From our perspective, the overarching aim of the Directive is sound. It should be possible for all consumers to make conscious (purchase) decisions. And this requires harmonised standards. We fully support this. REWE, PENNY and toom Baumarkt stores already offer corresponding product ranges. However, the Directive needs to go further than simply defining what should no longer be included in sustainability communications. There needs to be a way in which such communications can provide the necessary guidance in the future.
The Directive, at its current draft stage, is still ambiguous in many places and leaves too much margin for interpretation. This is also the case with numerous definitions and terms. A decisive factor for us will be the data on which environmental statements may be based in the future. It is certainly a complex challenge! If secondary data may be used, this significantly reduces the complexity; however, it makes it more difficult to present differences within categories. The problem with primary data is that it is not currently available for all products. If every company, NGO and standard now has to collect separate data, the effort required will be tremendous, especially for complex products involving multiple supply chains, such as frozen pizza or multivitamin juice.
A number of additional sustainability-related regulations are currently also being negotiated at EU level alongside the Green Claims Directive, including the Corporate Sustainability Reporting Directive, Sustainable Food Systems and Empowering Consumers for the Green Transition. These will also require the collection of vast amounts of data. We believe that standardised data should ultimately form a basis for all these regulations. The same applies to definitions and terms. They should not contradict each other.
What is absolutely vital is that the added value of sustainability projects in respect of animal welfare, biodiversity or social practice, for example, remains visible. Report on the good being done: both for customers looking for guidance and to keep people updated on the progress of projects worldwide. It would be a significant step backwards if it were no longer possible to communicate the sustainability credentials of individual products or services, or if communicating such information were no longer possible for capacity, process and budget reasons. This would indirectly lead to a significant reduction in the number of urgently needed supply chain transformation projects across many different sectors and countries and may even cause them to be abandoned altogether. I am certain that this is not the intention behind the regulation. We therefore appeal to the policymakers to ensure within the detail of the Directive that effective and well-founded sustainability communication is still possible for both larger and smaller companies. Ultimately, this is the only way to achieve an incentive effect.