Retail and wholesale feedback to the call for evidence on “Simplification of administrative burden in environmental legislation”

Retailers and wholesalers support the initiative for “Simplification of administrative burden in environmental legislation”. We welcome a proposal that does not undermine the key objectives of the legislation and brings simplification and reduced burdens. The amendment of the legislation should be aimed at streamlining for efficiency and effectiveness while enhancing the competitiveness and resilience of European companies through sustainability.

This document aims to provide first feedback from our sector and also summarises previous EuroCommerce messages on Better Regulation and Competitiveness that inter alia apply to this omnibus proposal.

The volume of new legislation during the 2019–2024 EU mandate has significant implications for retailers and wholesalers. Its effects are also particularly felt by SMEs and micro-enterprises and ultimately have an impact on the EU’s competitiveness. A decrease in administrative and reporting burdens, combined with an increase in supportive measures, is needed to address this situation. At the same time, we stress the importance of keeping SMEs within the scope of environmental legislation, as they play a vital role in achieving sustainability goals.

Therefore, we support targeted simplification measures that assist companies in implementing legislation, especially SMEs and microenterprises, provide much-needed clear guidance, overall coherence between legislations to ease practical implementation for companies and help continue building a sustainable and competitive EU market. Critically, simplification must be thoughtfully designed to avoid creating new uncertainties and information needed for the implementation of legislation needs to be provided timely to ensure proper preparation.

Lastly, we would like the Commission to conduct an impact assessment for this omnibus initiative. The current consultation period, launched during the summer holidays and limited to just six weeks, limits meaningful stakeholder engagement. We therefore urge the Commission to consider conducting a full impact assessment, ensuring transparency and responsiveness to stakeholders.