Avery Dennison Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Moderate	Avery Dennison provides a moderate level of transparency on its climate-policy lobbying. It names two identifiable EU regulations it is actively supporting—the Ecodesign for Sustainable Products Regulation and the Packaging and Packaging Waste Regulation—stating, for example, a wish to “Prioritize the Ecodesign for Sustainable Products Regulation (ESPR) implementation… by 2030” and to “Implement the … Packaging and Packaging Waste Regulation (PPWR) with no delays.” The company also sets out concrete results it wants from these files, including “Prioritize the roll-out of the DPP for first product groups by the end of 2026,” “Develop a DPP standard that applies to all digital labels mandated by EU legislation,” and “Introduce policy measures that incentivize circular transformation investments,” demonstrating clarity on its desired policy outcomes. By contrast, its description of how it seeks to influence policy is less detailed: it acknowledges involvement through trade associations and public-affairs agencies and notes that “We do not spend money on lobbying or political contributions,” and that it works with “a Belgium-based and a Washington D.C.-based public affairs agency to provide monitoring and policy analysis,” but it rarely identifies the particular government bodies or officials it contacts. As a result, while the objectives and policy focus are clearly articulated, the specific mechanisms and targets of its lobbying remain only partly disclosed.	2

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Avery Dennison has established a clear process to align its direct and indirect policy engagement with its climate strategy by tracking and reviewing relevant legislation and trade association positions. Specifically, the company “track[s] new and proposed climate change legislation through our engagement with trade associations and our sustainability organizations,” and “review[s] these regulations and engagements quarterly with those responsible for our sustainability efforts and make recommendations to ensure alignment with our Climate Change strategy.” Additionally, Avery Dennison’s “Climate Policy describes our strategy oversight and response to climate-related issues within our organization and throughout our value chain,” demonstrating a documented governance framework. While this indicates strong mechanisms for monitoring both direct lobbying and indirect advocacy through trade bodies, the disclosures do not identify a named individual or formal committee tasked with overseeing these lobbying alignment activities.	3