Brussels, 1 April 2004

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 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 Communication (COM (2003) 302) on Integrated Product Policy (IPP). It outlines well the tools and measures needed to integrate environmental aspects into the production process. EURO COOP believes that the IPP strategy should be an integral part of the EU Sustainable Development Strategy.

EURO COOP agrees with the five key principles of the IPP approach: Life-Cycle thinking, working with the market, stakeholder involvement, continuous improvement and a variety of policy instruments.

EURO COOP welcomes the proposal on voluntary pilot projects and the general IPP toolbox to:

• Create the right economic and legal framework through the use of environmental taxes, voluntary agreements, greener standards and such like;
• Promote life-cycle thinking by improving the availability of life-cycle information tools, considering obligations for producers on the design of products and implementing the product dimension on environmental management schemes;
• Give consumers the information to decide: this includes encouraging greener public procurement, encouraging green corporate purchasing and gradually expanding the existing EU labelling initiatives, such as the EU Eco-label.

However, EURO COOP is disappointed to see that the proposal has been watered down considerably compared to the Green Paper on IPP. EURO COOP would have liked to have seen the different tools, and how they could be used and interact, better outlined in the Communication. In addition to an evaluation process over time of the IPP method and how it is going to develop in the long term in respect of phasing out hazardous substances and non-sustainable production methods. Furthermore, EURO COOP would like to see the precautionary principle introduced in the proposal in order to address the question when scientific uncertainty arises about a substance or a product.

EURO COOP is concerned that real actions on an integrated product policy are not taken until 2007. In our view, products already exist, e.g. eco-labelled products, where action could be taken right away, in terms of life-cycle thinking, working with the market, stakeholder involvement, continuous improvement and a variety of policy instruments.

More specifically, EURO COOP has the following comments to make:

Environmental Taxes:

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 more emphasis put on the use and benefits of environmental taxes as well as concrete proposed actions in the Commission Proposal. 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 future1. 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.

EURO COOP also strongly supports the Commission suggestion to create a list of criteria to record environmentally negative subsidies with the view of eliminating those.

Consumer Information:

EURO COOP is happy to see that the importance of consumer information is stressed in the Communication. It is necessary that the consumer has full information about the product and its impacts on the environment as well as a choice of products in order for the consumer to play an active role in "greening" its demand for products. EURO COOP agrees that the three policy instruments mentioned, greening public procurement, greener corporate purchasing, and environmental labelling, are important to raise consumer awareness. However, other information tools are needed such as, information via web-sites, educational measures, leaflets in shops etc. Furthermore, another tool to provide consumers with the necessary information would be to enhance the dialogue between consumers, environmentalists and enterprises in order for consumers to be able to make more sustainable choices.

Public Procurement:

EURO COOP welcomes the Commission suggestion to encourage Member States to draw up publicly available action plans for greening their public procurement. As well as, the Commission's own intention to draw up an action programme by the end of 2006 for its own procurement. EURO COOP believes that Member States should be obliged to do "green" public procurement as they are a role model for other stakeholders. Currently, it is the policy in many Member States to "green" public procurement but it is rarely followed up by concrete actions. Therefore, public procurements actions should be officially published and made available to all interested parties in order to encourage Member States to live up to their policy of "greening" public procurement.