Newsletter. Online version
June 2023 | VOL. 3
SUSTAINABILITY REPORT 2022
More fit for the future – Nilorn Sustainability Report 2022.
The Sustainability Report serves as a comprehensive overview of Nilorn’s ongoing sustainability efforts, commitment to transparency, and accountability in its ESG initiatives, all aimed at being ”More Fit for the Future”.
• EU General Product Safety Regulation published in May 2023.
• Follow-up on the EU Green Claims Directive.
• Update on UK importer information (post-Brexit).
Announcement: EU General Product Safety Regulation published
In May 2023, the Regulation (EU) 2023/988 on general product was adopted. It replaces the General Product Safety Directive (GSPD) and is applicable per December 2024. This regulation was a necessity to keep up with changes in technology and consumption as well as improving the recall procedure.
It introduces a harmonized approach to make sure that products consumers buy are safe, closing loopholes that previously enabled non-conformity. Companies acting on the EU market are advised to get familiar with the new rules and start preparing.
(Link for further reading, source 1)
Published: Proposal for a Green Claims Directive
In March 2023, the European Commission published a proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive). The proposal aims to implement a specific directive (regarding voluntary explicit environmental claims) under a more general directive, the Unfair Commercial Practices Directive (regarding all voluntary general claims). It is expected to come into force in 2024.
- Companies must ensure reliable and transparent voluntary environmental claims (B2C).
- Claims verified by an independent verifier receive EU-recognized compliance certificates.
- Genuine environmental efforts create a competitive advantage.
- Certified claims save resources and reduce legal confusion.
- Unified rules reduce expenses for cross-border trade and enhance industry reputation.
- Non-EU businesses targeting EU consumers must also comply.
- Small companies (fewer than 10 employees, < €2 million turnover) are exempt.
HOW TO PREPARE?
- Get familiar with the rules of the Green Claims Directive and instruct your employees.
- Review how you communicate online and in stores.
- Assess the environmental impact of your products and activities.
- Have reliable evidence in place to support your claims.
- Enhance transparency by clearly explaining the basis of your claims to consumers.
- Develop new procedures and incorporate independent verification.
- Initiate communication with your labelling and certification schemes to raise awareness.
(Link for further reading, sources 2 and 4)
Updated: UK importer information requirements
Importers of consumer products covered by the 2005 General Product Safety Regulations are required to indicate their name and address (UK based) on the individual product or its packaging. Where this might be difficult, UK government allowed businesses to make use of an alternative method to ensure traceability for the end user and regulator, by including the importer’s address in accompanying documents, such as, shipping documents or invoices to the consumer.
Previously, this alternative approach was time-limited and not allowed after December 2022, but has now been extended until December 31, 2027. Nonetheless, it is advised to already now implement measures ensuring that individual goods carry the importer’s address as required before the new deadline is running out.
Please note that this general requirement as well as its alternative method for disclosure might be overruled by product specific legislation.
(Link for further reading, sources 3 and 5)
- European Parliament & Council of the European Union. (2023, May 10). Regulation (EU) 2023/988 of the European Parliament and of the Council on general product safety. Official Journal of the European Union, L 135/1, 1-51.
Retrieved from: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R0988&qid=1684997696555
- European Commission. (2023, March 22). Proposal for a Directive of the European Parliament and of the Council on substantiation and communication of explicit environmental claims (Green Claims Directive). COM(2023) 166 final.
Retrieved from: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52023PC0166
- Regulation (EU) 2023/988 of the European Parliament and the Council on general product safety. (2023, May 10). Official Journal of the European Union, L 135/1, 18-48.
Retrieved from: https://eur-lex.europa.eu/eli/reg/2023/988
- European Commission. (2023, March). Green Claims.
Retrieved from: https://environment.ec.europa.eu/topics/circular-economy/green-claims_en
- UK Government. (2005. Statutory guidance: General Product Safety Regulations 2005 (Updated 4 May 2023).
Retrieved from: https://www.gov.uk/government/publications/general-product-safety-regulations-2005/general-product-safety-regulations-2005-great-britain#contents
Please note that any advice or information provided in this newsletter is intended for general informational purposes only and does not constitute legal advice. The sender cannot be held liable for any actions taken or not taken based on the content.
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