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Brussels, 29 November 2000
Euro Coop's Comments to the Green Paper on Environmental Issues of PVC (COM (2000) 469)
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 4 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's Green Paper on Environmental Issues of PVC (COM (2000) 469). Euro Coop believes that it is vital to create an EU strategy on this crucial issue taking into consideration the consumer and environmental aspects. Currently, the Green Paper outlines the problems connected to waste management and the use of certain additives. However, the Green Paper does not address consumer issues or the responsibility of producers.
It is vital that the stakeholders are properly involved in solving the problems connected to PVC. This can only be done by providing the necessary information to the consumers in order for them to play an active role in the use and in the management of PVC. As well, it is vital to hold producers financially and legally responsible for the impacts of PVC and PVC waste to the environment and to human health in order to promote a more sustainable behaviour.
It is apparent that an integrated approach to PVC is needed in order to develop the necessary measures to ensure a high level of protection of human health and the environment. By only introducing means solving the problems, when damaged have already been done, will not solve the problems connected to PVC in the long run, neither will ad hoc initiatives and voluntary agreements. Therefore, it is necessary to have a legislative framework that is based on consumer protection, the precautionary principle and producer responsibility.
Presently, initiatives have been taken ad hoc by companies to address the issue of PVC. As such, some of Euro Coop's member organisations have taken initiatives to remove PVC from certain products. The Danish organisation FDB and the Swedish one KF have both taken initiative to push manufacturers to find substitutes for phthalates used in baby toys, which can be put in the mouth. None of the two organisations are selling these kinds of toys in their co-ops. The Spanish organisation HISPACOOP also has a clear policy that products for children cannot be produced with PVC. For the packaging of own brand products it is the aim to change it little by little to non-PVC. This has happened in both FDB and the Italian organisation ANCC, where, for instance, the wrapping used for fresh meat products is PVC - free.
Turning to the questions raised in the Green Paper Euro Coop has the following comments to make:
1. Lead and cadmium:
Cadmium and lead in PVC products should be phased out as soon as possible. This should be part of a legislative framework.
2. Phthalates:
The precautionary principle must apply. Therefore the use of phthalates as plasticisers in PVC should be banned through permanent legislation, when there is a potential risk to human health or to the environment, as for example in young children's toys.
3. Waste:
Euro Coop believes that a legally binding framework will be the best approach to secure a proper handling of waste. Nevertheless, the legal framework should not only focus on waste and use of certain additives but also address the whole life cycle of PVC. It is important that the use of PVC is minimised as much as possible. It should be a key concept in the EU's approach to PVC. In addition, the industry must be financially responsible for setting up mandatory collection systems for products containing PVC and heavy metals. Furthermore, the precautionary principle must apply where there is a potential risk to human health and to the environment. In these cases the use of PVC or harmful substances in specific products must be banned and substituted for safer alternatives. As well, other products should be labelled if PVC is used in the product or the packaging in order to facilitate the separation of PVC waste from the general waste stream, but also for the consumer to be able to choose between products.
4. Horizontal Issues:
Euro Coop is disappointed that the Green Paper is only considering a substitution policy as part of an IPP for specific PVC applications, which cannot be separated from the general waste stream, such as, in packaging, motor vehicles, and electrical and electronic equipment. Since Euro Coop feels that an Integrated Product Policy (IPP) approach, included in a legislative framework, is a key tool in addressing the PVC issues. Euro Coop believes that many of the current problems, for instance, connected to waste, could be avoided by actually trying to find a way to integrate the environmental costs in to the price of a product. It would allow for a more fair competition between less environmentally friendly products and more environmentally friendly products. At the same time it will allow the consumers to make a choice and to develop a more sustainable consumption pattern. An IPP would encourage producers to find safer substitutes for their products, as it would not pay off to use PVC. As a consequence, PVC would be used to a lesser extent in various products and packaging than is the case today.
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