In the run-un to the publication of Frequently Asked Questions (FAQs) about the Empowering Consumers for the Green Transition Directive, European retailers have been raising concerns about the absence of transitional provisions in the implementation of the text. Despite the release of the FAQs, fundamental questions remain. Most notably, the application of the Directive’s requirements regarding environmental claims and sustainability labels to existing stocks, placed on the EU Single Market prior to the entry into application of the new rules.
As a reaction to the lack of legal certainty, 18 European business associations published in December 2025 a statement pleading for the continued sale of products already lawfully placed on the market before the Empowering Consumers Directive’s application. This is also a plead to avoid unnecessary waste and costs, as well as supply chain disruptions.
Ecommerce Europe and the other 17 co-signatories fully support the goals of the Empowering Consumers for the Green Transition Directive. Nevertheless, we warn that the absence of appropriate transitional measures – such as a “grandfathering” clause and a coordinated action plan to manage legacy stock, will undermine the EU’s own sustainability objectives and generate unnecessary, burdensome costs for the businesses.
The signatory industry associations urge the EU to address this swiftly in order to safeguard consumer trust, ensure legal certainty, and support the green transition without imposing disproportionate burdens on European businesses. We stand ready to assist the Commission by providing an assessment of the anticipated impacts resulting from the absence of a grandfathering clause.
Read the full statement here.