Brussels, 23 January 2009

EURO COOP is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer co-operatives in 19 European countries. Created in 1957, EURO COOP today represents over 3,200 local and regional co-operatives, the members of which amount to more than 23 million consumers across Europe. Brussels, 23rd January 2009

1. INTRODUCTORY REMARKS

Euro Coop welcomes the long-awaited publication of the Action Plan on Sustainable Consumption and Production (SCP) and Sustainable Industrial Policy (SIP). Sustainability practices in general and Sustainable Consumption and Production policies in particular, have long been a core concern for consumer co-operatives gathered in Euro Coop as they perfectly match consumer co-operatives' founding values of respect towards the Environment and future generations.

Consumer co-operatives are a special kind of enterprises, created by consumers for consumers and, as such, they are committed to supplying a range of quality products and services that respond to broad sustainability criteria encompassing environmental, economic and social standards. From an historical point of view, it is worth mentioning that consumer co-operatives were among the first retailers to supply environmentally friendlier non-food products, organically produced foodstuffs as well as, for example, products derived from Fair Trade.

It is also important to note that consumer co-operatives, thanks to their policy of consumer information and education, are able to help their consumer-members in making better buying choices. They realise, in fact, that they are responsible for the impact of their activities on the planet and on future generations, and therefore, involve their members in this commitment by making them aware that their purchases and consumption habits must be as sustainable as possible.

Euro Coop believes that the sustainability Action Plan should also address wider product performance issues that go beyond the environmental criteria that are commonly associated with sustainability. Social and economic concerns such as quality, safety, affordability, functionality, health and convenience will be vital factors in ensuring that consumers embrace innovative products and services. It is crucial that these criteria are developed consistently across different policies.

That being stated, Euro Coop wishes to put forward its comments and remarks regarding the specific aspects of this Action Plan as detailed below.

2. THE ENERGY LABELLING DIRECTIVE

Euro Coop preliminary considers that, as a matter of fact, the Energy Labelling Directive 92/75/EC has pushed the market towards more efficient products by helping consumers to choose more efficient energy appliances. It thus welcomes the EC effort to extend its reach to cover a wider range of products, including energy using and other energy-related products. This policy shows to be in fact in line with Euro Coop's members expectations as a great number of them have been for a long time frontrunners of energy efficiency practices.

Euro Coop wishes though to recall the importance that any proliferation of different labels must be avoided to prevent consumers from getting confusing messages. More specifically, to ensure a coherent product policy it is fundamental that the technical basis adopted for one product policy is the same for all policy instruments.

Also, to help consumers decrease their carbon dioxide footprint, any change in energy labelling must be geared towards providing them with standardised and easily recognisable information. In this regard, Euro Coop considers that the main strengths of the current EU energy label lay in its compulsory format, the display of the label at point of sale and the simple message it conveys. This label has proved to be consumer-friendly and its success suggests that these features must be preserved. Simplicity, effectiveness and standardised information must be then regarded as key in any further evolution this labelling system might incur.

Euro Coop finally would like to take this occasion to stress that the European Union should be making progress with the manufacturers of electrical goods to ensure that these goods consume less electricity when on stand-by. The achievement of this goal would result into substantial energy savings even if the primary goal remains education and consumer awareness towards avoiding stand-by practices.

For further information on the same subject.

3. THE ECODESIGN OF ENERGY USING PRODUCTS DIRECTIVE 2005/32/EC (EUP)

Euro Coop welcomes the European Commission recast of the framework Directive establishing a framework for the setting of Ecodesign requirements for energy related products (EuP) and its aim to extend its scope to all energy-related products. As expressed in the paragraph above, Euro Coop considers that a great unexploited potential will be unleashed to the benefit of the environment and human health.

Also, Euro Coop is of the opinion that the design requirements need to indicate more specific targets for the manufacturers in order to have any impact. It in fact considers them to be too vague as currently laid down.,.

Regarding then the proposal of the Rapporteur to proceed to the immediate extension of the scope of the Eco-design requirements to all products except for means of transport for persons or goods, Euro Coop certainly believes that this could be a good means to better adapt to future environmental challenges and priorities such as the sustainable use of natural resources. It therefore supports the provisions aimed at attaining this goal.

4. THE EU ECOLABEL

Many of the consumer co-operatives gathered in Euro Coop were among the first retailers to adopt the Ecolabel scheme (also known as "The Flower") as they had long since firmly believed that it could represent a useful policy tool to attain a truly sustainable consumption and production policy. In this regard, Euro Coop appreciates the effort outlined in the regulation proposal to include additional product groups in the scope of Ecolabel as it sees this as an important step forward for the growth of the scheme. Nevertheless, it wishes to stresses the importance that their development be based on market analysis as this will ensure the relevance of a new product group in terms of potential purchasers and therefore motivate manufactures to get their products Ecolabelled.

In addition to that and regarding the introduction of harmonisation measures with other Ecolabelling schemes, Euro Coop considers that flexibility is key and suggests that the Flower constitutes a minimum baseline for the existing national and regional Ecolabels. It also supports the possibility that for product groups which are not covered by the EU Ecolabel, national labelling schemes are 'accredited' to offer the EU Ecolabel.

As to marketing measures, Euro Coop welcomes the EC's intentions to boost them and advises that it is important that the specific marketing of the Ecolabel is national, in order to have it adjusted to the campaigns of each market. However, it considers that Article 12 of the proposal does not suggest any new measures on how to improve the promotion of the scheme. It only mentions awareness-raising and information campaigns, which have already taken place until now. In this context, new measures of promotion are desirable in order to increase the general uptake of the Eco-label.

Euro Coop is also supportive of the measures aimed at making the system less costly and bureaucratic. It in fact considers that one of the main problems encountered for the development of the Flower has been its rigid institutional framework, which has contributed to a certain degree of paralysis. Euro Coop also agrees with the proposal to set mandatory environmental performance standards for products.

With reference to the extension of the Ecolabelling to food, Euro Coop is not in favour of the proposal as it is currently laid down. In this regard, it firstly considers that a possible confusion among a plethora of sustainability logos placed on the same product might take place, with special reference to the organic food labels. Euro Coop thus calls for a clarification of the links between the present proposal on the Ecolabel scheme and Regulation (EC) No 834/2007 on Organic Food.

Secondly, Euro Coop believes that Ecolabelling criteria must necessarily encompass a life-cycle thinking and thus not be limited to certain stages of the agricultural food chain. It therefore considers the current proposal as partial. Euro Coop nevertheless encourages further research on this relevant issue aimed at keeping strict criteria and live up to the reputation of the Scheme.

5. GREEN PUBLIC PROCUREMENT (GPP)

Euro Coop considers that the Action Plan's inclusion of a Communication on Public Procurement for a better environment represents a positive step forward. It indeed sees the role of Green Public Procurement (GPP) as essential for the widespreading of the Ecolabel and considers that the proposals for minimum levels of environmental performance for products and services in it are a very good means of providing clarity to procurers and create a certain minimum level playing field.

However, Euro Coop notes that the ambition levels of these "core" criteria need to be carefully set so as not to create confusion in relation to the EuP Directive environmental benchmarks or the European Ecolabel. GPP core criteria which are set for example at a level below the Ecolabel will send confusing messages and seriously threaten the attractiveness of that label to companies wishing to use it as the mark of environmental excellence for more easily winning public authority contracts.

6. THE EMAS REGULATION

Euro Coop considers that the Community system of environmental management and auditing (EMAS) should be generalised and that homogeneous standards for this must be adopted. Euro Coop also demands to start a process for linking EMAS to the Ecolabelling system as it has been outlined many times before at EC level.

7. CONCLUSIONS

In the last analysis, Euro Coop considers that this Action Plan represents a step forward in the achievement of sustainable consumption and production policy even if it lacks of the necessary ambition to fully attain this important goal. It therefore wishes to put forward a series of recommendation which, given the economic and social weight that the consumer co-operative sector represents in the EU, it hopes that this will be taken into due consideration.

• It is important to include in an Action Plan focussing on sustainability factors linked to product performance that go beyond strict environmental criteria and touch upon social and economic concerns. In this regard, products issued from Fair Trade represent an excellent example. Other features like quality, safety, affordability, functionality, health and convenience of a product need to be equally taken into consideration;
• The relationship between SCP/SIP and other areas of policy where key impacts are made - agriculture, housing and transport - needs to be strengthened, as SCP/SIP should act as a link between the individual policy areas and sustainable development;
• More focus is needed to the harmonisation of the separate policy mechanisms to ensure effective environmental improvements and to safeguard each mechanism's role and objectives;
• Economic and fiscal policies need to be studied further by the Commission within the context of SCP/SIP, and Member States need to discuss the systematic use of harmonisation in these areas;
• The voluntary approach put forward in the Action Plan is in contradiction to the results of the Commission's consultation on the Action Plan, where "lack of long-term policy and regulatory direction" was seen as the key barrier to innovation. It is then advisable to reverse this trend as a voluntary approach does not give clear market signals on the development of the intended policy framework;
• It is important to avoid an increase of bureaucracy and administrative burden especially for smaller actors.

In conclusion and in spite of the praiseworthy effort made through this Action Plan, Euro Coop believes there is a need for further action towards reaching a more sustainable industrial policy as well as more sustainable consumption and production patterns. This huge challenge, which consumer co-operatives have taken up long since as it is an integral part of their values and mission, needs the bar to be set higher and further synergies to be created. Only with a higher level of ambition, a full and dedicated co-operation of all actors involved and a consequent setting of all needed legislative tools the mission to create a truly sustainable environment and society will be finally achieved.

For further information, please contact:
Rosita Zilli - Policy Adviser
Email: rzilliateurocoop.coop - Tel.:+32-2-285-00-72 - Fax.:+32-2-231-07-57