WORLD TRADE  
ORGANIZATION  RESTRICTED 
WT/CTE/W/76 
G/TBT/W/60  
9 March 1998 
 (98-1038) 
Committee on Trade and Environment  
Committee on Technical Barriers to Trade Original:   Spanish 
 
 
 
ENVIRONMENTAL LABELS AND MARKET ACCESS: CASE STUDY 
ON THE COLOMBIAN FLOWER-GROWING INDUSTRY 
Document from Colombia 
1.  This document is being submitted to th e Committee on Trade and Environment (CTE) under 
Items 3(b) and 6 of its Work Programme and to the Committee on Technical Barriers to Trade, in the 
light of paragraphs 16 and 35 of the First Triennial Review of the Operation and Implementation of 
the Agreement on Technical Barriers to Trade (G/TBT/5). 
I. INTRODUCTION 2. In previous interventions before the CTE, Colombia has stated that some environmental 
measures adopted by particular developed countries,  such as eco-labelling or packaging regulations, 
have negatively affected its exports. 
3. At the CTE meeting in May 1997, referenc e was made to a study showing that some 
Colombian exporters, in particular, in the textile  and banana industries, were concerned over the 
indiscriminate use and the lack of transparency of  eco-labelling or packaging regulations, which in 
some cases could hamper access by their products to major markets. 
4. It was pointed out that compliance with the criteria laid down for e nvironmental labels in 
some countries was extremely costly and that t hose costs far exceeded the potential benefits of 
compliance with the set requirements.  The above-m entioned study further showed that, on occasion, 
some companies used eco-labelling for “protec tionist” purposes rather than to safeguard the 
environment. 
5. It was therefore pointed out that greater tran sparency was essential in working out the criteria 
for environmental labels.  It was even more importa nt for that transparency  to enable eco-labelling 
criteria to take account of the specific situations of exporting countries. 
6. In that connection and with regard to the futu re work of the CTE, Colombia stated that it was 
important for countries to implem ent paragraph 185 of the Report  of the Committee on Trade and 
Environment to the Ministers at Singapore. 
7. Further to our previous inte rventions, Colombia would now like to share the experiences of its 
flower-growing industry with regard to environmen tal labels and their effects on market access. WT/CTE/W/76 
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 II. ENVIRONMENTAL LABELS AND MARKET ACCESS: CASE STUDY ON THE 
COLOMBIAN FLOWER-GROWING INDUSTRY 
A. Introduction 
8. Although there is clear and resolute policy fo r eco-efficient flower cultivation in Colombia, 
the industry has experienced market access problems in  some countries owing to the proliferation of 
private environmental labels that are not cons istent with WTO disciplines on transparency and 
non-discrimination. 
9.  Following is a three-part presentation on this subject.  The first part explains the 
FLORVERDE programme, which was designed by Colo mbian floriculturists based on the principles 
of self-management and continual and gradual improvement.  The second discusses the industry’s 
experiences with voluntary eco-labels established by  some NGOs, while the third sets out the dangers 
identified by Colombian exporters as i nherent in private labelling schemes. 
B. The FLORVERDE Programme 
10. Environmental protection is a priority fo r floriculturists in Colombia.  This led 
ASOCOLFLORES - the association of Colombia’s principal flower exporters - to commit itself to 
carrying out major environmental protection activities. 
11. The first action undertaken by the associ ation was to review and document all the  
environmental initiatives that have been under way in the Colombian flower-growing industry for 
many years now.  It then made study of the va rious sectoral environmental management schemes 
existing both nationally and internationally.  The a ssociation then drafted a proposal tailored to suit 
the industry and which encouraged and motivated each flower grower to strive towards eco-efficiency 
and constant improvement.  Thus was born th e Environmental Self-Management Programme 
(Programa de Autogestión Ambiental)  for floriculturists in Colombia. 
12. This initiative takes the form of the FLO RVERDE programme, which aims to procure 
immediate benefits for the 76 participating companies and for the association as a whole.  
FLORVERDE is a systematic and comprehensiv e proposal for developing an environmental 
management style that will reorient attitudes towards cleaner production. 
13. The FLORVERDE programme is based on the principle of self-management and continual 
and gradual improvement.  It comprises five instruments: 
- A registration system; 
- case studies; 
- a Code of Good Practice ( Manual de Mejores Prácticas ); 
- An environmental management system; - regional committees. 
14. The first three instruments are intended for i mmediate implementation, while the last two are 
conceived for the medium to long term. 
Registration system 
15. The registration system entails the collection, processing, storage and the dissemination of 
environmental management indicators.  The areas for which indicators are determined and which are  WT/CTE/W/76 
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 subject to periodic monitoring are:  human resour ce management, soils, water, phytosanitary inputs, 
energy and wastes. 
16. The participating companies agree to be classi fied into category A, B or C, depending on the 
evaluation of their performance indicators.  The 20 per cent of companies with the best performance 
are given an A-rating.  The following 40 per cent a B-rating, and the remaining 40 per cent a C-rating. 
17. The level attained in category A during the fi rst evaluation becomes th e industry’s target for 
the following three years.  During that time, companies continue to submit and receive reports on  trends in their historical performance and how they st and in relation to the rest of the industry.  This 
enables them to strive for improved management  by gradually moving their indicators towards the 
desired goal. 
18. At the end of the three years, a new evaluati on of performance indicators will set a new level 
for category A (the best 20 per cent at that time).  This new level A becomes the new target for the 
next three years.  Thus, it is the industry that sets itself realistic goals and a gradual pace for sustained improvement. 
Case studies 
19. This covers the documentation of specific cases in which the company has successfully 
implemented desirable practices that have produ ced environmental and ec onomic benefits.  A case 
study is a powerful management tool in that it demonstrates that the concept of “eco-efficiency” can 
be realized.  The results of these studies boost th e confidence of flower growers in sharing and 
publicizing eco-efficient cases, which fosters and speeds up the process of widespread adoption of 
environmentally desirable and economically viable technologies (Van der Acker, 1996). 
Code of good practice and manual of procedures 
20. This is a document that can be updated and,  in addition to being a guide, lists generic 
environmental practices that are desirable and presently available.  
Environmental management systems 
21. At company level, the FLORVERDE programme supports the adoption of an ISO 14001-type 
environmental management system, with specific reference to the following elements: 
(a) Initial review or diagnosis; (b) elaboration of the plan of action and; (c) follow-up of the commitments undertaken therein. 
22. It is intended in each case to set up an e nvironmental committee within the company as part 
of its administrative structure, enabling it to  approach environmental matters preventively. 
23. When a company commits it self to environmental management, it examines its production 
processes and identifies obsolete practices and technologies that could be causing higher costs.  In setting the objective of cleaner production, that is, producing more using less resources (inputs, 
energy and water), the company is aiming simultaneously at environmental efficiencies and lower 
costs.  Thus, the concept  “eco- efficiency” whic h embodies a dual objective, becomes an excellent 
opportunity for promoting competitiveness within the flower-growing industry. WT/CTE/W/76 
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 FLORVERDE regional committees 
24. The regional committees were set up in an attempt to provide more regional fora for 
discussing environmental matters.  It  is thus hoped to encourage the sharing of experiences with a 
view to identifying the mo st eco-efficient solutions. 
C. Private eco-labels 
25. Despite the efforts described to improve e nvironmental protection, the Colombian flower-
growing sector has encountered restrictions on its exports by means of environmental measures.  
These restrictions to have not taken the form of la ws or labelling or packaging regulations, but have 
resulted from the proliferation of private environm ental labels being proposed by a variety of 
organizations. 
(a) The origin of the problem 26. Roughly since 1990, campaigns have been wa ged to discredit Colombian flowers on some 
international markets. FirstFood Information and Action Network (FIAN) an NGO founded in 
Germany, launched a “Flower Campaign” with the sole aim of  denouncing, inter alia , the 
environmental aspects of flower production in Colombia. 
27. The attacks against flowers from Colombia have not been based on serious, objective and 
representative studies from the industry.  Despite the good intentions of some of these pressure groups, the accusing studies and documents take isol ated and not necessarily verified cases as being 
representative of Colombia’s  flower-growing industry. 
(b) Eco-labelling by private organizations 
28. In 1995, at the height of these campaigns, the German importers association (BGI) proposed 
to ASOCOLFLORES the programme known as the “Colom bia Flower Declaration”.  The aim of this 
initiative was to produce a voluntary declarati on in which Colombian floriculturists would 
acknowledge compliance with environmental standards in force in Colombia and accordingly agree to 
submit to an environmental audit by a commission of  Colombian and German experts.  The BGI also 
sent a checklist of several requirements that w ould be verified by the monitoring committee. 
29. The proposal also envisaged that a committee of German experts would visit Colombia to 
verify compliance by each farm with the requirement s set out in the checklist.  The experts proposed 
were basically private consultants and persons lin ked to universities, but who had no form of 
accreditation as international certifiers or verifiers. 
30. Faced with the threat of exclusion from the European market and bearing in mind that they 
had no problems of compliance with labour and en vironmental or occupational health and safety 
standards in Colombia, the Colombian floriculturi sts were prepared to go along with the Colombia 
Flower Declaration and hence to submit to an  audit by private consultants from Germany. 
31. Nevertheless, ASOCOLFLOR ES decided not to subscribe to the proposed system of 
certification, owing to considerations such as the following: 
- The programme was very costly and any company agreeing to the scheme would 
have to pay an additional amount for the label, while there was no mechanism for 
recovering the investment should the consum er have to pay a surcharge on account of 
the certification.  The proceeds from a so -called green surcharge paid by the  WT/CTE/W/76 
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 consumer would go towards the operation of the labelling scheme in the importing 
country; 
- the approach used was coercive, as a nyone who did not accept the labelling scheme 
was subjected to negative pressure from the Flower Campaign.  In other words, the 
proposal was not consistent with the lead ing world-wide environmental management 
initiatives for the private sector, such as t hose within UNEP, the proposals of the 
Rio Summit for businessmen who would make up the World Business Council for Sustainable Development, or with current  international environmental legislation 
which envisages voluntary and therefore real commitment by the production sector; 
- the scheme proposed by the German importers was discriminatory, as it had not been 
proposed to any other country exporting flowers to Germany, but was aimed solely at Colombia. 
32. Furthermore, the Government of Colombia disapproved of the scheme on the ground that it 
amounted to an eco-labelling programme in which co mpliance was subject to verification by foreign 
experts.  It was inadmissible for a foreign committ ee to be responsible for verifying compliance with 
Colombian environmental regulations, as that task  fell within the exclusive competence of the 
National Government. 
33. In the wake of this refusal, the activities of  the Flower Campaign have multiplied, as have the 
certification initiatives. 
34. Indeed, proposals have been received of mo re than three different types of private 
environmental labels: 
(i) A new proposal from Germany called th e “Flower Label Programme” (FLP), which 
is the being offered only to flower exporte rs from Colombia and Ecuador, and not to 
other flower-producing countries.  Again, the programme involves a checklist and an audit committee comprised of German experts. 
The checklist proposed under the programme  seems arbitrary, as it is not clear 
regarding the terms of compliance with so me of its demands, for example, in the 
following cases: 
- The proposed programme states that “only ac tive pesticide ingredients registered in 
countries with stringent registration laws  may be used.  Registration procedures in 
force in the country where the company is located will be given due consideration at 
the time of evaluation”.  What is meant by stringent registration laws? How objective 
is that criterion? 
- It further states that “products with toxicological classification (1a) Extremely Toxic 
and (1b) Highly Toxic, according to the WHO toxicological classification, should only be used in duly justified cases of extreme necessity”.  What is meant by extreme 
necessity? How is it defined?  That woul d surely depend on each cultivation and its 
specific circumstances. 
- “Only biodegradable products may be used for post-harvest treatments”.  No 
alternative biodegradable products for this type of treatment are as yet commercially 
available to producers who need to expo rt their products over great distances. WT/CTE/W/76 
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 What is more, the programme seems very co stly to exporters and does not guarantee the 
gradual process of continual improvement which is being incorporated into the FLORVERDE 
environmental management programme.  It woul d cost a minimum of US$2,500 per year to 
defray the expenses arising from the verification visit, plus a price of US$1 per label sold, 
which must be affixed to each box of exported flowers.  In other words, if 20,000 boxes of 
flowers are sold per year, that would imply US$20,000 in addition to the US$2,500 in verification expenses. 
The programme’s advocates also said that this extra cost would be met from the premium  to 
be paid by the consumer, though they have no way of guaranteeing that all retailers in 
Germany will buy FLP flowers exclusively: 
(ii) FIAN, the NGO that launched the Flower  Campaign, has been working on the design 
of its own environmental label for flower s from Colombia, in cooperation with the 
Colombian NGO Fundación Cactus . 
(iii) The Max Haveelar Foundation in Switzerla nd is designing its own generic label, and 
even though it has not been specifically o ffered to Colombian flower exporters, there 
is no doubt that the hope is for it to beco me the label allowing flowers to be sold on 
the Swiss market. 
35. The experiences described with the BGI’s Colu mbia Flower Declaration and with the private 
labels proposed to Colombian floriculturists dem onstrate the serious threats facing the industry.  
There is the risk that private organizations with no qualification as internati onal certifiers and without 
being subject to any kind of international standa rds, will be in a position to issue environmental 
product labels. 
D. Inherent Dangers of Pr ivate Eco-Labelling Schemes 
36. Private environmental labels can significantly  affect trade flows in that they inform 
consumers about flowers in a potentially discrimin atory manner, depending on whether or not the 
flowers display the label. 
37. The proliferation of private labels sold by private organizations based on divergent and 
dissimilar criteria would lead to significant trade diversion by favouring demand for flowers 
displaying those labels, without adequately informing the consumer as to the nature of the labels, the 
way they are supervized or even how they actually come about.  This could lead to market disruption 
which would then be very difficult to correct. 
38. In the case of the Colombian flower industry, for example, a look at its export volumes for the 
period 1992-1996 shows that while global flower e xports showed an upward trend, exports to 
Germany declined markedly.  One of  the possible causes of this is the proliferation of unjustified 
environmental labels and campaigns in respect of Colombian flowers.  WT/CTE/W/76 
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 Percentage Change in Volume of Flower Exports from Colombia 
 
 1992-1993 1993-1994 1994-1995 1995-1996 
Global 6.32% 4.15% 0.53% 1.47% 
To Germany -14.93% -4.85% -4.15% -21.80% 
Flower Exports from Colombia to Germany 1992-1996 
Volume 
Graph - Offset 
 
 
    
 
 39. To sum up, the Colombian flower-exporting i ndustry has identified the following as the most 
risky aspects of private eco-labelling: 
- The lack of supervision or complian ce with internationally accepted standards 
guaranteeing transparency, impartiality and objectiveness in the demands made and 
the absence of monitoring to allow for self-corr ection.  This situation entails a serious 
risk for the bodies managing these labels in th at they could fall prey to interests that 
have nothing to do with the actual envi ronmental conditions of cultivation. 
- The absence of any common minimum parameters, which means that the consumer 
does not receive comparable and intelligible information.  Each label may be 
designed based on different criteria, or may assign greater specific weight to some 
criteria over others, depending on the orientati on of its promoters.  Furthermore, there 
is the risk that no account is taken of differences in production processes from one region to the next. 
  - The impossibility of complying simultaneously with the different requirements and 
checklists issued by each organization for each country. WT/CTE/W/76 
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 III. CONCLUSIONS 
40. The case study of the Colombian flower-gro wing industry reveals the dangers inherent in 
private environmental labelling schemes and their potential negative implications for market access. 
41. Colombia therefore considers it important  for the CTE and the Committee on Technical 
Barriers to Trade to have a clear position aimed at  ensuring that the proliferation of private 
environmental labels without common standards or  monitoring of any kind do not create trade and 
markets distortions and thereby confuse consumers. 
42.   It is essential to have a transparent,  concerted and non-discriminatory policy on voluntary 
eco-labelling, which makes allowance for the ci rcumstances of exporting and importing countries so 
that environmental and trade policies may really co mplement each other and satisfy both business and 
environmental interests. 
43. Hence, it is necessary to guarantee transparen cy in the conception and application of eco-
labels, to ensure that they are non-discriminatory and that the parties concerned can participate in 
developing them, designing the programmes, choosing their product coverage, selecting the criteria on 
which they are based and in wo rking out any audit procedures. 
44. Therefore, Colombia once again underscor es the importance of implementing paragraph 185 
of the Report of the Committee on Trade and Environm ent to the Ministers at Singapore, which reads: 
 “185.  As stated above, the CTE’s discussi on on eco-labelling has focused primarily on 
voluntary eco-labelling schemes/programmes and in particular on the transparency of such 
schemes/programmes. Without prejudice to the views of WTO Members concerning the 
coverage and application of the TBT Agreemen t to certain aspects of such voluntary eco-
labelling schemes/programmes and criteria, i.e.  those aspects concerning non-product-related 
PPMs, and therefore to the obligations of Members under this Agreement regarding those 
aspects, the CTE stresses the importance of WTO Members following the provisions of the 
TBT Agreement and its Code of Good Practice, including those on transparency. In this 
context, the CTE underlines the particular importance of ensuring fair access of foreign 
producers to eco-labelling schemes/programmes.” 
45. For Colombia, it is of capital importance for the Code of Good Practice for the Preparation, 
Adoption and Application of Standards of the Agreem ent on Technical Barriers to Trade to be applied 
to voluntary eco-labels.  This Code is open fo r acceptance by governmental and non-governmental 
bodies and is an important instrument for monitoring the adoption of labelling standards applicable to 
a product. 
46. It is clear that if a private, recognized institution approves a document containing rules, 
guidelines or specifications on products or the re lated production processes a nd methods,  intended for 
generalized and repeated albeit optional use, it is subject to the provisions of the Code. 
47. Thus, by observing the principles of the Code  of Good Practice, private organizations would 
ensure that products originating in the territo ry of any WTO Member receive treatment no less 
favourable than that accorded to similar products of national origin or originating in any other 
country.  In that way they would effectively prev ent the elaboration, adoption or application of 
standards having the objective or effect of cr eating unnecessary barriers to international trade.  WT/CTE/W/76 
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 48. In the light of the foregoing, Colombia reite rates the importance of applying Article 4 of the 
TBT Agreement which states that Members shall ta ke such reasonable measures as may be available 
to them to ensure that non-governmental sta ndardizing bodies within their territories accept and 
comply with the Code of Good Practice. 
49.  Finally, another aspect of interest to Colo mbia is for the WTO to study and develop the areas 
of mutual recognition and equivalence with respect  to eco-labelling, for the application of these 
concepts could solve some of the problems raised  in this document with regard to such schemes. 
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