and parameters for each product group. This approach would avoid a one-size-fits-all solution for the diverse range of products covered by the ESPR. By establishing clear methodologies first and addressing labelling at the product level, sustainability labels can be more meaningful, improve consumer understanding, and better align with the EU’s goals of simplification and digitalisation.

It is also paramount to prioritise digital solutions, such as the Digital Product Passport (DPP), EPREL and QR codes, which can provide detailed sustainability information without adding unnecessary physical labels or regulatory overlap.

The associations remain committed to constructive engagement with EU policymakers to ensure that the ESPR framework supports both sustainability objectives and effective implementation across sectors.

Click here to read the full statement

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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.