Brussels, 24 June 2004

EURO COOP is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer co-operatives in 16 of the 25 EU Member States and in 2 EU Candidate Countries. Created in 1957, EURO COOP today represents over 3,200 local or regional co-operatives, membership of which amounts to 22 million consumers in Europe.

EURO COOP welcomes the European Commission initiative to set out a European environment and health strategy as well as the Action Plan as outlined in the two Communications (COM (2003) 338) and COM (2004) 416).

There are a number of existing programmes and measures (e.g. the 6th Environmental Action Programme, the EU Public Health Programme for 2003 - 2008, and the proposal on a new chemical policy, REACH) dealing with the environment and health but the Communication on a strategy is the first attempt to have an integrated approach on the issue. Unfortunately, it fails to address how the various existing programmes and initiatives should be co-ordinated.

EURO COOP agrees with the three objectives in the proposed strategy, namely:

• To reduce the disease burden caused by environmental factors in the EU.
• To identify and to prevent new health threats caused by environmental factors.
• To strengthen EU capacity for policymaking in this area.

As well as, the five key elements in the proposed strategy SCALE: Science, Children, Awareness, Legislation and Evaluation.

EURO COOP welcomes the involvement of all stakeholders in the development of the strategy.

Nevertheless, EURO COOP would like to caution against putting too much emphasis on further studies but rather to concentrate the strategy on what concrete actions can be taken.

EURO COOP believes that the strategy must build on the following four principles:

• The precautionary principle.
• To secure a high level of protection for all.
• To prevent environmental factors' negative effects on health.
• Information and stakeholder participation in order for all to take responsibility for a healthy living.

In this respect, EURO COOP calls for the following:

1. Clear Definition of the Health Concept

EURO COOP calls for a clear definition of the health concept. It is not sufficient just to link it to statistical data on health care. Since it can be difficult to prove what is the cause and what are the effects. For instance, what causes the illness? Does it come from the air, the food or a combination? How does one show that the cause of the illness is due to dioxin, endocrine disrupters etc., when there is no clear proof? One example is the case of men and women's sterility or difficulties in having children, where the cause is unknown but may be due to endocrine disrupters. Another example is the so far scientifically fairly unknown "cocktail effect" as described under point 3 (Precautionary Principle and Principle of Substitution).

It is therefore necessary to identify the risk areas not primarily from statistical data on health care but also from potential risks.

2. Endocrine Disrupters

EURO COOP would therefore like to reiterate its call for the Commission to speed up the process of identifying the problem of endocrine disruption, its causes and consequences. The Commission must take immediate action in cases where vulnerable groups are exposed to known endocrine disrupting chemicals.

3. Precautionary Principle and Principle of Substitution

Furthermore the precautionary principle and the principle of substitution must be introduced to make the environment as poison less as possible. It is particular important to stress the use of the substitution principle within the framework of the REACH proposal. Methods should be developed in order to risk assess cocktail and synergy effects of chemicals. If not, there is a risk that chemicals will be authorised due to their PNEC (potential no effect concentration), despite the fact that there would be a problem if a number of chemicals appear as a "cocktail" in the air, the sewage sludge, water or soil.

4. Producer Responsibility

EURO COOP calls for the strategy to introduce producer responsibility. The burden of proof must lie with the producers to guarantee that their products will not cause any harm to human health or the environment. It must also be the producer's responsibility to substitute substances or processes for less hazardous ones in order to lower the risk and not only to avoid using the officially recognised hazardous ones.

5. Information to Consumers

EURO COOP believes that it is important that consumers become aware of environment related health problems by receiving proper information. Some of the tools could be to use and promote eco-labelled and organic products to guide consumers, but also via education, various kinds of information material and information on web-sites etc. This is important in order to make consumers understand why they would need to change their habits and life style. In EURO COOP's opinion, there is therefore a public responsibility to take action in promoting eco-labelled and organic products.

In this respect, EURO COOP's member organisations publish information on health and environment related issues on their web-sites, in brochures etc., but also publish educational material to secondary schools and elderly people as well as organising events for their consumer-members.

EURO COOP, furthermore, believes that the strategy should not only target children but also other vulnerable groups such as pregnant women and people with allergies. EURO COOP would therefore like for the Action Plan to address the issue of allergies and what kind of actions needs to be taken.

6. Public Authorities

EURO COOP believes that co-ordination among public authorities in the EU Member States is vital in order to secure that the actions taken on health and environment are successful.

It would therefore also be important to make it clearer in the Strategy and Action Plan what the EU Member States' obligations are in taking action and also what those actions should be.

7. Conclusion

In conclusion, EURO COOP would like to see immediate actions taken to reduce negative effects of chemicals, to replace hazardous substances faster with less-hazardous, to reduce occurrence of allergies and respiratory problems, and to strengthen efforts in the field of endocrine disrupters.