EuroCommerce response to the Call for Evidence on the proposed Communication on Better Regulation

EuroCommerce, representing EU retail and wholesale, strongly believes evidence-informed policy-making will lead to better law making. The EU needs to strike a better balance between regulation and innovation to give legal certainty and predictability for EU retailers and wholesalers to innovate, globally, nationally and locally in a business environment that enables decisions balanced with business risk. Priority should be given to the Single Market. The EU institutions should only move ahead with new initiatives that truly deepen and strengthen the Single Market and do not codify fragmentation into EU law.

While we welcome the desire to make the consultation system smarter, invoke ‘simplicity by design’ and have a renewed focus on evidence-based, decisive EU action, we believe caution is necessary in creating accelerated pathways. Faster action in the case of urgency is required especially to ensure speed and legal certainty but checks and balances are critical to ensure that accelerated procedures remain exceptional. Creating a new fast-track procedure that undermines proper assessment, can result in administrative burden, incoherence and impracticability, undermined competitiveness and unintended consequences.

The Commission has a rich structure and tools that enable assessment of all aspects of initiatives from their effect on the environment to jobs, as well as the impact on taxes, growth and international trade. Time needs to be given to ensure that legislation is checked through all relevant ‘lenses’, in the inter-service consultations, well prepared through inter-service steering groups, robust stakeholder consultation, and with true scrutiny from the Regulatory Scrutiny Board, before proposals are made.

Legislation needs to be ‘reality checked’, with stakeholders and options tested. The EU needs to resist the temptation of ‘quick fixes’ that may initially sound appealing but in fact undermine the healthy functioning of free markets. Reality checked means legislation that is cost-effective, proportional, based on gap-analysis, that achieves its intended goal and is mapped with stakeholders to identify harmful unintended side-effects once implemented.

Initiatives need to help all businesses particularly SMEs manage the regulatory obligations more efficiently, by streamlining compliance processes, providing financial support, offering expert guidance, implementing training programmes and developing digital tools to automate compliance tasks, to significantly reduce administrative burden. The goal from the start needs to be clear, coherent, and easily applicable rules.

We propose several key principles that could guide the Commission in reconciling the need for evidence-based policies with urgent action, ensure a holistic approach to stakeholder consultation, and ensure EU laws are simpler and easier to implement in practice.

Key principles

To ensure EU laws are simpler and easier to implement in practice, focus on:

Practicability
Workability
Capability
Understanding indirect effect
Undertaking a competitiveness check
Retaining flexibility where possible
Inspection at the right level
Avoiding duplication
Correctly allocating responsibilities
Understanding value chains
Avoiding unintended consequences by properly preparing and using Inter-Service Consultation
Using the EuroCommerce ‘Better Regulation Checklist’
Using AI tools to check the degree of variation between a proposal and the final text agreed by co-legislators, and to test the quality of impact assessments
Incorporating coherence into digital-first policies and ensure they are technically feasible and capable of maintaining operational functionality
Not leaving targets to a political decision
Exercising restraint
Considering how enforcement works in practice ahead of legislative proposals.

To reconcile evidence-based policies with urgent action and ensure a holistic approach to stakeholders, focus on:

Preparation & anticipation in advance
Creating a system of checks & balances for urgent procedures
Improving clarity and quality in stakeholder consultation
Increasing transparency at more milestones, not focusing on once-only consultation
Remaining realistic in stakeholder consultation
Simulating what compliance would involve
Using the opportunities provided to gather feedback

The importance of doing less, better

The largest service sector, retail and wholesale, creates over 10% of EU GDP and distributes goods over a billion times a day, providing an essential service to millions of businesses and individual customers. Our sector generates 1 in 7 jobs, offering careers to 26 million Europeans, many of them young people. Additionally, we create millions of indirect jobs throughout the supply chain, from small local suppliers to international businesses.

We offer strength in diversity, providing choice and stability to the EU’s customers. Retail includes a large variety of business models, from integrated stores with omnichannel experiences, to franchise models, cooperatives, independent retailers, pure online players and SMEs. Wholesale ensures the supply of goods along the entire value chain, providing financing for their customers, especially SMEs, offering choice, storage, one stop shop solutions, logistical support, and efficiency and minimises risks relating to goods such as availability, quality, security of supply, financing and transport.

Undermining specific business models or reducing their competitiveness will:

Decrease resilience that is achieved through diversity;
Expose affected companies to takeovers, often by non-EU players;
Increase market concentration; and
Decrease equal access to products and services and increase risks of shortages and unavailability.

Legislative initiatives often fail to appreciate the crucial role of wholesale and retail in its diversity plays in strengthening the EU’s resilience against shocks and disasters, from the local to the European level. The lack of appreciation of this, is an example of ‘self-defeating legislation’ that Draghi refers to in his report.

Excessive administrative burden hampers our sector’s capacity to invest and incentives/opportunities to innovate. The amount of legislation applied to retailers and wholesalers has exploded in recent years. This is because we supply millions of products in the market and offer a wide variety of services across a multitude of channels. Real societal benefits will accrue if the EU can find a better balance between a comprehensive regulatory framework and fostering innovation. Draghi’s suggestions for a new competitiveness framework need to be advanced to ensure better policy coordination, matching of budget, self-constraint in legislation, better assessment of regulatory burden, stress testing of existing legislation, review stakeholder consultation and promote innovation.

How to strike the balance

The EU needs to focus on understandable regulations that have greater clarity, avoids overlapping rules, has clear prioritisation of legislative acts, longer transition times for SMEs, and sufficient guidance materials and practical tools tailored to different segments and industries (with the need for guidelines assessed and prepared ahead of proposals).

This requires the Commission to:

Focus more on implementation and give more room for non-regulatory approaches.
Focus on stability and give room for businesses to make decisions that fit with businesses that work with strategic plans over a longer term, not short-term vision.
Continue the momentum on the Transition Pathways and use them as part of the ‘competitiveness check’. The European Commission's transition pathway for the retail ecosystem offers a strategic plan to foster a resilient, digital, and green retail ecosystem. They can be used to check if legislation promotes competitiveness and is coherent.
Develop legislation trackers on the supporting online portals for the Transition Pathways. This will help businesses prepare for implementation and help policymakers monitor the cumulative burden.
Consult with stakeholders throughout the full development of initiatives, increase the number of milestones where input is systematically collected, and fully test all options before implementation to spot unintended consequences in advance.
Ensure consistency and prioritisation of goals, to stop legislation pulling in different directions with no common thread.
Add a new focus on relevance (e.g. sunset clauses) and removal of forced stagnation (e.g. lack of legal certainty, slow guidance, etc.).

Learn from experience (including previous mandates) and use our better regulation checklist.

Key principles to consider

The following principles could guide the Commission in reconciling the need for evidence-based policies with urgent action, ensuring a holistic approach to stakeholder consultation, and ensuring EU laws are simpler and easier to implement in practice.

Prepare & anticipate in advance

Creating separate procedures for urgent reaction should be the last resort. Better planning and use of foresight could enable preparation in advance of crisis. Having intelligence upfront, gathered from trade associations or through the roll-out of the Preparedness Union, can better inform decision-making even under pressure.

Many efforts are already made to understand how value chains are affected in times of crisis, for example using the Industrial Forum or the Europe Food Security Crisis Preparedness and Response Mechanism.

The first step should be to map where information has been or is being collected within the Commission, its expert groups or via other means, on the experience of past shocks. The second step should be understanding of how global supply chains can increase preparedness and help resolve over-reliance before disaster strikes and developing scenarios for possible future ‘black swan events’ to inform policy design. The third step should be creating structures to collect such intelligence (e.g. identifying contact points, chains of command, method of communication) can be set up in advance, taking the lessons learned from recent crisis.
Create a system of checks & balances for urgent procedures

Checks and balances on the use of urgent procedures are critical to ensure application only in the case of emergencies, rather than as a general option for a ‘short-cut’ or fast-track procedure. For example, decisions on using urgent procedures and the absence of an impact assessment could require a decision from the Regulatory Scrutiny Board based on transparent procedures.

Where the urgency fades, consultations need to be brought back to normal procedure.

Example:

After farmers’ protests in March 2024, the Commission announced new rules on the cross-border enforcement of unfair trading practices (UTPs) initially through a non-paper, before reference was more formally made in an Implementation Report. There was no prior publication on the Commission’s Have Your Say portal and rules were proposed well ahead of the Directive’s review date of 2025, despite an evaluation study being launched and undertaken in parallel. The implementation report admits ‘the conformity check assessing the compatibility of national implementing measures with the Directive, is still not finalised’, making it difficult to understand how the Commission was ready to correct ‘problems’ and do so without an impact assessment. Nonetheless, the Commission published its proposal more than six months later in December 2024, without an impact assessment nor stakeholder consultation. This lack of transparency and no shared analysis of the compatibility of the proposal with the Single Market and private international law led to the European Parliament adopting a position that could have seriously undermined the Single Market (namely by allowing extra-territorial effects of stricter national rules). The trilogue was concluded in November 2025 and the subsequently published evaluation report of December 2025 revealed that no major overhaul of rules was needed.
Understand value chains

Initiatives that will affect value chains need to be based on a full understanding of how those value chains operate in practice. Retail and wholesale rely on complex value chains to offer choice and better prices to customers. The reality and interlinkage of those value chains needs to be better understood in policy making as well, as the effects of regulation on one part of the value chain on employment in the rest of the chain. Notably because retail and wholesale supports millions of jobs throughout the supply chain, from small local suppliers to international businesses.

As recommended in the European Economic and Social Committee report on ‘How to consider value chains in policymaking’ the importance of identifying the leading firm operating in each value chain and understanding their role is important for the purposes of targeted policy support as well as ensuring policy creates value-chain wide benefits.

Example:

The Corporate Sustainability Reporting Directive led to spillover effects to SMEs despite their exclusion from the scope. Many wholesalers, who are predominantly SMEs, faced huge administrative burden due to their position in the value chain and the potential to be overwhelmed by the number of questionnaires they need to complete. It was only through the voluntary SME standard that the position of SMEs stands to be improved, with the hopes for relief for the value chain coming through the Omnibus proposal.
Correctly allocate responsibilities

Obligations need to remain with those in the supply chain best placed to comply with them – i.e. those who place products on the market. This needs to be considered in all impact assessments for future legislation to ensure legislation is implementable.

EuroCommerce is preparing a report that will analyse inconsistent use or interpretation of definitions across EU legislation, with aim of concluding on some basic principles that should be kept for all legislation (e.g. it is never the obligation of retailers to print instructions, e.g. private label owners should not be treated as manufacturers).

Example:

In the CLP Regulation (Classification, labelling and packaging of substances and mixtures) retailers are considered suppliers within the meaning of Article 4(4), and whereas they have no control over product design or knowledge of the chemical mixture, are call to label and package as manufacturers. Additionally, Articles 34a–34b oblige retailers and wholesalers (suppliers) to provide the digital-only elements of labels “by alternative means” (upon request or if the digital format is unavailable). This is disproportionate for distributors, given that the obligation to provide product information lies with the manufacturer. Imposing this duty on distributors would create a significant administrative burden, as it would require them to store and manage physical copies of information that the manufacturer only supplies digitally—an operationally unworkable scenario. It could also lead to inaccuracies, since distributors cannot guarantee that such information remains up to date or aligned with the manufacturer’s latest version.
Avoid unintended consequences by properly preparing and using Inter-Service Consultation

The Inter-Service Consultation offers policymakers the ability to view a proposal through different ‘lenses’ from the impact on the environment and jobs, to growth, competitiveness and international trade. Respecting proper procedures, ensuring documents are made available and time is given for reflection is key to avoid unintended consequences and coherence.

Formalising an ‘inter-DG consultation’ will also ensure coherence of initiatives within a Directorate General that can be inadvertently missed depending on the size of a Directorate General and volume of initiatives.

True scrutiny from the Regulatory Scrutiny Board should also mean negative opinions have consequences and proposals should not be adopted by the College until all concerns are fully addressed.

Examples:

The Paperless Omnibus is a welcomed effort for simplification. However, unless clarity is provided digitalisation threatens to simplify the situation for operators upstream, by moving obligations downstream. For example, the requirement that instructions can be provided digitally, but at request of user “at the time of purchase” the instructions should be provided in paper format. Unless it is explicitly mentioned that providing instructions in paper format is an exclusive obligation of the manufacturer, and that distributors should not be called to print or store instructions, the effort to simplify simply swifts the burden from manufacturers to distributors (i.e. an obligation to print or store instructions).

Additionally, safeguards should ensure that when the Digital Product Passport (DPP) is displayed in online retail, traffic is not re-directed to a manufacturers’ website, creating unfair competition by re-directing consumers away from retailers’ websites.

Different aspects of the DPP from access rights to how the DPP is being made available on online platforms are discussed in different pieces of vertical EU product legislation, while standardisation discussions are still ongoing and the delegated acts under Ecodesign for Sustainable Product Regulation are not completed yet.
Use the EuroCommerce ‘Better Regulation Checklist’

The EuroCommerce Better regulation checklist proposes key principles for effective EU regulation that is high impact, high quality and low cost. The checklist reproduced in the Annex reflects the situation in November 2024, with some updates following recent simplification exercises or developments in the co-legislative procedure noted as footnotes.

The principles call for practicability, workability, capability, assessment of indirect effect, a competitiveness check, flexibility, inspection at the right level and avoidance of duplication. They are complemented by examples of lessons that can be learned from initiatives of the last Commission mandate.

This needs involvement of stakeholders throughout policy development, increasing feedback points and testing options. As well as aligning internal processes to ensure policies are consistent, conflicts avoided and competitiveness retained.
Use AI tools (e.g. adapting what has been developed by Deloitte) to check the degree of variation between a proposal and the final text agreed by co-legislators, and to test the quality of impact assessments.

Testing the assumption that the higher degree of variation comes from too little time spent preparing a legislative proposal, the origin of a proposal or the basis for agreement (e.g. qualified majority vote, unanimity), will help improve legislative quality by understanding why the co-legislative procedure leads to major variations (indicating issues with the original proposal and/or the procedure).

In addition, studies could be carried out to consider how much effort is needed at national level to ensure rules are understood and applied after adopted into EU law (e.g. how much national consultation is needed, the level of awareness raising necessary, the nature of and number of questions asked by businesses and other stakeholders, etc.) and how they play out in practice.
Do not leave targets to a political decision

Work should be based on what is happening in the market and what can be achieved, properly understanding the barriers. For example, efforts made to encourage the adoption of green fleets remain disconnected to what is available on the market and any targets should be based on a reasoned forecast/projection rather than an unreasoned target.

Example:

In the revised Energy Performance of Buildings Directive Article 14 introduces far-fetched and disproportionate requirements regarding the installation of charging points, which come with substantial costs and are technically challenging to implement for retailers and wholesalers. Specificities of our sector were not taken into account. Instead of strict requirements about the number of charging points, a flexible approach that is demand-driven and looks at the total charging capacity or targeted exemptions would be better and leave businesses more flexibility.
Exercise restraint

Restraint can come from focusing on stability and initiatives that truly deepen the Single Market, giving more room for non-regulatory approaches, dismantling Single Market barriers, removing overlaps where collective agreements cover the perceived legislative gap, and shifting the focus of the State of the Union address to reporting on progress and prioritisation rather than the announcement of new initiatives.

Examples:

An initiative on AI in the workplace is being discussed as part of the Quality Jobs Act. The EU has already responded with an extensive framework (e.g., AI Act, Platform Work, and GDPR). Furthermore, certain Member States reinforced workers’ rights through national employment and labour laws, implementing EU laws. In this context, the changes to the implementation of the AI Act as well as those concerning the revision of GDPR should be taken into account when examining this matter.

Introducing origin rules through parallel legislative frameworks, such as the Organic Regulation, Breakfast Directives or sector-specific marketing standards under the Common Market Organisation (CMO) risks fragmentation, regulatory overlap, and legal uncertainty. The Food Information to Consumers (FIC) Regulation provides a horizontal, consumer-focused framework that is already well-established and widely implemented. Relying on the FIC as the primary legal basis for origin labelling would promote coherence, simplify compliance, and ensure that origin information is applied consistently across the EU food supply chain.
Incorporate coherence into digital-first policies and ensure they are technically feasible and capable of maintaining operational functionality

Standardised primary data collection and harmonised methodologies can streamline compliance efforts. This requires transparent guidance and clear expectations from policymakers to reduce uncertainty and build trust. It also requires flexible, interoperable systems that can grow and adjust to improve data quality and make it easier to compare information as regulations change over time.

Digital tools intended to enable compliance are often not operationally fit for purpose by the date of application. Before digital solutions are proposed, they need to be assessed for technical feasibility, for example, creating a role for technicians in DG DIGIT to be more involved in the inter-service steering group. Effective and proportionate enforcement requires that digital systems be fully functional before they become the exclusive channel for compliance. Rules without workable systems do not uphold credibility, instead, they place operators in an impossible position.

Examples:

The changes to the Fisheries Control Regulation illustrate how legislation can outpace operational reality. The new rules entered into force before the EU’s digital systems were technically ready, creating disproportionate administrative burdens for operators and undermining efficiency. Key compliance tools are still not functional, yet they are meant to be the sole channel for enforcement, leaving operators in an impossible position. Fragmented national workarounds are now emerging in the absence of EU‑level guidance, risking Single Market inconsistencies. Although retailers and wholesalers have heavily invested in digital traceability, many suppliers—especially small ones still cannot provide the required data, or uploading data in the CATCH IT system does not work making full compliance unattainable in practice.

The readiness and robustness of the Information system to support the implementation of the EUDR was uncertain, leading to a further delay on the date of application and a change in obligations for operators and traders. This issue had been flagged by the affected sectors in good time. Economic actors nevertheless continued to develop their IT systems and now require further investments to adapt the systems.
Consider how enforcement works in practice ahead of legislation

The enforceability of new EU rules needs to systematically be assessed during legislative impact assessments, especially regarding non-EU traders and marketplaces.

Ahead of the proposal for a Regulation on Cross-Border Enforcement of Unfair Trading Practices, EuroCommerce highlighted that the current patchwork approach to cross-border enforcement of EU rules is inefficient, risks leading to multiple different procedures and undermines legal certainty. We called for the Commission to examine and, if necessary, propose a common approach or single procedure (e.g. through a set of general rules or a single package of proposals) to facilitate cross-border enforcement across all existing EU legislation that may require coordination between enforcement authorities. However, this approach was not taken up by the Commission and means a patchwork of different rules remains (e.g. on unfair trading practices, the GDPR).

Examples:

EuroCommerce is calling for #Compliance4All to address growing concerns over non-compliant third-country traders and marketplaces, which affect consumer safety and the competitiveness of European retail. For rules to be effective, they need to be enforceable. Unfair competition by third-country players can only be resolved by one coherent and coordinated enforcement strategy shared and supported by all relevant enforcement authorities. Enforcement authorities responsible for market surveillance, product safety, consumer protection, online content, data protection, extended producer responsibilities schemes, customs, and more need to improve cooperation and coordination at EU and national levels with their peers and across policy domains.

In REACH, the lack of sufficient or accurate data on the chemical characterisation of substances and mixtures or chemicals (especially in articles) are key challenges for our sector. This creates information gaps which some distributors cover by investing in additional testing to ensure products comply, an exercise that not all have the resources to undertake, and which is not an obligation that should be burdening our sector. Improve clarity and quality in stakeholder consultation

What is asked in public consultations does not always reflect what is intended and is open to interpretation. A focus on clarity, testing whether there is a common understanding for example, with a sample of associations or third parties, could avoid confusion.

Examples:

The questions asked in the SME Panel on the proposal for a Regulation on Late Payments (September 2025) were one-sided, taken from the perspective of SME suppliers in the value chain. The results of the survey have been presented in the Council, Parliament and at the SME Assembly as representative despite the lack of perspective of buyers or large companies being collected.

The JRC runs an annual survey on UTPs. The questions are based on perception, rather than evidence. The UTP Directive only protects smaller suppliers, but larger suppliers can take part in the survey; buyers, on the other hand, (including SME buyers) are not eligible to respond to the survey.
Increase transparency at more milestones, not focus on once-only consultation

Stakeholders should be consulted throughout the full development of initiatives and the number of milestones where input is systematically collected and the full testing of options should be the goal, rather than consultation once-only. Ideas develop and should respond to stakeholder feedback, arguing against once-only consultation if a balanced result is to be achieved that avoids unintended consequences and gives equal opportunities for all those affected to respond.

The same principle should apply in relation to delegated and implementing acts and during the co-legislative procedure. In the co-legislative procedure , items for political discussion or the four-column table are not publicly available or may only be shared with certain stakeholders. Such asymmetry of information gives little time for meaningful input to be provided or risks being one-sided, based only on the views of those that may have seen the documents in advance. Given the rules will ultimately apply to all stakeholders, understanding the full differences in viewpoints should be the basis for informed decision-making.

In addition, the co-legislators could be required to assess the impact of their amendments following the same methodology as the original impact assessment.
Remain realistic in stakeholder consultation

The Commission should develop the most effective means to gather cost-benefit feedback, through technical discussions, not based on requests for general information on the cost. A better approach would be to stimulate what compliance would involve (see below).

Similarly, trade associations handle multiple consultations and files simultaneously and companies also need to manage competing pressures outside of public affairs. For quality input, preparatory documents for workshops or interviews need to be circulated well in advance to allow time for input to be gathered or a common position found. The views of an individual company cannot be taken as the agreed view for a whole sector.

Example

While we appreciate the opportunity to participate in Implementation Dialogues with the Commission, it is often challenging to secure the involvement of senior company representatives or individuals able to make strategic decisions on only one or two weeks’ notice. Providing input on technical issues requires sufficient time for these members to be briefed and prepared. Allowing more time to identify, brief, and prepare relevant experts would significantly improve the quality of participation and provide more meaningful insights for both stakeholders and policymakers.
Simulate what compliance would involve

Policymakers need to consider what the rules they are proposing mean in practice. Rather than relying purely on stakeholder feedback to understand, policymakers could simulate how they would put the obligations into practice (e.g. how long it would take, what they would need to guide them, what is available on the market to meet the demand, etc.) and then test this with stakeholders. This would also help make the SME Test more robust, avoid over-reliance on Fit for Future opinions that may have limited stakeholder feedback and SME Panels that only reach limited stakeholders.

Channeling consultations through the Enterprise Europe Network only gives limited visibility. The launch of SME Panels should be shared with the network of SME Envoys as a rule, to try and increase the pool of possible respondents. Similarly, the responses of associations representing SMEs should be taken as the SME view, as many entrepreneurs rely on their associations to represent their interests and do not have time to directly respond to questionnaires.

Developing methodology jointly with stakeholders, for example using the Joint Research Centre, could help create the tools for this assessment. Investment in better evaluations could also help policymakers understand how laws operate in practice, so lessons learned can be taken into future policymaking and necessary adjustments made.

Example:

In October 2024, the Fit for Future Platform adopted Opinion 2024/4 on the ongoing evaluation of Directive 2019/633 on unfair trading practices in B2B relationships in the agricultural and food supply chain (‘the UTP Directive’). EU retailers and wholesalers are not directly present in the Fit for Future Platform. They are a key sector but were not consulted on their views on the Directive as part of the Platform’s evaluation or recommendations.

This should also include consideration of the consequences of rules, for example, what are the responsibilities in relation to products that can no longer be legally marketed in the EU or the effect on, or coherence with, payment systems.

Examples

Retroactive application of the Directive on Empowering Consumers for the Green Transition risks forcing companies to withdraw millions of goods lawfully placed on the market before the Directive’s application date, leading to considerable economic and environmental impacts, including costs and burdens regarding relabelling, providing additional information at the point of sale, repackaging, and potentially destruction of products, which would directly contradict the Ecodesign for Sustainable Products Regulation and the operators’ efforts to be more sustainable. This could be avoided by introducing a “grandfathering” clause allowing products lawfully placed on the market before the Directive’s application date to continue being marketed.

Articles 5 and 7 of the Alternative Fuels Infrastructure Regulation (AFIR) conflicts with the existing EU legislation on payments mainly the second Payment Services Directive (PSD2) in its provisions concerning payments for electric and hydrogen vehicles. It requires ‘at least one of the following’: ‘payment card readers’ or ‘devices with a contactless functionality that is at least able to read payment cards’. These two are contradictory or overlapping descriptions.

The Electronic Identification, Authentication and Trust Services (eIDAS 2.0) Regulation does not make it clear for merchants if acceptance of the EU Digital Identity Wallet (EUDIW) is mandatory as a way to perform Strong Customer Authentication (SCA) as required in second Payment Services Directive (PSD2) for payment transactions. SCA means that at least two different factors must be used to authenticate a payment: something you are (e.g. biometrics), something you have (e.g. a card) and something you know (e.g. a PIN).

It should also consider how legislation may inadvertently negatively affect incentives or practical problems. For example, what are the consequences for retail and wholesale that may be ordering products 1.5–2 years in advance, or who need to be able to sell unsold products in the next sales season.

Example:

The Ecodesign for Sustainable Products (ESPR) Regulation mandated that economic operators store back-up copies of the Digital Product Passport (DPP) with external DPP service providers, which might lead to increased costs and duplication of information. Clarification is needed on the volume and type of data to be stored, the frequency of updates, and who is responsible for carrying them out—particularly for circular products or DPPs serialised on item level—to avoid operational burdens and environmental cost associated with storage of large amounts of data.
Use the opportunities provided to gather feedback

Many associations hold events and panel discussions. These events are frequented by the members of the association, so provide an opportunity to raise questions and improve understanding. Often, Commission representatives are only able to remain for keynote speeches or cancel attendance at the last minute. This means many miss out on the rich discussions that is an efficient way to gather feedback, understand how a sector may be affected by an initiative or to test ideas. It also, enables practical questions to be asked of those that will need to implement the legislation or will be involved with national transposition.

A stronger commitment to engagement with stakeholders at these events, or inclusion of a requirement to attend a certain number of stakeholder events on a topic could be introduced as requirement of the consultation strategy. The same should apply to store visits, which give the possibility to engage with the experts.