The European Brands Organisation (AIM), the Fair Wear Foundation (Fair Wear), ISEAL Alliance and the Fair Trade Advocacy Office (FTAO), (together “we”) welcome the European Commission (“EC”)’s draft revised Horizontal Block Exemption Regulations and Horizontal Guidelines (“HGs”) and the opportunity to comment on them as part of the public consultation.

We find it particularly positive that the EC introduced a standalone section on the application of competition law to sustainability agreements that defines sustainability by taking into consideration the economic, environmental, and social dimensions of sustainability, as well as collective benefits, beyond the sole consumer benefits. We also welcome the reference to the UN’s Agenda 2030 on Sustainable Development, as we believe that it rightly defines the concept of sustainability by considering all its aspects. We very much welcome this direction, as this will encourage the development of genuine sustainable business practices.

However, we would like to draw attention to the social dimension of sustainability, which, in our view, does not find equal recognition in the draft revised HGs in comparison with the environmental dimension of sustainability. The strong focus on the environmental aspects of sustainability in the draft HGs tends to obscure the direct link between social sustainability aspects, such as human rights, and their potential adverse effects on the environment.