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Memorandum on "Sustainable Consumption" Prepared by Euro Coop : December 1996 Table of contents : Introduction A. GENERAL COMMENTS Framework of action : 5th Community Programme of action "towards sustainable development" Environmental management instruments Instruments to assess the environmental compatibility of products Market instruments International context Terminology B. ACTION PRIORITIES The consumers' role Listening to their requests Determination of the consumers' part of responsibility Responsibility of producers and industry Integration in all policies Information/education Existing information elements How could consumer organisations contribute - Examples of action Introduction EURO COOP welcomes the priorities set by the Commission for the policy that it intends to carry out on behalf of consumers during the period 1996-98. In this paper, EURO COOP wishes to respond in particular and put forward its views with regard to the point raised under item 7 : "encouragement of practical approach to sustainable consumption". The previous action programmes having made it possible to put into motion the process of achievement of the internal market, it is now important to go a stage further and to deal with the questions or problems remaining as a result of new events or new obligations for the EU. The dual theme of sustainable development and consumption form part of the present concerns both on the part of the EU. institutions and of our European movement of consumer co-operatives. The consumer co-operatives are enterprises created by consumers for consumers and, as such, they are committed to supplying their members and consumers generally with a range of quality products and services, as part of a global approach. In fact, the Co-ops were among the first distributors to supply less environmentally harmful non-food products and organically produced foodstuffs. As enterprises of distributors, they have in fact to guide product development according to an environmental approach. Beyond the mere fact of offering products, they fulfil a social role by working towards a sustainable society. Thanks to their policy of consumer information and education, their objective is to help their consumer-members in making better buying choices. As they realise that they are responsible for the impact of their activities on the other parts of the planet and on future society, the consumer co-operatives involve their members in this commitment by making them aware that their purchases and consumption habits must be viable. Besides this implicit sense of responsibility vis-à-vis their environment, another motivation of the Co-ops is to be found in the task given to the world population at the 1992 Rio Conference. This Conference entrusted all NG0s, which have a similar mission as the consumer co-operatives, with an important role, that is their participation in the creation of an "ecocycle society", by following the principle according to which anything that is taken from nature must be used in a sustainable fashion, then be re-used recycled or finally disposed of with the least possible use of resources, so as to ensure that nature is not damaged. By reason of their dual commercial and social mission, the consumer co-operatives can play a significant role in establishing environment protection as one of the fundamental rights of consumers. As the Commission underlines in the presentation of its priorities for a consumer policy, everybody agrees (politicians, environmental NG0s, etc ... ) that, faced with the limited capacities of our eco-system, society and the European Union as a whole will not be able to remain viable unless the citizens-consumers adapt their behaviour and consumption habits so that growth remains within the limits of an acceptable, "sustainable" use of our common resources. Aware that human activities have repercussions on our environment, we must find the means by which to satisfy the needs and desires of individuals without putting future generations and our planet in danger. Before giving our comments on the action priorities of the Commission, we wish to emphasize a certain number of general comments which, in our view, call for clarification. A. GENERAL COMMENTS 1. Framework of action : 5th Community Programme of action "towards sustainable development" The 5th Community Programme of action "towards sustainable development", adopted in 1992, serves as a basis for the environment policy. It underlines the fact that the environment depends on our collective action and it proposes a general strategy by stressing the sharing of responsibilities through greater participation of the different actors in the socio-economic sector, whether it be at the level of the Member States, of their administrations, of public and private enterprises, or simply of the citizens The Commission has undertaken a review of this programme and published in early 1996 an "interim report on the state of progress of the implementation of this programme", in which the Commission itself admits the existence of certain weaknesses. In addition or in parallel to these points, EURO COOP point out here below what we consider to be the main deficiencies of this programme, from the consumer point of view : The consumer is cited as one of the "actors", but he appears simply as a passive actor and not as a responsible party. In cases where his responsibility is mentioned globally, the latter is very badly defined. The definition of concepts, such as "sustainable development" and "sustainable consumption", is too vague, despite the Resolution of the European Parliament which called for "easily understandable and precise definitions". Definitions are also incomplete regarding "partnership" and "environment policy actors". In this new strategy for the environment, enlargement of the range of instruments to be used to solve the different problems is only envisaged when there is a real need to establish an operational frame . The means to reach more sustainability are not indicated. The "integration" of environment requirements in other policies is only envisaged, without giving any sort of guidelines for such a goal to be reached. As a result, the "integration" of environmental concerns often remains a declaration of intent (even if in its interim report on the implementation of the 5th action programme, the Commission considers that this integration has progressed in the various target sectors). The legislative approach is incomplete and problems remain to be solved. The Directive of 20.12.1994 on packaging and packaging waste is the typical example of a legislation which does not make it possible to solve the problem at the source. The Directive does, of course, fix quantitative objectives of recovery and recycling, which the Member States will have to transpose into their national legislation, but the necessity to diminish the volume of packaging produced remains a declaration of intent, if the means of achieving this objective are not envisaged. Access to justice should be promoted. In the absence of direct harm of physical persons, the environmental associations do not in fact have the right to go to court in the general interest. This point has been underlined by the Commission in its interim report, in stating that "there has been no EU action to promote practicable access to the courts for individuals and public interest groups". 2. Environmental management instruments As already mentioned above, one of the new elements announced in the 5th Programme consisted in the enlargement of the panoply of environmental management instruments, but this has merely remained a declaration of intention. On this particular point, EURO COOP wishes to raise a number of issues. 1 . Instruments to assess the environmental compatibility of products The creation of instruments to assess the environmental compatibility of products, packaging, production and distribution activities must be encouraged and promoted. A consumer should not be asked to pay a higher price for a "green" product if its performance is inferior to that of A traditional product. The Life-Cycle Analysis (LCA) is a useful instrument providing for the analysis of the impact of a product on the environment, mostly used internally by the producer or the distributor as a sort of quality-test to help in the adaptation or improvement of the production. The harmonisation of the methods should be accelerated to facilitate a standard methodology. The Community 'system of environmental management and auditing (EMAS), based, like the Eco-label, on a voluntary approach, should be generalised and uniform standards for this must be adopted. If the system becomes compulsory, industry would be obliged to accept its own responsibility by making regular assessments and a consequent improvement of its performances. 2. Market instruments EURO COOP believes that, in addition to the stock of legislation, market instruments must be created. A more positive approach to taxation should be adopted, i.e the knowledge of how this money is used in view of promoting environmental good practices, instead of presenting it as a sanction. It is the opinion of EURO COOP that Eco-taxes are an effective instrument to promote more sustainable production and consumption patterns. Environmental taxes are not the only way to achieve environmental objectives, and economic incentives should also be found. This could be a price policy, making ecological products more competitive on the market. Unfortunately, there is still not enough account of environmental aspects in the indication of prices: a product which is not environmentally sound should lead to a cost-internalisation, so that the final price includes the damage to the environment, because the environmental impact must be taken into consideration, in the same way as other production factors. If the consumers' participation is considered as being crucial, it is impossible to change their behaviour just by requesting their financial contribution to environmental changes. Pressure should be made on the political bodies of the Member States so that the costs of the move to a more "sustainable" society are divided fairly resulting in the "polluter pays principle" fulfilling its real function of innovation and efficacity in the research of less harmful technologies. Markets for recycled materials of all kinds should be promoted. 3. International context EURO COOP wishes to strongly underline that the establishment of free trade by the suppression of trade barriers should not signify a watering down of environment protection. On the other hand, environmental management instruments andlor labelling should not be used as trade barriers for developing countries. 4. Terminology Before making any further comments, EURO COOP would like to stress the following, concerning the terminology: within the notion of "durable development", the durability is important because any development will only be lasting if it takes account of the limited disponibility of our resources and the increase in world population; as far as "sustainable consumption" is concerned, certain environmental problems may call, not for "greener" products, but for a diminution in their consumption, or the elimination of some of these products. Up until now, it was the exclusivity of the opulent society to wonder 'Which product to buy?" and not "is it really necessary to buy?". B. ACTION PRIORITIES If the main objective is to make the demand evolve and to introduce the concept of sustainability as an integral part of European cultural identity, EURO COOP would like to tackle 4 key issues which we consider as being crucial and logical for a global approach to sustainability. 1. The consumers' role 1 . Listening to their requests "Sustainable consumption" is a way of consuming which is compatible with a sustainable development, but the protection of the environment should be regarded as a fundamental consumer right, in the same way as security and quality of the products and their availability on the market. Providing consumers with full information is the best way to make them genuine actors. Enhancing dialogue between consumers, environmentalists and enterprises can be a way to provide consumers with the necessary information that will help them to make more sustainable choices. It is still too much a question of "protection" of consumers, in a "product" approach, instead of a real consumer policy which makes the consumers its actors. For example, as already mentioned above, in the 5th Community action programme the consumer only appears as a passive actor. 2. Determination of the consumers' part of responsibility Consumers have only limited possibilities to bring about the evolution towards a sustainable consumption. They can only give a few "signals" to producers, but the latter are the ones who are responsible for the direction taken by production. Consumers can only make their choice from the offer on the market, so that their choice is by nature limited. Consumers can only make their choice from the offer on the market, so that their choice is by nature limited. The consumers' role is different according to the various groups of products. In the 4 main consumption areas: food - paper products - household products waste (packaging), consumers have a direct impact on the two latter, whilst their role is rather one of "support" vis-à-vis production and industry in respect of food and paper. Obviously, it is possible to influence the environment directly by choosing less environmentally damaging products, with less packaging material for instance, and by knowing how to treat them afterwards. Indirectly, consumers can choose to buy products produced in a less environmentally harmful way (foodstuffs from organic farming, paper-products, etc ... ). In the first case, the consumer can bear a heavy responsibility, but helshe cannot be blamed for buying a product that is produced under poor environmental circumstances. Subsequently, and even if everybody agrees on the fact that "modern" consumption is not compatible with long term sustainability, before talking of 91 patterns", EURO COOP would recommend that DG XXIV (consumer policy) reinforce the work upstream, mainly with DG XI (environment policy), which is responsible for the stages preceding consumption. The consumer is brought into the picture too late, and placed before the "fait accompli"; it is the role here of DG XI to establish the definition of a "sustainable product". 2. Responsibility of producers and industry As stated above, if one wants to develop "good environmental behaviour", the fact that producers carry a great responsibility should be emphasized. A producer should assume that an environmentally sound product should be the norm. Environment is not an ideology anymore, damages to the environment have a serious impact on the society, in particular on people's health and security. In terms of own responsibility, assurance should be given that the "polluter pays principle" (PPP) fulfils its reparing damage role. Here again, the approach is incomplete because, when a damage is caused, it is not always possible to repare it. Yet, it is possible to enforce this principle through taxation, environmental charges, legislation and standardization. Fixing a legal definition of the producer's responsibility for more and more groups of products should for example be a way to induce them to price the treatment of their used products in an environmentally acceptable way. The legislative work with regard to environmental responsibility must be continued (burden of the proof; retroactive responsibility; future damages; fields of action "damages" or "activity" approach?, etc.). Concerning the problems of definition of responsibility, the European institutions could, in following a horizontal approach, draw their inspiration from the product liability Directive in order to make life easier for insurance companies, manufacturers and consumers. Voluntary agreements run counter to the shared responsibility principle. Their other main obstacle is that they require back-up in the form of confirmed political will to impose regulations if targets are not met. 3. Integration in all policies The need to maintain economic development while reducing environmental impact represents a real challenge for policy-makers, because this means they will have to implement strategies and instruments that encourage and facilitate alternative demand patterns by consumers. EURO COOP believes that actions to make consumers aware of the problems will only be credible if an integrated environmental policy is carried out on a parallel. The latter must be based on the principle of the sustainable cycle from the planning to the putting into operation of commercial activities, accompanied by appropriate environmental management systems, in order to participate in the preservation of our natural resources. The respect of the environment must moreover be a criterion for the selection of products. This should be achieved at the European level in all sectors and in all decisions of the European Union. For example, EURO COOP sugests that, in keeping with the spirit of the 1996 Directive on the assessment of the effects of certain public and private projects on the environment, every new Commission proposal should include an impact assessment on the possible effects of such new piece of legislation on the environment. Focussing on agriculture, and whilst the Commission talks of "providing regular reporting on the pressures and effects on the environment of agricultural practices", EURO COOP insists on the importance of biological diversity, which should be considered in the Common Agricultural Policy (CAP). 4. Information/education 1. Existing information elements The ECO-Label The ECO-Label scheme is an interesting approach, because it allows for the assessment of products having a reduced environmental impact. However, EURO COOP wishes to make the following comments on this scheme: this recent initiative is not visible enough on the market, because only a handful of products meet the criteria at present; so that they remain in a niche market position; the ECO-Label does not give consumers sufficient information for them to make a choice; the awarding process must be made more rapid and less costly in order not to give to the Co-ops, amongst other enterprises, the impression of being penalised rather than rewarded for their environmental behaviour; finally, in view of the new international context, such a system should be prevented from being used as a new type of trade barrier vis-à-vis products from developing countries. EURO COOP therefore requests that the reviewing process just started by the Commission helps to simplify the procedure and improve the ECO-Label scheme. Private labels The plethora of national and private labels, as well as the more and more frequent appearance of "green" claims, and of "green" marketing on the part of certain private firms does not help to provide the consumer with neutral and reliable information. EU. legislation on such claims is strongly needed. In view of previous experience concerning EU. legislation for claims on foodstuffs, EURO COOP fears that the Commission may consider that a solution to the problem of environmental claims could be included in the misleading advertising directive. EURO COOP wishes to underline once more that this would not be an appropriate solution. 2. How could consumer organisations contribute - Examples of action First of all, consumer organizations must act as the "relays" to educate and raise the awareness of citizens/consumers so that subsidiarity may fulfil its role of completing the legislative apparatus. Information campaigns Information campaigns on a more sustainable consumer behaviour should be organised at national and European level. They could, for example, include : the distribution of leaflets at points of sale giving "tips" for sustainable shopping; the development of a network of environmental "green telephones" giving practical information to consumers who wish to adopt a more sustainable behaviour at the time of purchase and during the use of certain products; development of electronic communication as a means of distribution of information to consumers. Educational initiatives Educational campaigns should encourage a new orientation of consumer behaviour towards more ecological consumption patterns. They could include workshops at points of sale; demonstration pilot projects with high visibility, i.e. travelling exhibitions, cooperation with educational systems to prepare the citizens-consumers to a more sustainable way of life. Introduction of environmental assessments of products and services in comparative tests and consumer surveys, together with information on performances, would help consumers in obtaining objective information. Comparative studies between the costs of the changeover to a "sustainable" consumption and the costs of no change would help in raising consumers' awareness. Promotion of the reduction, reuse and recycling of waste (policy of 3Rs). This means reducing waste from the very beginning, opting for reusable forms and recycled materials, and actively encouraging source-sorted waste collection by the consumer. Sociological studies Such studies could be organised throughout the EU, in conjunction with well known sociologists of the different Member States, in order to respect the national sensitivities of their citizens. If one wants sustainable consumption to be accepted as the only viable long term strategy for our society, certain consumer requirements must be re-defined, as well as the notions of "welfare" and "wealth". In the same way as certain economists are working on a new definition of economic growth, consumers must be educated to make them aware that to behave in a manner that is more respectful of the environment does not bring about a decrease in their quality of life. ********** The combination of the various actions referred to above should make it possible for the still somewhat theoretical notion of "sustainable consumption" to be transformed into a real political objective and for the collective force of consumers in their purchasing decisions to constitute a market signal.