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Brussels, 14 april 2000
Euro Coop's Proposals to the 6th Environmental Action Programme
I. Introduction
II. Euro Coop's Priorities
- Role of the Consumer
- The Role of the Producer
- An EU Chemical Strategy
- Packaging and Packaging Waste
- Green Claims
- The EU Eco-labelling Scheme
- Market Instruments
- Integration of Environmental Policy into other Policy Sectors
III. Annex : [Denmark] [Finland] [Italy] [Portugal] [Spain] [Sweden] [United Kingdom]
I. Introduction
Euro Coop is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer co-operatives in 13 of the 15 Member States of the EU and in 5 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 initiative to invite all interested parties to submit their proposals for what should be the priorities in a 6th Environmental Action Programme. In this context, Euro Coop would like to give its proposals based on the Commission's Communication: "Europe's Environment: What directions for the future?" (COM(1999)543).
Euro Coop believes that consumers are important partners in the promotion of a sustainable development and in the protection of the environment. Nevertheless, they can only play their full role if the appropriate resources and choices are offered to them. These elements should be properly addressed in EU's 6th Environmental Action Programme.
Consumers do have a responsibility in choosing more environmentally friendly products, and in adopting more sustainable consumption patterns. However, this can only be achieved if they have access to full information about the environmental impact of a product and if they are offered a real choice of products with reduced negative environmental impact. This choice will not only depend of the range of products available, but also on the price policy. Too often, consumers must pay a high price for environmentally friendly products. Even so, consumers can only be responsible partners, if the other actors of society are prepared to take upon them their share of responsibility. In particular, producers should be encouraged to promote more environmentally sustainable products and consumer information about the products.
In this respect, Euro Coop's member organisations are taking a range of actions to provide consumers with information on environmental issues and taking environmentally sustainable actions within their co-ops. For instance, many of our member organisations have had information campaigns on the sustainable use of packaging in order for the consumers to become aware of the environmental problems connected and thus change to products with less packaging, if possible. Another example of their work for more consumer information is leaflets made available for consumers in many of the organisations' co-ops on various environmental issues, like eco-labels, organic food and recycling points. Please, see the annex attached for more examples from each member organisation.
Moreover, Euro Coop wishes to see priority given to: an EU chemical strategy, packaging and packaging waste, green claims, the EU Eco-labelling scheme and integration of environmental policy into other policy sectors.
Finally, Euro Coop urges the Commission to draft a programme where practical measures are proposed on how to solve environmental problems and not to consist of long theoretical discussions. Only then, will a new programme truly reach its two goals: promoting a sustainable development and protecting the environment by taking into consideration the role and responsibility of each stakeholder in society.
Contacts:
Caroline Naett, Secretary General
Louise Ousted Olsen, Adviser
II. Euro Coop's Priorities
More specifically, Euro Coop would like to see that the following issues are given priority in the 6th Environmental Action Programme :
1. The Role of the Consumer :
Euro Coop believes that it is essential that the role of the consumer as an active player in protecting the environment is properly addressed throughout the 6th Environmental Action Programme. If the Commission seriously wants to solve existing and potential environmental problems. Therefore Euro Coop calls on the Commission to introduce means and resources in the programme to enable the consumer to take an active and responsible part in achieving a more sustainable environment. As such, two things must be fulfilled: full information and choice of products.
Euro Coop has over the years argued that it is vital for the consumer to receive full information in order to change for a more sustainable consumption pattern. One way to provide consumers with the necessary information in order for them to make more sustainable choices would be to enhance the dialogue between consumers, environmentalists and enterprises. In that respect, Euro Coop's member organisations as consumer co-operatives are taking their responsibility seriously in contributing to a more sustainable environment. They are taking a range of actions to provide consumers with information on environmental issues and taking environmentally sustainable actions within their co-ops. Please see the annex attached for examples of actions taken by Euro Coop's member organisations over the years in their respective country.
Furthermore, the consumer is limited in choice of products available on the market. It is necessary that the producers make more sustainable products available for the consumer to have the option to act in a more environmentally responsible way. Therefore the producers have a huge responsibility, too, in the direction sustainable consumption and environmental protection take.
2. The Role of the Producer :
Euro Coop would like to see the responsibility of producers and industry addressed properly in future legislative proposals by introducing means, such as: the Polluters Pay Principle (PPP) and reverse burden of proof. Assurance should be given that the PPP fulfils its role to repair damage done. It is possible to enforce the principle through taxation, environmental charges, legislation and standardisation. For instance, one way to ensure that the principle is respected, would be through a differentiated environmental tax, which would indirectly reward producers who are taking environmentally sound actions that are quantitatively and qualitatively measurable. As they would not have to pay the tax and consequently their products would be cheaper for the distributors and consumers. At the same time the tax would make sure that producers polluting the environment would be held responsible for their damage by having to pay the tax. Preferably, such a tax would encourage polluters to change their behaviour into a more environmentally sustainable one. Presently, taxpayers, and consequently consumers, are paying for environmental damages caused by producers. In addition, the introduction of a legal definition of the producer's responsibility for more and more groups of products would be a way to induce them to price the treatment of their used products in an environmentally acceptable way.
3. An EU Chemical Strategy :
As stated in Euro Coop's position paper on Chemical Policy from 26 January 1999, we wish to see an EU chemical strategy based on :
- The Precautionary Principle: everyone who handles chemicals must take the necessary precautions in advance to prevent damage to other persons and/or the environment.
- Producer responsibility: the burden of proof should be placed on producers who would have to prove that a substance is not harmful to the environment in its production, use and disposal.
- Consumer protection: chemical controls must take into account the possible impact on consumers.
Therefore a new revised EU chemical policy should include:
- A risk assessment approach which tackles "generic" groups of chemicals, rather than the current substance-by-substance approach. The current approach costs too much in time and resources.
- A comprehensive approach to chemicals, focusing on their use, dispersion and disposal throughout product life cycles and not just on impacts during chemical production.
- A development of criteria for persistency, bio-accumulation and toxicity.
Furthermore, to ensure that consumer protection is respected Euro Coop suggests that the EU considers the following in a new chemical strategy :
- Environment declarations, which specify each product's chemical content, should be obligatory for producers to put on their products. This would allow the consumer to make an informed choice about whether or not to buy a particular product.
- Legislative provisions to provide a general framework for encouraging voluntary co-operation between the EU, the chemical industry and consumers to ensure that the consumers' voice is heard in all discussions on chemical policy.
4. Packaging and Packaging Waste :
Euro Coop would welcome a more efficient resource use and management. As called for in its comments to the revision of the Directive on Packaging and Packaging Waste (94/62/EEC) from 24 November 1999, Euro Coop wishes to see means introduced to diminish the volume of packaging produced. It believes that it is crucial that preventive means are introduced to get to the root of the problem, namely, less packaging produced, in order to obtain sustainable consumption in the long run. Therefore, the primary aim of a revised Directive must be prevention in terms of reduction of packaging and packaging waste. One mean would be to increase the level of information available to users of packaging, in particular businesses and consumers. A higher level of information should make users aware of the environmental problems connected to packaging and packaging waste in order for them to change consumption habits in favour of a sustainable environment. It is essential that the information given provides transparency in the following areas concerning packaging waste management: the full costs involved, the price to pay, the environmental damages and health risks. Furthermore, 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 to promote environmental responsibility among producers and traders, as well as to secure a reduction in packaging and packaging waste. In the current system society is paying and in the end the consumers. It seems only fair that the producers become directly responsible for use of packaging for their products by the introduction of the PPP.
5. Green Claims :
Euro Coop has been calling for EU legislation on green claims for many years in order to provide consumers with neutral and reliable information, recently in its Comments to the Commission's Consultation Document on Green Claims from 17 September 1999. It is important to maintain consumer confidence in ecological products. Euro Coop would therefore welcome a Community approach on green claims. Euro Coop is of the opinion that a separate legislation is needed. In addition, Euro Coop only sees such a legislation as the first step in the right direction of the more ambitious target in having only sustainable products on the market as a matter of the consumer's health and safety in the long run.
6. The EU Eco-labelling Scheme :
Euro Coop supports the principles underlying the 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. However, as pointed out in Euro Coop's two position papers from 16 October 1997 and from 16 February 1999, for the label to make a real contribution to environment protection and to consumer information the following should be respected :
- Informs the consumer about the reduced environmental impact of a product in an easy manner that can help him decide on the purchase of the product at the point of sale.
- Encourages producers to take on board the scheme, and thus increase its visibility.
- Internalise external costs. Eco-label schemes are actually the opposite of this, as producers have to pay when the product is more sustainable.
- Organise extensive marketing campaigns to increase awareness of the scheme.
In the light of the problems encountered with the recognition and with the implementation of the EU Eco-label Scheme, Euro Coop is in favour of using national labelling schemes parallel to the EU Eco-label until the EU Eco-label is better known or perceived in a better way. As such, problems exist regarding lack of visibility of the EU Eco-label on the market, few producers applying for the label, high administrative costs, and difficulties for various interest groups to agree on criteria for the products.
7. Market Instruments :
Euro Coop would welcome the introduction of environmental taxes as one way to achieve environmental objectives. In Euro Coop's opinion, environmental taxes are an effective instrument to promote more sustainable production and consumption patterns. However, other economic incentives should be promoted as well. This could be a price policy making ecological products more competitive on the market. Unfortunately, there is still not enough account of environmental aspects in the indication of prices: a product, which is not environmentally sound, should lead to a cost-internalisation, so that the final price includes the product's damaging impact on the environment. Such an incentive would provide true price transparency for the consumer when choosing between similar products. One cannot expect the consumers to change behaviour just by requesting their financial contribution to improve the environment. Full information and price transparency are crucial in changing the consumer's consumption pattern to a sustainable one.
8. Integration of Environmental Policy into other Policy Sectors :
Euro Coop believes that integration of environmental policy into other policy sectors is vital in order to solve the environmental problems. Each policy sector must have as a criterion the respect of the environment when carrying out its work. An integrated environmental policy approach should be based on the principle of sustainability from planning to carrying out activities in order to preserve the environment.
Finally, Euro Coop urges the European Commission to draft a programme where practical measures on how to solve environmental problems are proposed and not to consist of long theoretical discussions. Proposed practical measures are crucial in order for the new action programme to make a real contribution to a sustainable development.
III. Annex
The annex provides an overview of some of the actions taking over the years by some of Euro Coop's member organisations in the environment field.
Denmark
In Denmark, our member organisation, FDB, has had several information campaigns on various issues, such as: 1. The Nordic Swan Eco-label and the EU Eco-label in co-operation with the Danish Environment Agency. 2. How to do your laundry, cleaning and personal hygiene in an environmental acceptable way in co-operation with the Danish Society for Nature Conservation. 3. The consumers' choices to select products with less packaging in co-operation with the Danish Society for Nature Conservation and Green Youth. Furthermore, FDB has made an information package for pupils in primary and secondary school explaining environmental issues. Finally, FDB has provided information on environmental issues through information folders, on their homepage and through advertising.
Finland
In Finland, our two member organisations, SOK and TRADEKA, have provided information to consumers through its member magazines, through leaflets published by regional co-ops on environmental information, and through information available on blackboards in co-op shops regarding issues on eco-labels, organic food, recycling points etc. Furthermore, they are gradually changing their transport policy so that producers are delivering their products to the central warehouses. From there the products are collected in one load, which is then transported to the co-op concerned by appointment. Before, many producers delivered their products directly to each co-op shops. It meant that between 10 to 25 lorries could come to one single co-op shop per day. Now, the lorries and traffic have diminished significantly.
Italy
In Italy, our member organisation, ANCC, has promoted Coop brand fresh organic products, like fruit, vegetables and meat, in its range of commodities in its Coop shops. As well, ANCC has introduced a range of Coop brand products in its coop shops, which are using less packaging. Such as a reduction in packaging volume weight, using recycling material and elimination of superfluous packaging. Besides, ANCC is selling household film without PVC in their Co-op shops. Finally, ANCC has launched consumer information campaigns on reduction in the use of pesticides in agriculture, on packaging and packaging waste, and on genetically modified organisms.
Portugal
In Portugal, our member organisation, FENACOOP, has been contacting companies to try to make them act more environmentally responsible on for instance their use of water. As well, municipalities have been contacted to make them reduce their use of light systems on streets during daytime as the consumption level is huge.
Spain
In Spain, our member organisation, HISPACOOP, did a campaign on sustainable use of packaging together with ANCC and FENACOOP. The campaign was addressed to schoolchildren. The campaign consisted of an educational package on the issue containing a video, a booklet for the schoolteacher, work material for the pupils and a game. The campaign was partly financed by the European Commission's Directorate General for Health and Consumer Protection. Furthermore, HISPACOOP did a radio programme on sustainable consumption for half an hour per week, lasting 40 weeks. The programme addressed the problems connected to sustainable consumption, such as: laundry, vacations and car driving. In this context a "questions and answers" book was published based on the radio programmes. Once more, funding was received from the European Commission's Directorate General for Health and Consumer Protection.
Sweden
In Sweden, the member organisation, KF, has, among others, through articles, lectures and talks, television, radio and other forums increased public awareness of environmental labelling, organic food, better animal welfare in farming, the phasing out of PVC and the identification of genetically modified foodstuffs. KF has, like the Finnish organisations, changed their transport delivery system so that the total number of lorries to the co-op shops are now 1-2 per day compared to around 19 before. In association with a Swedish trade union, KF has launched study material, named "knowledge of the environment" to use, together with other education materials, to educate its personnel in order for them to be able to advise consumers properly in the co-op shops. Furthermore, a game for schoolchildren aged between 10 and 12 years old was introduced in the autumn 1999 with great success. Finally, KF has as a goal to increase the sale of green products in their co-op shops by 10% at the end of year 2000.
United Kingdom
In United Kingdom, our member organisation, CWS, is, together with three other UK retailers, working with the PVC industry to come up with an Eco-efficiency Code of Practice for the production of PVC. The Group is working under the auspices of the environmental NGO "Forum for the Future" and hopes to be able to publish the Code soon. Besides, CWS invested £1 million in purchasing balers for each of its Distribution Centres. This allows each co-op to send back waste cardboard from the co-op to the Distribution Centres, where the cardboard is baled and sent for recycling. So far, 20,000 tons of cardboard has been recycled per year. CWS' co-ops have started to recycle waste plastic, too, using the same method. In 1999, 500 tonnes of plastic was recycled.
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