Brussels, 3 November 2003

EURO COOP is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer co-operatives in 11 of the 15 Member States of the EU and in 3 Central and Eastern European countries. Created in 1957, EURO COOP today represents over 3,200 local or regional co-operatives, membership of which amounts to over 19 million consumers in the EU and 2 million in the associated countries of Central and Eastern Europe.

EURO COOP welcomes the European Commission Proposal for a Directive on establishing a framework for the setting of Eco-design requirements for Energy-Using Products and amending Council Directive 92/42/EEC (COM (2003) 453).

However, EURO COOP believes that the objective of the Directive should be based on environmental aims, such as environmental protection and sustainable development, and not solely on the free movement of goods as is currently the case. By including environmental aims as part of the Directive's objectives, EURO COOP believes that the environmental aspects of the consumer appliances concerned would be properly covered.

In addition, EURO COOP finds it unfortunate that the proposal does not set a framework of binding targets, deadlines and bench marks, and is completely absent of stakeholder involvement. For instance, the option to leave initiatives to the individual manufacturers on eco-design requirements makes it impossible to have any input of other stakeholder opinions or any form of independent evaluation of the performance of the individual products through the eco-design actions taken.

EURO COOP, as already stated in its initial comments to a previous Commission Working Paper , would have liked the issue to have been dealt with in the Directive (2002/96/EC) on waste electrical and electronic equipment (WEEE) in order to have an overall and more ambitious approach. As this is obviously no longer achievable, EURO COOP believes that the Directive must take into account the provisions of Directive 2002/96/EC.

Furthermore, EURO COOP is disappointed to see that once more that no incentives are proposed to promote innovation. In EURO COOP's opinion, it is important to continue developing more sustainable products in order to protect the environment and human health. Therefore, financial support should be made available at both national and EU levels for independent research in order to promote "greener" electrical and electronic equipment.

Moreover, there is no mention of upgrade ability of goods. This should be addressed in the proposal in order for it to deal properly with impacts on the environment.

EURO COOP is of the opinion that the design requirements need to be more specific and binding for the manufacturers in order to have any impact. As they are written now, they are too vague in their requirements and leave it too much up to the manufacturers to decide what is the most appropriate design solution, especially the environmental aspects.

On the other hand, EURO COOP welcomes the inclusion of information concerning the environmental design aspects as part of the requirements - particularly information to consumers. However, information should not only be provided to consumers via labelling of products but also be made available via web-sites, brochures in shops, information campaigns and educational measures in order for consumers to be better involved in the process.

EURO COOP stresses that the information given on similar products must fulfil the same requirements and address the same characteristics in order for the consumer to be able to compare and choose between products.

Finally, EURO COOP would like to emphasise the importance of establishing a connection between the proposed Directive, eco-labelling and the Commission Communication on Integrated Product Policy (IPP) of 18 June 2003.