Brussels, 12 November 2003

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 3 Central and Eastern European countries. Created in 1957, EURO COOP today represents over 3200 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 initiative to elaborate a strategy to develop a comprehensive and consistent policy on waste prevention and recycling.

As stated in the Communication, waste presents our society with a two fold environmental challenge. First of all, waste can be a symptom of inefficient consumption and production patterns, in the sense that materials may be used unnecessarily. These materials not only create waste but also have different impacts during their production and use phase. Secondly, all waste has to be recovered or disposed of through operations, which inevitably have environmental impacts and economic costs. By focusing on the first challenge, the second one will partly be solved too.

For EURO COOP, it is therefore important to develop a comprehensive strategy on the prevention of waste, which includes prevention targets and measures needed to achieve them. This would mean changing the way resources are used in production processes and in products by modifying the behaviour of all actors in society. Prevention of waste must be the main focus in waste management.

EURO COOP believes that it is crucial that specified preventive means are introduced, such as:

• Incentives.
• Partnership initiatives.
• Innovation.
• Information, education and training.
• Producer responsibility.

Incentives:

EURO COOP agrees with the approach suggested in the Communication to address materials rather than end-of-life products. To do this a mix of instruments to address the issues of waste management would be necessary. This mix could include new legislative initiatives as well as economic instruments.

However, incentives should also be introduced to promote the use of recycled products, such as: tax reductions for recycling above a certain amount of waste; and tax on virgin raw material.

The above suggested incentives would also be closely linked to prevention of waste.

When speaking of prevention of waste, another tool would be the possibility to upgrade existing products.

Regarding Pay-As-You-Throw schemes, EURO COOP remains sceptical due to the possibility of illegal dumping.

Partnership initiatives:

The Commission should look into the possibilities of partnership initiatives with stakeholders to minimise waste in terms of new technologies and finding substitutes for materials that are better for the environment.

Furthermore, it would be important for Member States to share experiences on best practices concerning prevention and recycling of waste.

Innovation:

One option is innovation. Therefore the Commission should make funding available for research projects in order to explore new materials, techniques and technologies for more environmentally friendly products. In this respect, EURO COOP would urge the Commission to include the ideas presented in the Commission Communication (COM (2003) 302) on Integrated Product Policy (IPP) and to take into account the conclusions reached from the upcoming pilot projects as announced in the IPP Communication.

Information, education and training:

Another tool is to increase the level of information available to stakeholders, in particular businesses and consumers. A higher level of information should make stakeholders aware of the environmental problems connected to waste in order for them to change consumption habits in favour of more sustainable products. It is essential that the information given provides transparency in the following areas: the full costs involved, the price to pay, the environmental damages and health risks.

Moreover, it would also be important to provide training for stakeholders on the various aspects of waste prevention and recycling in order for them to understand the issues and to actively participate in solving the problems when buying products or handling waste. EURO COOP's member organisations are already doing this by educating, training and informing their staff and consumer-members.

However, when speaking of consumer involvement, information, education and training only partly contribute to consumers taking active part in waste prevention and recycling by better understanding the problems connected to waste and handling thereof. Waste recycling facilities must also be easily available to consumers.

Producer responsibility:

Finally, EURO COOP is in favour of introducing the principle of producer responsibility by making the producers in charge of the costs for the return, collection, reuse and recycling systems. It is an important principle to introduce in order to promote environmental responsibility among producers, as well as to secure a reduction in waste.