From the Sector

At the "International Conference on Cellulose Fibers 2024" in Cologne, Germany, the Nova Institute for Ecology and Innovation awarded first place in the Innovation Prize to the project partners of the EU-funded HEREWEAR project. They presented a dress made of cellulose fibers, which is entirely made of straw pulp.

HEREWEAR is an EU-wide research project that brings together partners from research and industry. They are working to establish a European circular economy for locally produced textiles and clothing made from bio-based raw materials.
The HEREWEAR consortium consists of small and medium-sized enterprises and research institutions. HEREWEAR covers all the necessary expertise and infrastructure from academic and applied research and industry from nine EU countries.

The HEREWEAR approach includes technical and ecological innovations in the production of fibers, yarns, fabrics, knitwear and garments, as well as the use of regional value chains and the circular development of fashion items.

New technologies for wet and melt spinning of cellulose and bio-based polyesters, e.g. PLA, from which yarns and fabrics are produced, form the technical basis. Coating and dyeing processes have been developed and tested as part of the project. In addition to reducing the carbon footprint of the product, another environmental goal is to reduce the release of microfibers throughout the textile manufacturing process and life cycle.

Improving the sustainability and recyclability of the developed garments is ensured by design for circularity and digitally networked production means. On-demand production is realized in so-called "microfactories", which are individualized and produce only for actual demand. This production method can be achieved through regional, networked value chains and enables the traceability of materials and manufacturing processes.

The dress presented at the award ceremony is an example of the cooperation and the different qualifications of the project partners: TNO (Netherlands Organization for Applied Scientific Research) provided sustainably produced pulp. The HighPerCell fibers were produced in DITF's spinning facilities. At the same time, designers from the fashion label Vretena created the design for the flexible, two-piece dress, which can be knitted without cutting waste. DITF textile experts worked with the designers to develop the knitting pattern. DITF textile engineers and technicians produced the knitted fabric and assembled the dress at the institutes’ technical center. DITF computer scientists and engineers created the "value chain" and "digital twins" for digital traceability of the production processes.

The innovation prize was awarded to the HEREWEAR consortiu for their joint achievement. Representatives of DITF Denkendorf and Vretena accepted the award on behalf of the EU project partners.

Messe Frankfurt will extend its footprint in the Central Asian market by establishing seven brand events in Tashkent, Uzbekistan. The country’s strategic location as a crossroads of Europe and Asia positions it as a promising trade gateway and transportation hub, facilitating the economic development of neighbouring countries and access to the wider region. The company’s stronger presence in the market will promote business opportunities and foster the sustainable development of pillar industries, including cosmetics, textiles and clothing, automotive, logistics and transportation.

Uzbekistan has a promising consumer market with significant potential. It is the largest in Central Asia and is expected to increase due to population growth, rising incomes and the modernisation of economic and industry sectors.
 
The nation has actively sought to diversify its economy in recent years, undertaking reforms for greater entrepreneurial freedom and opening up to more international and regional cooperation. The country already exports precious metals, textiles and agricultural produce. It imports machinery, equipment, means of transportation, and vehicle components from foreign trading partners. Attracting overseas investment is also apparent through incentives such as tax benefits, reduced import duties and simplified procedures for overseas investors.
 
In addition, shifting global supply chains and trading patterns could also drive opportunities in the region. The nation benefits from its geographical location owing to its position between Asia and Europe, to which the Uzbek Government recognises the prospects of investing in infrastructure, such as transportation and logistics, to create an efficient transit hub. Against this backdrop, China acknowledges the importance of developing routes along the Belt and Road while Europe has expressed a readiness to support Uzbekistan’s efforts to diversify transport corridors.

Line-up of shows include:

• Automechanika Tashkent; Futuroad Expo Tashkent; and, Scalex Tashkent: 23 – 25 October 2024
• Heimtextil Uzbekistan; Texworld Tashkent; and, Apparel Sourcing Tashkent: 6 – 8 November 2024
• Beautyworld Central Asia: 21 – 23 November 2024

Fashion for Good's Sorting for Circularity framework expands to address the challenge of ensuring rewearable textiles remain in use as opposed to finding their way into global waste streams or landfills. This 18-month project tests automated sorting technologies using artificial intelligence and machine learning to optimise the sorting of rewearable garments and enable greater circularity.

This project will test automated sorting technologies using machine learning and artificial intelligence (AI) to collect product information — such as colour, style, garment type, and quality. This will enable sorters and brands to make better decisions and sort efficiently based on product data and criteria from local, European, and export resale market requirements, thus optimising the flow of textiles to achieve their highest value potential.

To ensure accuracy and representation in capturing data on the flow of textiles within the EU and export markets, this project will focus on specific geographical regions: Lithuania (Nordic/Baltic), the Netherlands (Western), Poland (Central-Eastern), and Spain (Southern Europe).

The findings will be shared in a report with a supporting business case and implementation roadmap to inform investment decisions in infrastructure, Circular Business Models (CBM) and repair centres.

The Rewear Project builds on Fashion for Good’s Sorting for Circularity framework initiated in 2021 and subsequently launched in Europe, India and the United States harmonising the collection, sorting and recycling industries in order to advance textile-to-textile recycling technologies and the resale industry.

It is funded by brand partners adidas, BESTSELLER, Bonprix, C&A, Inditex, Levi Strauss & Co., Otto Group, PVH Corp., and Zalando. Circle Economy Foundation leads the creation and implementation of the methodology, with support from Consumption Research Norway, Oslo Metropolitan University and Revaluate.

Kornit Digital LTD., a leader in sustainable, on-demand digital fashionx and textile production technologies, announced the Company is taking the power of digital fashion to new heights with enhancements to the Kornit Presto MAX system for digital fabric decoration on demand.

Designed with the fashion and home décor industry in mind, the enhanced solution presents innovative capabilities for transforming virtual concepts into custom fabrics, supplementing digital efficiency and quality with white printing on colored fabrics. The new NeoPigmentTM Vivido ink achieves darker, deeper blacks and colors and establish new fashion standards with a pigment-based process. Kornit’s patented solution offers a streamlined and completely dry process for the a sustainable fabric decoration.

At ITMA 2023, Kornit will also be displaying an end-to-end partner ecosystem – underscoring how integrated solutions ensure a smooth transition towards a digital infrastructure and enable long-term business growth. Highlighting the power of partnership alongside Kornit is Greentex.co, a supplier of textiles and apparel leveraging digitally enabled, eco-friendly waterless printing. The company will be showing Presto MAX with fabrics highlighting the depth of black inks. Working alongside Kornit, Zünd will demonstrate how its modular cutting systems is the foundation for an end-to-end “eco factory,” completing fashion decorated by Presto MAX with their digital cutting solutions. Pentek Textile Machinery joins to display the possibilities for inline, sustainable softening of fabrics for unique and demanding applications.

• Currency-neutral sales up 4%, despite more than € 300 million negative impact from macroeconomic constraints
• Markets representing more than 85% of the business grow 14% overall
• Gross margin down 1.5pp to 50.3% reflecting significantly higher supply chain costs
• Operating profit reaches € 392 million
• Net income from continuing operations amounts to € 360 million
• FY 2022 outlook reflects double-digit growth during the second half of the year

“Our Western markets continued to show strong momentum in the second quarter amid heightened macroeconomic uncertainty. With Asia-Pacific returning to growth, markets combined representing more than 85% of our business grew at a double-digit rate,” said adidas CEO Kasper Rorsted. “With sports back at center stage this summer, revenues in our strategic growth categories Football, Running and Outdoor all increased by double digits. However, the macroeconomic environment, particularly in China, remains challenging. The recovery in this market is – due to continued covid-19-related restrictions – slower than expected. And we have to take into account a potential slowdown in consumer spending in all other markets for the remainder of the year.”

Currency-neutral revenues increase 4% despite macroeconomic constraints
In the second quarter, currency-neutral revenues increased 4% as adidas continued to see strong momentum in Western markets. This growth was achieved despite continued challenges on both supply and demand. Supply chain constraints as a result of last year’s lockdowns in Vietnam reduced top-line growth by around € 200 million in Q2 2022. In addition, the company’s decision to suspend its operations in Russia reduced revenues by more than € 100 million during the quarter. Continued covid-19-related lockdowns in Greater China also weighed on the top-line development in Q2. From a channel perspective, the top-line increase was to a similar extent driven by the company’s own direct-to-consumer (DTC) activities as well as increases in wholesale. Within DTC, e-commerce, which now represents more than 20% of the company’s total business, showed double-digit growth reflecting strong product sell-through. From a category perspective, revenue development was strongest in the company’s strategic growth categories Football, Running and Outdoor, which all grew at strong double-digit rates. In euro terms, revenues grew 10% to € 5.596 billion in the second quarter (2021: € 5.077 billion).

Strong demand in Western markets
Revenue growth in the second quarter was driven by Western markets despite last year’s lockdowns in Vietnam still reducing sales, particularly in EMEA and North America, by
€ 200 million in total. In addition, the top-line development in EMEA was also impacted by the loss of revenue in Russia/CIS of more than € 100 million. Nevertheless, currency-neutral sales grew 7% in the region. Revenues in North America increased 21% during the quarter driven by growth of more than 20% in both DTC and wholesale. Revenues in Latin America increased 37%, while Asia-Pacific returned to growth. Currency-neutral revenues increased 3% in this market despite still being impacted by limited tourism activity in the region. In contrast, the company continued to face a challenging market environment in Greater China, mainly related to the continued broad-based covid-19-related restrictions. As a result, currency-neutral revenues in the market declined 35% during the three-months period, in line with previous expectations. Excluding Greater China, currency-neutral revenues in the company’s other markets combined grew 14% in Q2.

Operating profit of € 392 million reflects operating margin of 7.0%
The company’s gross margin declined 1.5 percentage points to 50.3% (2021: 51.8%). Significantly higher supply chain costs and a less favorable market mix due to the significant sales decline in Greater China weighed on the gross margin development. This could only be partly offset by a higher share of full price sales, first price increases and the benefits from currency fluctuations. Other operating expenses were up 19% to € 2.501 billion (2021: € 2.107 billion). As a percentage of sales, other operating expenses increased 3.2 percentage points to 44.7% (2021: 41.5%). Marketing and point-of-sale expenses grew 8% to € 663 million (2021: € 616 million). The company continued to prioritize investments into the launch of new products such as adidas’ new Sportswear collection, the next iteration of its successful Supernova running franchise and first drops related to the Gucci collaboration as well as campaigns around major events like ‘Run for the Oceans.’ As a percentage of sales, marketing and point-of-sale expenses were down 0.3 percentage points to 11.8% (2021: 12.1%). Operating overhead expenses increased by 23% to a level of € 1.838 billion (2021:
€ 1.492 billion). This increase was driven by adidas’ continuous investments into DTC, its digital capabilities and the company’s logistics infrastructure as well as by unfavorable currency fluctuations. As a percentage of sales, operating overhead expenses increased 3.5 percentage points to 32.8% (2021: 29.4%). The company’s operating profit reached a level of € 392 million (2021: € 543 million), resulting in an operating margin of 7.0% (2021: 10.7%).

Net income from continuing operations reaches € 360 million
The company’s net income from continuing operations slightly declined to € 360 million (2021: € 387 million). This result was supported by a one-time tax benefit of more than € 100 million due to the reversal of a prior year provision. Consequently, basic EPS from continuing operations reached € 1.88 (2021: € 1.93) during the quarter.

Currency-neutral revenues on prior year level in the first half of 2022
In the first half of 2022, currency-neutral revenues were flat versus the prior year period. In euro terms, revenues grew 5% to € 10.897 billion in the first six months of 2022 (2021:
€ 10.345 billion). The company’s gross margin declined 1.7 percentage points to 50.1% (2021: 51.8%) during the first half of the year. While price increases as well as positive exchange rate effects benefited the gross margin, these developments were more than offset by the less favorable market mix and significantly higher supply chain costs. Other operating expenses increased to € 4.759 billion (2021: € 4.154 billion) in the first half of the year and were up 3.5 percentage points to 43.7% (2021: 40.2%) as a percentage of sales. adidas generated an operating profit of € 828 million (2021: € 1.248 billion) during the first six months of the year, resulting in an operating margin of 7.6% (2021: 12.1%). Net income from continuing operations reached € 671 million, reflecting a decline of € 219 million compared to the prior year level (2021: € 890 million). Accordingly, basic earnings per share from continuing operations declined to € 3.47 (2021: € 4.52).

Average operating working capital as a percentage of sales slightly decreases
Inventories increased 35% to € 5.483 billion (2021: € 4.054 billion) at June 30, 2022 in anticipation of strong revenue growth during the second half of the year. Longer lead times as well as the challenging market environment in Greater China also contributed to the increase. On a currency-neutral basis, inventories were up 28%. Operating working capital increased 23% to € 5.191 billion (2021: € 4.213 billion). On a currency-neutral basis, operating working capital was up 14%. Average operating working capital as a percentage of sales decreased 0.4 percentage points to 21.0% (2021: 21.4%), reflecting an overproportional increase in accounts payable due to higher sourcing volumes and product costs.

Adjusted net borrowings at € 5.301 billion
Adjusted net borrowings amounted to € 5.301 billion at June 30, 2022, representing a year-over-year increase of € 2.155 billion (June 30, 2021: € 3.146 billion). This development was mainly due to the significant decrease in cash and cash equivalents.

FY 2022 outlook reflects double-digit growth during the second half of the year
On July 26, adidas adjusted its guidance for FY 2022 due to the slower-than-expected recovery in Greater China since the start of the third quarter resulting from continued widespread covid-19-related restrictions. adidas now expects currency-neutral revenues for the total company to grow at a mid- to high-single-digit rate in 2022 (previously: at the lower end of the 11% to 13% range), reflecting a double-digit decline in Greater China (previously: significant decline). While so far the company did not experience a meaningful slowdown in the sell-through of its products or significant cancellations of wholesale orders in any market other than Greater China, the adjusted guidance also accounts for a potential slowdown of consumer spending in those markets during the second half of the year as a result of the more challenging macroeconomic conditions. Therefore, growth in EMEA is now expected to be in the low teens (previously: mid-teens growth), while revenues in Asia-Pacific are projected to grow at a high-single-digit rate (previously: mid-teens growth). Despite the more conservative view on the development of consumer spending in the second half of the year, adidas has increased its forecasts for North America and Latin America reflecting the strong momentum the brand is enjoying in these markets. In North America, currency-neutral revenues are now expected to increase in the high teens. Sales in Latin America are projected to grow between 30% and 40% (both previously: mid- to high-teens growth).   

Due to the less favorable market mix and the impacts from initiatives to clear excess inventories in Greater China until the end of the year, gross margin is now expected to reach a level of around 49.0% (previously: around 50.7%) in 2022. Consequently, the company’s operating margin is now forecast to be around 7.0% (previously: around 9.4%) and net income from continuing operations is expected to reach a level of around € 1.3 billion (previously: at the lower end of the € 1.8 billion to € 1.9 billion range).

The European Pultrusion Technology Association (EPTA) has published a report from its latest conference, which focuses on advances in sustainability and recycling.

More than 130 professionals from the global pultrusion community gathered at the 16th World Pultrusion Conference in Paris on 5-6 May 2022. Organised by EPTA in collaboration with the American Composites Manufacturers Association (ACMA), the event featured 25 international speakers sharing insight on market trends, developments in materials, processing and simulation technologies, and innovative pultruded applications in key markets such as building and infrastructure, transportation and wind energy.

‘Bio-pultrusion’:  
Composites based on natural fibres offer a number of benefits, including low density and high specific strength, vibration damping, and heat insulation. The German Institutes for Textile and Fiber Research Denkendorf (DITF) are developing pultrusion processes using bio-based resins and natural fibres. Projects include the BioMat Pavilion at the University of Stuttgart, a lightweight structure which combines ‘bamboo-like’ natural fibre-based pultruded profiles with a tensile membrane.

Applications for recycled carbon fibre (rCF):
The use of rCF in composite components has the potential to reduce their cost and carbon footprint. However, it is currently used to a limited extent since manufacturers are uncertain about the technical performance of available rCF products, how to process them, and the actual benefits achievable. Fraunhofer IGCV is partnering with the Institute for Textile Technology (ITA) in the MAI ÖkoCaP project to investigate the technical, ecological and economic benefits of using rCF in different industrial applications. The results will be made available in a web-based app.

Circularity and recycling:
The European Composites Industry Association (EuCIA) is drafting a circularity roadmap for the composites industry. It has collaborated with the European Cement Association (CEMBUREAU) on a position paper for the EU Commission’s Joint Research Centre (JRC) which outlines the benefits of co-processing end-of-life composites in cement manufacturing, a recycling solution that is compliant with the EU’s Waste Framework Directive and in commercial operation in Germany. Initial studies have indicated that co-processing with composites has the potential to reduce the global warming impact of cement manufacture by up to 16%. Technologies to allow recovery of fibre and/or resin from composites are in development but a better understanding of the life cycle assessment (LCA) impact of these processes is essential. EuCIA’s ‘circularity waterfall,’ a proposed priority system for composites circularity, highlights the continued need for co-processing.

Sustainability along the value chain:
Sustainability is essential for the long-term viability of businesses. Resin manufacturer AOC’s actions to improve sustainability include programmes to reduce energy, waste and greenhouse gas emissions from operations, the development of ‘greener’ and low VOC emission resins, ensuring compliance with chemicals legislation such as REACH, and involvement in EuCIA’s waste management initiatives. Its sustainable resins portfolio includes styrene-free and low-styrene formulations and products manufactured using bio-based raw materials and recycled PET.

The global composites community reunited at JEC WORLD 2022 on May 3rd to 5th for three days of innovation, networking and knowledge sharing. The industry was excited to reconnect in Paris after three years and the show exceeded all expectations in terms of product launches, content, business activity and attendance. Overall, the event welcomed 32,000+ professional visits, in Paris and online, from more than 115 countries and featured 1,201 exhibitors and 26 pavilions, whilst the JEC World Connect platform offered an additional way to explore the show this year.

While fewer Asian participants were able to join the show this year due to travel complexities, the attendance of a high level of decision makers from 117 countries and all key players along the value chain resulted in a dynamic environment for networking and business. As a consequence, companies were keen to confirm their presence next year; by the time the show closed its doors, 50% of JEC World 2023 exhibition space had already been booked.  Exhibitors and attendees have expressed very positive feedback about the quality of the exhibition and such a successful come-back of JEC World as the pinnacle event of the industry.

Innovations at JEC World
With more than 500 product launches during this year’s show, JEC World remains a popular venue to introduce new products to the global market.

The JEC Composites Innovation Awards celebrated 10 collaborative projects, reflecting the dynamism and the resilience of our industry, and two Innovation Planets displayed 80 impressive applications.

Celebrating its five-year anniversary, the JEC Composites Startup Booster competition is now established to discover startups in the advanced composites sector.

JEC World contributing to a more sustainable world
JEC World’s conference program shone a light on this year’s theme and most impactful topic: Composites for a Sustainable World. Sustainability continues to rise as a key growth driver for the composites industry, enabling diverse application sectors to achieve ambitious sustainability goals, from energy and transportation, to building and infrastructure, and so many more. JEC World highlighted how the growing application of composites will open up exciting new horizons for human activities, improving people’s lives and leading to a better, more sustainable world.

International community
Three Country on Stage presentations showcased the structure and strengths of the composites industries of South Korea, the Netherlands and the United States. The program featured keynote presentations and business cases which demonstrate the countries’ composites expertise  in hydrogen, in sustainable excellence, and innovation in building and mobility, respectively.

Ministers, ambassadors and official representatives from 16 countries also visited the show as part of dedicated official delegation tours from the United States, Turkey, Hungary, Taiwan, Portugal, Croatia, the Netherlands, the United Kingdom, North Macedonia, Germany, Slovakia, Luxembourg, Belgium, Sweden and Spain.

Thus, JEC World was the opportunity for government representatives to meet the leading composites actors of their respective regions or markets and show their support. Official inaugurations also took place on the Dutch, American and British pavilions.

The California Association of Sanitation Agencies (CASA) and INDA, Association of the Nonwoven Fabrics Industry joined in welcoming the recent introduction of the WIPPES Act in the U.S. Senate by Senators Jeff Merkley (D-OR) and Susan Collins (R-ME).

This bipartisan legislation is intended to address the growing problem of sewer system clogs caused by improper disposal of consumer wipes like baby wipes, household cleaning wipes, cosmetic wipes and others that are not intended to be disposed of in toilets. Improper disposal of these wipes can have significant negative impacts on wastewater infrastructure, including causing sewer spills. The bill would help address this problem by establishing federal requirements for these disposable wipes to carry prominent “Do Not Flush” labeling on packaging. Additionally, the bill would provide funding for an Environmental Protection Agency-administered grant program focused on educating consumers about how to recognize “Do Not Flush” labeling, identify relevant products, and understand the impacts that flushing these products can have on wastewater treatment infrastructure.

• Project delivered on schedule and at budget after two and a half years of construction despite challenges arising from a global pandemic
• New state-of-the-art lyocell plant with a capacity of 100,000 tons will help serve the growing demand for sustainably produced fibers
• Important milestone towards a carbon-free future has been set

The Lenzing Group is pleased to announce the completion of its key lyocell expansion project in Thailand. The new plant, one of the largest of its kind in the world with a nameplate capacity of 100,000 tons per year, started production on schedule and will help to even better meet the increasing customer demand for TENCEL™ branded lyocell fibers. For Lenzing, the project also represents an important step towards strengthening its leadership position in the specialty fiber market and into a carbon-free future.

The construction of the plant located at Industrial Park 304 in Prachinburi, around 150 kilometers northeast of Bangkok, started in the second half of 2019 and proceeded largely according to plan, despite the challenges arising from the COVID-19 pandemic. The recruiting and onboarding of new employees has been successful. Investments (CAPEX) amounted to approx. EUR 400 mn.

“The demand for our wood-based, biodegradable specialty fibers under the TENCEL™, LENZING™ ECOVERO™ and VEOCEL™ brands is growing very well. In Asia in particular, we see huge growth potential for our brands based on sustainable innovation. With the production start of the lyocell plant in Thailand, Lenzing reached an important milestone in its growth journey, supporting our ambitious goal to make the textile and nonwoven industries more sustainable”, said Robert van de Kerkhof, Member of the Managing Board.

In 2019, Lenzing made a strategic commitment to reducing its greenhouse gas emissions per ton of product by 50 percent by 2030. The target is to be climate-neutral by 2050. Due to the established infrastructure, the site in Thailand can be supplied with sustainable biogenic energy and contribute significantly to climate protection.

Together with the key project in Brazil and the substantial investments at the existing sites in Asia, Lenzing is currently implementing the largest investment program in its corporate history (with more than approx. EUR 1.5 bn). Lenzing will continue to drive the execution of its strategic projects, which are to make a significant contri-bution to earnings from 2022.

The current energy crisis is impacting on the competitiveness of the European textile and clothing industry. Because there are limited alternatives to the use of gas in different parts of the production process, production costs increase sharply. EURATEX asks the European Commission and Member States to urgently support the industry to avoid company closures. At the same time, we need a long term vision to move towards climate neutrality, while keeping the T&C industry internationally competitive.

EURATEX presented ten key requirements to Kadri Simson, European Commissioner for Energy, to develop such a vision:

1. The apparel and textile industry needs a safe supply with sufficient green energy (electricity and gas) at internationally competitive prices.
2. The transformation of industry requires access to very significant amounts of renewable energy at competitive costs. Additional investments in infrastructure will also be needed to guarantee access to new renewable energy supplies.
3. Until a global (or at least G 20 level) carbon price or other means for a global level playing field in climate protection are implemented, competitive prices for green energy must be granted at European or national levels (e.g. CCfDs, reduction on levies, targeted subsidies).
4. As the European textile and clothing sector faces global competition mainly form countries/regions with less stringent climate ambitions, it is of utmost importance that the European textile and clothing companies are prevented form direct and indirect carbon leakage.
5. EU-policy should support solutions, e.g. through targeted subsidies (for hydrogen, energy grids, R&D, technology roadmap studies etc.).
6. A dedicated approach for SMEs might be appropriate as SMEs do not have the skills/know-how to further improve their energy efficiency and/or becoming carbon neutral.
7. CAPEX and OPEX support will be necessary for breakthrough technologies, like hydrogen.
8. The Fit-for-55-Package must support the European Textile and Clothing industry in decarbonization and carbon neutrality. The EU must therefore advocate a global level playing field more than before. The primary goal must be to establish an internationally uniform, binding CO2 pricing, preferably in the form of a standard at G-7 / G-20 level.
9. EU-policy must not hinder solutions, e.g. we need reasonable state aid rules (compensating the gap between national energy or climate levies and a globally competitive energy price should not be seen as a subsidy).
10. The European Textile and Clothing industry has made use of economically viable potentials to continuously improve energy efficiency over many years and decades. The obligation to implement further measures must be taken considering investment cycles that are in line with practice. Attention must be paid to the proportionality of costs without weakening the competitive position in the EU internal market or with competitors outside the EU.

Please see the attached position paper for more information.