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Bruxelles, le 14 décembre 2001
Euro Coop's Calls for a Sound Policy on Electrical and Electronic Equipment
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 4 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 Working Paper for a Directive on the Impact on the Environment of Electrical and Electronic Equipment (EEE) from February 2001, as it is important to get legislation in this area in order to protect the environment and promote a sustainable development.
However, Euro Coop would have wished to see the Working Paper being part of the proposed pair of two Directives on Waste Electrical and Electronic Equipment (COM (2000) 347), as called for in its Comments to the Commission's proposal, in order to have an overall and more ambitious approach.
Euro Coop believes that a link should also be made between the Working Paper and the European Commission's Green Paper on Integrated Product Policy (IPP). Since the two issues are very closely linked.
Furthermore, Euro Coop is disappointed to see that the Working Paper is not proposing any incentives to promote innovation. It is important to keep developing more sustainable products in order to protect the environment and human health. Therefore, financial support should be made available on national and EU level to independent research in order to promote "greener" electrical and electronic equipment.
As well, Euro Coop believes that more information is needed to the consumers besides through labelling of products in order for them to be better involved in the process. The information could be in form of brochures in shops, information campaigns and educational measures.
More specifically, Euro Coop finds it necessary to further develop the requirements as outlined under Annex II (Essential Requirements), point B). 3. As they are written now they are too vague in their requirements and leave it too much up to the manufacturers to decide what is the most appropriate design solution. Therefore, the requirements should become more specific and binding for the manufacturers. The improvements of these should be based on the 6th Environmental Action Programme and by defining what the most relevant environmental aspects of different groups of electronics are.
Last but not least, Euro Coop believes that the Committee on impact on the environment of electrical and electronic equipment (IMPEC), as outlined in Article 10, should not only consist of Member States' representatives but also by relevant stakeholders, such as, NGOs, consumer organisations, retailers and manufacturers, in order to better determine and to develop, among others, the essential requirements for design solutions. It seems only natural that stakeholders who are dealing with the issues on an every day basis contribute to the work of IMPEC with their expert knowledge.
In conclusion, Euro Coop believes that the Working Paper needs to be strengthened in the above-mentioned areas in order to develop a legislative framework protecting the environment and promoting sustainable development.
Contact : Louise Ousted Olsen, Acting Secretary General
Tel.: 02.285.00.76 - Fax: 02.231.07.57 - e-mail:Lousted_Olsen@eurocoop.org
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