With the assistance of Covington, Unilever submitted the attached paper to the European Commission and a number of National Competition Authorities. It suggests a possible framework for the application of EU competition law to sustainability collaborations between competitors.  The paper is available here.

The paper reflects insights from experts across Unilever and puts forward examples of existing or possible co-operations, seeking to make the subject as concrete and tangible as possible from an industry perspective. The paper tries to integrate these scenarios into the framework of Art. 101 TFEU.

The paper seeks to contribute to the review of the horizontal guidelines in the EU, and the broader policy debate regarding sustainability collective action.