04 December 2023

BEUC's response on the roadmap on reporting duties

The Commission intends to make proposals to rationalise and simplify reporting requirements that oblige public authorities or business to provide information to competent authorities either at EU or national level, with initial proposals targeting the green, digital and economic thematic areas.

BEUC welcomes the opportunity to comment on this initiative, particularly because requirements to provide information from businesses to consumers are included. We underline the importance of the Commission’s clarification that certification, labelling, permitting, and similar processes are excluded. These types of information requirements must indeed not be subject to such a simplification initiative with a normative target of reduction.

Clarification needed:
We would ask the Commission to clarify whether it considers that the typical requirements for traders to inform consumers about products and services or conditions of purchase or use are included or not. An inclusion would in our opinion not be justified because these information requirements do not aim at better implementation, monitoring and evaluation of EU legislation but serve to protect consumers.
Likewise, information requirements which are at the request of consumers, such as for example the ‘right to know’ in the EU’s chemical legislation REACH (Art. 33.2) which obliges business to provide upon consumer requests information on the presence of certain chemicals in their products (not a labelling requirement) should not be covered.
More broadly, EU climate, environmental and digitalization policy efforts cannot deliver without strong monitoring, reporting and verification requirements, applying both to public authorities and private companies. The simplification of reporting duties must not weaken these policies by depriving policymakers of the essential data needed to design, develop and enforce EU laws. Furthermore, we would like to know how this initiative relates to disclosure requirements for which a legal mandate exists, but which still need to be developed, in particular the sector-specific European Sustainability Reporting Standards the deadline for which looks likely to be postponed. These requirements are essential for achieving the objectives of the sustainable transition because they shed light on companies’ efforts and activities to meet those objectives.
Methodology missing:
Secondly, no one is against removing redundant, duplicating, or obsolete requirements, or inadequate collection methods, but reporting duties are an essential element of the Better Regulation methodology as a tool to make sure legislation is effective and is complied with. In the Better Regulation toolbox of July 2023, the Commission states that “Reporting requirements are a prerequisite to ensure the timely monitoring of EU initiatives”. Indeed, any oversight measure can only be undertaken with reporting duties and without them the burden falls on authorities or the European Commission who do not have enough resources already today

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