Products covered by the ESPR differ widely in terms of functions, usage patterns and information needs. This is why FESI supports an approach where any future label is assessed at the level of each product group, ensuring that the information provided is relevant, accurate and useful to consumers. Introducing horizontal requirements for a common label layout before defining the scope, metrics and methodologies risks increasing regulatory complexity and creating confusion for consumers. Together with other industry organisations, FESI is therefore calling for Article 16(5) of the ESPR to be reviewed and amended to avoid introducing horizontal labelling requirements that are not yet supported by clear methodologies.