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Brussels, 16 October 1997
Opinion Paper on the revision of the Eco-label scheme
EURO COOP welcomes the long-awaited proposal for a revision of the Council Regulation n°880/92 establishing the Community Eco-label Award Scheme, as a voluntary instrument intended to promote products with a reduced environmental impact during their entire life cycle and to provide consumers with accurate and scientifically based information on the environmental impact of products.
The experience gained since the implementation of this Regulation shows that this scheme has not worked in a satisfactory way, mainly due to long and cumbersome procedures, and is not visible enough on the market. However, EURO COOP thinks that the Eco-label scheme is an interesting approach which should be encouraged, because it allows for the assessment of products which have a reduced environmental impact.
EURO COOP hopes that this revision process will help to increase the effectiveness, efficiency and transparency of the scheme. For such an instrument to make a real contribution to environment protection and to consumer information, EURO COOP wishes to underline the following requests:
- the Eco-label scheme should primarily be encouraged as a genuine, clear and reliable information instrument for consumers and should not only be used as a "marketing instrument";
- the awarding procedure should be simplified;
- the system should be much more publicised on the market, through advertising and consumer information. On the other hand, more products carrying the Eco-label should be made available on the market: to this end, the reluctance of manufacturers to apply to it should be overcome and they should be encouraged to increase their cooperation with retailers;
- the introduction of a graduated system (flowers) according to the score of the product on key environmental aspects is rejected, because it would be too complex and would change the meaning of the Eco-label scheme, which is supposed to help in identifying the most environmentally sound products. Rating a number of environmentally important aspects of a product category would make the choice by the final consumer more complex and less transparent by confusing the message;
- the proposal to widen access to the Eco-label scheme for products sold by retailers under their own-brand name is accepted;
- the proposal that, in order to be included in the scheme, a product group must represent a significant overall volume of sales and trade in the internal market, could be harmful to small enterprises. Their access to the Eco-label must be ensured;
- the current fee system is unsatisfactory, because it is too expensive and unfair. Small producers, who cannot afford it, thus lose a good information system to help consumers make their choice. On the other hand, the present open-ended royalty figure depending on the volume of sales is also discouraging for bigger producers. The proposed revision of the fee system is acceptable in its main lines (introduction of a ceiling for the annual fee - fixation of the fee regardless of the volume of products sold - reduced fee for SMEs and manufacturers in developing countries), but it is still felt that a ceiling of ECU 40,000 is too high;
- consumers should not have to pay for the cost of changing production methods, but the products which do not fit the environmental criteria should internalise the environmental cost, so that they would be more expensive than those with the Eco-label;
- if the Commission maintains that the Eco-label scheme is an instrument that helps to fulfill the Fifth Action Programme "Towards Sustainability", it should allocate some financial help to reach such an aim. Indeed, there are concerns over the Commission's financial proposals. The Nordic experiences from the "Swan" label show that the estimated Eco-label budget is at least 50% too low;
- a new organisation does not automatically solve the Eco-label's problems. An intermediate structures of a board composed of competent bodies from the different countries, under the chairmanship of the Commission would be preferable. Different criteria could be harmonised and the mutual recognition of criteria could be developed;
- whichever Organisation is created it should include representatives from consumers and environmental non-governmental organisations and should not put an end to the Commission's own responsibilities;
- the Eco-label scheme should not create unfair trade barriers vis-à-vis third countries.
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