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Bruxelles, le 6 juin 2001
Euro Coop's Comments to the Green Paper on Integrated Product Policy (COM (2001) 68)
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 Green Paper on Integrated Product Policy (COM (2001) 68). The Paper covers well the various aspects of the complex issue of an Integrated Product Policy (IPP).
However, Euro Coop urges the Commission to follow up the Green Paper with initiatives and legislative proposals in order to ensure that the IPP approach is properly implemented. Otherwise, the Green Paper ends up being a paper of good intentions but with no real value to the environment and to the society.
IPP is part of the proposed 6th Environmental Action Programme (EAP) and plays an important role in achieving the objectives of the 6th EAP for a more sustainable environment and development.
Euro Coop calls for the following to be included in an IPP:
- Introduction of a price policy making ecological products more competitive on the market.
- Providing the consumer with full information about products and a choice of products. Information about products could be given through labels on products, information on web-sites, educational measures, leaflets in shops etc. Euro Coop would like to see a strong support of the EU Eco-label as one way to submit environmental information in an easy manner.
- Member States should be obliged to do "green" public procurement being a role model for other stakeholders.
- Using practical and simple Life Cycle Analysis models to measure the environmental impact of products.
- Eco-design guidelines for products, which are profitable to use for companies in order for them to be effective.
- The body of standardisation must consist of all relevant stakeholders in order to reflect the various interests of society and to secure that the necessary environmental aspects are included in each product standard.
- Creation of stakeholder groups to work on how environmental goals can be achieved or obstacles overcome in relation to their particular product group. It is important that financial and secretarial support is provided to the groups by the Commission in order for them to work optimally. Euro Coop supports the idea of creating Product Panels as seen in Denmark.
- To support the IPP approach through research and development programmes, and through LIFE.
- To increase visibility and openness on producers' efforts to "green" their products through environmental management and audit systems, and financial reporting systems.
- Drafting of Guidelines on how to incorporate environmental costs and benefits into a company's annual account, based on the outcome of the Commission's study, in order to have a standard way of presenting environmental information in Annual/Financial Reports.
Turning to the questions raised in the Green Paper, Euro Coop has the following comments to make:
Question 1: "How can IPP contribute to getting "the prices right"":
As Euro Coop has already stated in its Proposals to the 6th Environmental Action Programme, getting "the prices right" is important in order to correct market failures. Accordingly, a price policy should be introduced making ecological products more competitive on the market. In that way, 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. Therefore, full information and price transparency are crucial in order to get "the prices right".
Question 2: "How can consumer demand be "greened" most effectively":
In order for the consumer to play an active role in "greening" its demand for products, 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. 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. Other possibilities are information through labelling. The information on a label must be understandable, relevant and credible. When it comes to the EU Eco-label Scheme, it should inform 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. As well, there should be fewer administrative costs in order to make the Scheme more attractive to producers. Concerning green claims, Euro Coop would welcome a Community approach. Euro Coop is of the opinion, as expressed in its comments to the Commission from 17 September 1999, that a separate legislation is needed in order to maintain consumer confidence in ecological products.
However, there is a limit to the amount of information that one can put on a label. Therefore, another possibility would be information through web-sites, educational measures, leaflets in shops etc. In general, the information to consumers about various products must be easy accessible.
Question 3: "How can "green" public procurement be promoted":
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 the Member States to live up to their policy of "greening" public procurement. Euro Coop welcomes the European Commission's stated intention to take the lead in greening it procurement activities and looks forward to reviewing any progress made.
Question 4: "How can more reliable information be generated on the environmental characteristics of products":
Euro Coop welcomes the use of Life Cycle Analysis in order to develop a model to measure the environmental impact of products. However, such a model should be practical and simple. A too ambitious model would be difficult to work with in practice.
Question 5: "How can environmental aspects become a key feature of product design":
Eco-design guidelines for companies' products are a good idea. However, in order for the guidelines to be effective, they must be profitable for companies to use.
Question 6: "How can IPP contribute to greening the standardisation process and to use the potential of New Approach legislation optimally":
Euro Coop believes that it is important to incorporate environmental aspects in the process of European product standardisation, e.g. when developing new and reviewing existing product standards. The standards are mostly there to aid the producers in developing their products. However, it is important that the body for standardisation consists of all relevant stakeholders in order to reflect the various interests of society and to secure that the necessary environmental aspects are included in each product standard.
Question 7: "How can the design process of products be influenced to better take into account environmental factors":
Euro Coop is positive towards the creation of stakeholder groups to work on how environmental goals can be achieved or obstacles overcome in relation to their particular product group. Such stakeholder groups or so-called product panels are having great success in Denmark. The product panels allow the various stakeholders to get together and discuss what should be the environmental criteria for a product as well as what problems need to be solved in order to fulfil the criteria, for a product that they are familiar with. However, it is important that financial and secretarial support is provided to the product panels by the Commission in order for the panels to work optimally.
Question 8 - 11: "How can environmental management and audit systems, the Community Research and Development Programmes, the LIFE programme, and the financial reporting systems contribute to IPP and to the "greening" of products":
Euro Coop believes that it is vital to support an IPP approach through research and development programmes as well as through LIFE. Furthermore, by using environmental management and audit systems and financial reporting systems, more visibility and openness are given on the producers' efforts to "green" their products. Therefore, Euro Coop welcomes the Commission's initiative to have a study undertaken to identify disclosures that allow for standardisation and comparability of environmental information being presented in corporate Annual/Financial Reports. Euro Coop hopes that the outcome of the study will be followed up by the drafting of Guidelines on how to incorporate environmental costs and benefits into a company's annual account. Since, currently, there is no standard way of presenting environmental information and no analytical standards for their interpretation. This weakens the impact of financial reporting.
Contact : Louise Ousted Olsen, Acting Secretary General
E-mail: Lousted_Olsen@eurocoop.org
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