Brussels, 19 July 2004

EURO COOP welcomes the European Commission initiative to set out a strategy on the sustainable use of natural resources as outlined in the Communication: "Towards a Thematic Strategy on the Sustainable Use of Natural Resources" (COM (2003) 572).

EURO COOP agrees with the strategy's long term goal, which is to achieve a reduction of the environmental impact of resource use and the use of scarce resources, in accordance with the aims of general improvement in the environment, restoring and developing the functioning of natural systems and sustainable development of the EU as a whole.

However, EURO COOP is sceptical about the conclusion made in the Communication that predictions about global scarcity have turned out to be unfounded . Since it does not correspond to earlier statements in the text that there will be no reserves left of zinc, lead, copper and silver in 25 years time. On the contrary, EURO COOP believes that the scarcity of non-renewable resources is a serious threat to sustainable development and actions should be taken to prevent this.

EURO COOP furthermore believes that the proposed time period of 25 years for the strategy is a very long time span. It would be necessary to regularly update and revise the strategy during the 25 years for it to take into account new knowledge and scientific research.

The Strategy's Three Core Elements:

EURO COOP finds the three core elements of the strategy important. However, when it comes to knowledge gathering, EURO COOP would like to emphasize the role of the consumer. There is a need to recognise consumers as key players because the question of knowledge is not only scientific but also a question of behaviour and consumption patterns. It is therefore important that the strategy also focuses on products in order for the consumer to understand and to be able to change behaviour in the long run. Some tools already exist, such as eco-labelled and organic products, that can guide the consumer. However, education and proper information is important too in order to make consumers understand why they would need to change their habits and life style.

In this respect, EURO COOP's member organisations publish information on environmental issues on their web-sites, in brochures etc. and organise information evenings for their consumer-members.

Concerning the two other core elements, policy assessment and policy integration, EURO COOP believes that they go hand in hand. Since environmental problems related to resources are not due to different environmental policies but lack of integration of environmental issues in other policy areas. It is therefore necessary for the strategy to introduce measures to avoid conflicting policies.

Material Efficiency:

When it comes to material efficiency, there is a need to look at how to reduce excessive use of natural resources and where possible find alternatives, particularly when it comes to non-renewable resources. In this respect, waste could be defined as a resource, which currently is not used efficiently enough. It is therefore important to promote and introduce incentives to recover and recycle used products and materials to a higher extent than is the case today.

The Five Tasks:

EURO COOP supports the proposed five tasks as outlined in the Communication. Even so, EURO COOP would like to question if "Task 1: An estimate of materials and waste streams in the Community, including imports and exports, for example by using material flow analysis" is realistic to obtain. At the very best, one would get an estimate of the situation. EURO COOP therefore thinks that the use of staff resources could be spent better on some of the other tasks, in particular "Task 3: Establishment of goals and targets for resource efficiency and the diminished use of resources, de-coupling the link between economic growth and negative environmental impacts", which EURO COOP finds far more important. Studies already exist that could be used for task 1, so the strategy could in stead focus on the concrete actions that would need to be taken in order to meet the strategy's long-term goal.

Concerning "Task 5: Development and implementation of a broad range of instruments including research, technology transfer, market-based and economic instruments, programmes of best practice and indicators of resource efficiency" EURO COOP is particularly interested to see what economic instruments that are going to be proposed. EURO COOP believes that "getting the prices right" is important in order to correct market failures. Therefore a price policy should be introduced to make ecological products more competitive on the market. It would mean that a non-environmentally sound product should lead to a cost-internalisation, so that the final price would include the product's damaging impact on the environment. Such an incentive would provide true price transparency for the consumer when choosing between similar products. Therefore, full information and price transparency are crucial in order to "get the prices right".

In this respect, EURO COOP would have liked to have seen the issue of the use and benefits of environmental taxes as well as concrete proposed actions addressed in the Communication. EURO COOP believes that environmental taxes can be a useful addition to the measures that the EU can take to promote sustainable development, limit environmental damage and to preserve and improve the environment for the future . Since environmental pollution is, in many instances, a cross border issue and to ensure consistency for consumers, EURO COOP would prefer for environmental taxes to be introduced at EU level.

In general, EURO COOP favours a shift to taxation of activities that deplete natural resources or pollute the environment. However, there is a need to ensure that in any such change that the taxation burden does not fall disproportionately onto poorer consumers.