EURO COOP welcomes the European Commission initiative to simplify and improve the regulatory environment by examining environmental agreements.

EURO COOP believes that the Communication should concentrate on defining voluntary agreements and setting-up guidelines on when and how to use them. We regret that a major part of the Communication deals more with regulatory measures than voluntary agreements.

It should be kept in mind that voluntary agreements are often introduced by industry when they perceive an interest in doing so - such as avoiding binding legislation. EURO COOP would therefore welcome the introduction of a formal and open process in order to closely monitor such initiatives.

It is the opinion of EURO COOP that it is vital for voluntary agreements endorsed by the Commission to be open, transparent and auditable if they are to work properly. This includes that third party independent audit should be possible. It is also necessary to include a mechanism that allows a review of a voluntary agreement.

EURO COOP is pleased to see that reference is made in the Communication to the UN-ECE Convention on access to information, public participation in decision-making and access to justice in environmental matters in connection with environmental agreements.

Nevertheless, EURO COOP would have liked to have seen more details on how to ensure that information on environmental agreements is made accessible to the public in accordance with the provisions of the Convention. This would be important in avoiding any risk of lack of transparency and democracy.

In general, voluntary agreements should be transparent. More specifically, they should meet the following requirements:

• Set-out the objectives to be achieved;
• Set deadlines and mechanisms relating to implementation;
• Identify methods of monitoring the application of agreements;
• Mention any sanctions impose in case of non-compliance;
• Transparency.

Since, as long as it is profitable to harm the environment in stead of protecting it, a change in some stakeholders' behaviour is not going to happen unless some kind of sanction is imposed. It is therefore in the Commission's interest to try to involve all stakeholders by appealing to their role and responsibility in society and to make it less attractive to pollute.

For instance, in the case of PVC, voluntary agreements in some EU Member States have shown not to work satisfactorily for all stakeholders.

EURO COOP would therefore caution against viewing voluntary agreements as the panacea for environmental problems.

Rather, voluntary agreements can be a helpful tool in combination with other legislative measures.