Climate Policy Engagement Analysis
Climate Policy Engagement Overview: EuroCommerce is actively engaged with climate change policies, taking predominantly negative positions on circular economy and land use related climate policy while stating top-line support for the EU’s 2050 net zero target.
Top-line Messaging on Climate Policy: EuroCommerce expresses high-level support for climate action in the EU but appears to not fully support the need for climate regulations. In a report published in June 2024, the association stated broad support for the European Green Deal and its 2050 climate target. However, in its May 2024 EU elections position paper, EuroCommerce appeared to not fully support the need for climate regulation, and generally advocated for less regulation and a more supportive policy approach. In a July 2024 joint declaration, EuroCommerce seemed to suggest that sustainability policies in the EU should be designed in a way that does not impact the bloc's international trade.
Engagement with Climate-Related Regulations: EuroCommerce appears to have limited transparent engagement on specific climate-related policies in recent years. The association did not take a clear position on the EU Carbon Border Adjustment Mechanism in a report published in June 2024, and stated some concerns around its implementation.
Engagement with Land Use Climate-Related Regulations: EuroCommerce appears to take mostly uunsupportive positions on land use regulation in the EU. In a January 2024 joint letter, EuroCommerce strongly supported a target for nature-based carbon removals as part of the EU 2040 Target, while advocating for best practice to mitigate negative trade-offs and acknowledging the need to prioritize GHG emissions reductions in line with scientific recommendations. However, EuroCommerce advocated to delay the implementation of the EU Regulation on Deforestation-free Products (EUDR), for example in a July 2024 press release and a November 2024 statement. In its EU elections position paper published in May 2024, EuroCommerce stated broad support for the sustainable intensification of agriculture. However, in a May 2023 open letter, EuroCommerce seemed to support the EU Sustainable Food Systems Framework while advocating for the policy to take into account all products and processes.
Engagement with Circular Economy-Related Climate Regulations: EuroCommerce is actively engaged with circular economy legislation in the EU. The association took mostly unsupportive positions on the EU Packaging and Packaging Waste Regulation, advocating to weaken reuse obligations and opposing flexible implementation of rules to allow Member States to set more ambitious targets, for example in a February 2024 joint statement and in a December 2023 joint letter. EuroCommerce supported the EU Ecodesign for Sustainable Products Regulation with major exceptions. EuroCommerce did not fully support the Commission proposal on the destruction of unsold consumer goods in a September 2023 joint letter and did not appear to support setting sustainability requirements for different product groups in May 2023 comments to policymakers.
Positioning on Energy Transition: EuroCommerce does not appear to have a detailed position on the energy transition. In a January 2024 open letter, EuroCommerce stated support for a target for industrial carbon removals with permanent storage in the EU 2040 Target, acknowledging the limitations of industrial removals in line with scientific recommendations. In its May 2024 EU elections position paper, the association stated broad support for a transition to a low-carbon economy but with several conditions, calling for a technology-neutral policy approach.