Brussels, 05 february 2007

Euro Coop welcomes the revision of the EU eco-label undertaken by the European Commission. Our organization wishes that during this procedure, leading to the adoption of a new regulation, stakeholder opinions are taken into due account. The voice of consumers, which are the ones that have the last word on the success of the scheme, is very important. Euro Coop therefore responds positively to the newly launched public consultation.

The EU eco-label, the Flower, is potentially a useful policy tool for the achievement of a sustainable development but it must be improved. In fact, it has not been as successful as it should have been. This is the reason why the shortcomings that have delayed its expansion have to be overcome through the experience gained during the last years.

Aim and Vision

Euro Coop agrees on the objective set up by the Commission stating that the Community Eco-label award scheme has to promote products which have the potential to reduce negative environmental impacts, as compared with other products in the same product group, thus contributing to the efficient use of resources and a high level of environmental protection.

Management of the scheme

One of the main problems encountered for the development of the Flower has been its rigid institutional framework, which has contributed to some kind of paralysis. Euro Coop therefore supports the Commission proposal to change the institutional body of the eco-label scheme, dividing the management into three different institutions.

We support the proposal placing the day-to-day management of the scheme under the responsibility of an Executive Agency or a Bureau made up by specialists, who will be able to quickly react to technical issues. It is vital though, that the proposed body responsible for the criteria-setting, the Eco-label board, takes into account the voice of all relevant stakeholders; environmental representation, retailers, manufactures and consumers, as they are the ones who finally decide the success of the scheme.

Lastly Euro Coop would like the overall responsibility for the eco-label scheme to remain to the Commission.

Ambition level, product groups and criteria definition

Regarding the debate on how to set the ambition level for the Flower, Euro Coop stresses that it is important to have ambitious goals. Ambitious goals regarding both the number of product groups included in the scheme, and the criteria settings. Ambitious criteria setting has to ensure that, as a maximum the best third of the companies from each product group, can achieve the EU eco-label.

It is equally important that the EU eco-label is further developed to encompass additional product groups and that the development of those product groups is based on market analysis. Market analysis will ensure the relevance of a new product group, in terms of potential purchasers and therefore motivate manufactures to get their products eco-labeled.

It is also important to Euro Coop that the application structure for the eco-label is simplified and that a great deal of flexibility is incorporated in the criteria setting. Euro Coop supports the Commission suggestion to set up a checklist and template structure for the application and criteria documents. In this way all criteria relevant for similar product groups would simply refer to the same core criteria. This would ensure full consistency of such criteria and allow them to be easily viewed and updated. The Commission suggestion to make the expected development in the criteria setting transparent for the industry is also supported by Euro Coop.

In addition to that, Euro Coop thinks flexibility is the key word in relation to the harmonization of the Flower with other existing national and regional eco-labels. Euro Coop suggests that the Flower constitutes a minimum baseline for the existing national and regional eco-labels and supports the possibility that, for product groups not covered by the EU eco-label, national labelling schemes are 'accredited' to offer the EU eco-label. We support a high degree of flexibility consisting of several fast track options, to avoid process duplication on work already undertaken by manufactures, retailers and national eco- label bodies.

Fees and Green Public Procurement

In relation to the proposed revision of the fee structure, Euro Coop stresses that it is of great importance that the fee structure is arranged in a way that is motivating rather than seen as a barrier from the producers applying for the scheme. It is important that companies can see a market advantage in eco-labeling and Euro Coop sees the fee structure as a tool to achieve these goals. We therefore support the proposal of one fixed annual fee per eco-label license unrelated to the volume of sales of any product (with the possibility of a minor fee for SMEs).

We see the role of Green Public Procurement as essential for the widespreading of the eco-label and as a consequence the revision has to take Public Purchasers into account in both the overall revision of the scheme and in the development of new criteria and product groups.

Marketing

It is important for Euro Coop that the specific marketing of the eco-label is national, to have it adjusted to the campaigns of each market. That being stated, we still support the Commission suggestion to have a common marketing expertise, which will be responsible for raising funds, coordinate and share experience across borders and developing common action plans in line with those known from the Organic farming scheme.

FOR FURTHER INFORMATION, PLEASE CONTACT:
EUROCOOP SECRETARIAT
Tel.: +32. (0)2.285.00.70 Fax: +32. (0)2.231.07.57
E-mail: infoateurocoop.coop.