EN    EN EN 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 16.7.2008 
SEC(2008) 2118  
  
COMMISSION STAFF WORKING DOCUMENT 
accompanying the 
 
Proposal for a  
 
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
 
on a Community Ecolabel scheme 
  
IMPACT ASSESSMENT  
 
{COM(2008) 401 final} 
{SEC(2008) 2119} 
EN 2   EN TABLE  OF CONTENTS 
 Page
Executive summary  2 Section 1: Procedural issues and cons ultation of interested parties  4
Section 2: Policy Background 8Section 3: Problem definition  11Section 4: Objectives  18Section 5: Policy options  20Section 6: Analysis of impacts  27Section 7: Comparison of options  43Section 8: Administrative costs  44Section 9: Monitoring and Evaluation 47Section 10: Conclusion 48 Annex - List of current product groups 50
 
EN 3   EN EXECUTIVE SUMMARY  
According to Article 20 of  the Ecolabel Regulation1, the EU Ecolabel scheme, which has been 
in place since 1992, has to be reviewed an d the Commission must then propose any 
appropriate amendments to the Regulation. 
The overall objectives of the scheme are to  encourage the sustai nable production and 
consumption of products, and th e sustainable provisi on and use of services, by setting 
benchmarks for good environmental performance. By guiding consumers towards them, the 
Ecolabel should promote those products and se rvices that have me t these benchmarks 
compared to others in the same category. The Ecolabel scheme also needs to be usable as an 
integral and effective part of the wider Sustainable Consumption and Production policy 
framework of the European Commission, linking we ll with other instruments, such as Green 
Public Procurement (GPP), the Eco-Management  and Audit Scheme (EMAS), the Eco-design 
directive and the Enviro nmental Technologies Action Plan (ETAP), etc. 
The Ecolabel review and impact assessment process began in February 2002, with the launch 
of a large-scale evaluation study on Ecolabel2 In addition to the review, a number of 
stakeholder consultations have taken place, culmin ating in a public intern et consultation at the 
beginning of 2006, the results of wh ich indicated strongly the n eed for significant changes to 
be made to the Ecolabel Regulation. The impact  assessment shows that the current scheme is 
unable to achieve its objectives as it suffers fr om low awareness of the label and low uptake 
by industry resulting amongst others from excessively bureaucratic processes and 
management.  
Three main or macro-options are considered in  this impact assessment: continuing with the 
present approach; phasing out the scheme; or ma king modifications to the scheme. Within the 
last option a number of micro- options are analysed and then considered as a package of 
measures representing the best modifications of  the scheme. Following the analysis of impacts 
this last option has been chosen. The following p ackage of measures is therefore proposed for 
the modification and simplification of the scheme: 
• Design Regulation to better fit into the ot her sustainable production and consumption 
actions of the Commission; 
• Open up the scope of the label; 
• Introduce measures to encourage harmonisatio n with other eco-labelling schemes: EU 
Ecolabel criteria as a standard  for other eco-labels; fast track  procedure to adopt criteria 
developed by national ecolabel schemes; 
• More product groups / quic ker criteria development; 
• Introduce a template for criteria documents to ensure they are more user friendly; 
• Incorporate guidance for Green Public Pu rchasing into criteria development; 
• Simplification of the assessment and verifica tion procedures and abolition of the annual 
fee; 
• Peer review for Competent Bodies; 
                                                 
1 Regulation (EC) No 1980/2000 of the European Parliament and of the Council of 17 July 2000 on a 
revised Community eco-label award scheme  
(http://ec.europa.eu/environment/ecolabel/pdf/regulation/001980_en.pdf ) 
2 http://ec.europa.eu/environment/ecolabel/revision_en.htm  
EN 4   EN • Boost marketing. 
It can be expected that this modification and si mplification of the scheme will lead, on the one 
hand to a considerable increase in companies using the label, therefore also to an increase in Ecolabelled products on the mark et and, on the other hand, to an increase in th e number of 
consumers that know about, and ar e prepared to buy, Ecolabelled products as well as to an 
increase in the use of EU Ecolabel criteria in public procurement. The Ecolabel will be better 
tailored to policy makers, particularly within  the framework of the Sustainable Consumption 
and Production Action Plan, and w ill be a useful benchmark and information tool on the 
environmental performance of products and services. 
The economic and environmental impacts of the scheme will depend on the Ecolabel's 
success and this will in turn depend, amongst ot her factors, on how we ll it co-ordinates with 
other policy instruments aiming at promoting innovation in the life-cycle environmental 
performance of products. Forthcoming Commi ssion actions on Sustaina ble Consumption and 
Production will examine ways to use a range of product policy instruments in a coherent and co-ordinated way to maximise their effect as a whole in driving both innovation and sales of 
better performing products. As the Ecolabel would be  a part of such a package of instruments, 
its impact will need to be judge d as part of that package. 
This impact assessment concludes that, as a voluntary instrument, a m odified Ecolabel can 
have net economic benefits for the EU economy, and increase both competition and competitiveness. The Ecolabel therefore works with the market and – with its simplified 
approach – is a model "better regulation" policy instrument.  
EN 5   EN SECTION 1: PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES  
1.1. Organisation and Timing 
Work Programme reference : 2007/ENV/011 
General chronology of the Impact Assessment:  
The impact assessment process began in February 2002, when the Ecolabel Policy 
Management Group first met and was given the task to "continue to develop and adapt the 
long-term policy and strategy of the scheme, as we ll as the integration of the Ecolabel in the 
various policies being developed in relation to sustainable consumption" . A sub-task of this 
multi-stakeholder group, set up by the European  Union Ecolabelling Board according to their 
roles defined by Commission Decision 200/730/EC3, was to prepare for the revision of the 
scheme. The official evaluation study (named th e 'EVER' study – see below) was launched in 
2005. This study was accompanied by a Commi ssion inter-service group that met on two 
occasions. 
Task Deadline Status 
External evaluation Dec 04 - Dec 05 Completed 
Selected stakeholder consulta tion Jan 06 – Dec 06 Completed 
Draft main direction revisi on May 06 – June 06 Completed 
Internal agreement main direc tion June 06 – Nov 06 Completed 
Draft text Regulation Nov 06 – Aug 07 Completed 
Impact assessment 
(incl. stakeholde rs consultation) Dec 06 - Apr 07 Completed 
Internal agreement draft text  May 07 - July 07 Completed 
Revise draft text I 
Stage delayed due to integration into 
SCP Action Plan Aug 07 - Feb 08 Completed 
Inter-service consultation Mar 08 - Apr 08 Underway 
Revise draft text II Apr 08 – May 08 To be completed 
Commission adoption new Regulation June 08 To be completed 
EP – Council co-decision Sep 2008 - End 2009  To be completed 
Adoption new Legislation Beg 2009 – End 2010 To be completed 
                                                 
3 Commission Decision of 10 November 2000 establishing the European Union Ecolabelling Board and 
its rules of procedure (OJ L 293 p24-30) 
EN 6   EN  
1.2. Consultation and expertise 
External expertise used : 
External expertise was used to conduct th e evaluation study of the existing EMAS and 
Ecolabel Regulations. A large- scale evaluation study on the EMAS  and Ecolabel instruments 
was carried out by a consortium of consultants led by Bocconi University, known as the 
‘EVER’ study.4 This study included, as well as a ma jor literature review, two stakeholder 
workshops and in depth interviews with particip ants and non-participan ts in the schemes as 
well as other interested parties. The Policy Management Group also provided input and was 
made up of representatives of Member St ates, consumer and environmental NGOs and 
industry. This group met on twelve occasions a nd produced four reports on the future of the 
Ecolabel scheme. A second important source wa s the study carried out for the Commission by 
AEA Technology "The Direct and Indirect Benefits of the European Ecolabel"5. 
In addition this impact assessment makes us e of the findings of the Working Group on 
Product Information Needs6 (one of the EU Integrated  Product Policy working groups 
consisting of experts from government, industry and NGOs). 
Stakeholder consultation : 
Significant consultation has taken place with  members of the multi stakeholder EU 
Ecolabelling Board (EUEB) based on inform al discussion documents prepared by DG 
Environment (including six days  of documented workshops spread  over the last two years at 
EUEB meetings in Brussels and EUEB Presidential meetings in the Member States). These 
discussions have generated deta iled written responses from key stakeholders (i.e. from 
Member States, environmental, consumer and i ndustry representatives) that have guided the 
Commission in the early stages of developing options for the revision of the scheme. The 
above mentioned evaluation study (EVER) is partly  built on detailed interviews with different 
stakeholders. 
Finally, as part of the Impact Assessment,  a public stakeholder consultation using the 
integrated policy making (IPM) internet cons ultation tool was organised in January and 
February 2007. This on-line questionnaire enabled all types of stakehol ders to input their 
opinion on options proposed for the Ecolabel re vision. The results of the 185 responses have 
been analysed and a report has been prepared in line with Commission guidelines.7 These 
results support the main directions of the re vision options proposed, although in general they 
would favour a more radical change to the r unning of the Ecolabel (away from Commission 
Decision) and more radical rules on the influence of the criteria, such as them being used for 
reduced taxation or as the mini mum standards for green claims. 
Commission's minimum standards : 
The Commission’s minimum standards on consultation have been met.8 The time allowed for 
stakeholders to reply to the internet stakeh older consultation was more than 8 weeks, the 
minimum standard for the Commission. Additionally, as outlined above, extensive 
                                                 
4 http://ec.europa.eu/environment/ecolabel/revision_en.htm  
5 http://ec.europa.eu/environmen t/ecolabel/pdf/market_study/b enefitsfinalreport_1104.pdf  
6 http://ec.europa.eu/environment/ipp/pdf/20070115_report.pdf  
7 http://ec.europa.eu/environment/ecolabel/pdf/revision/revision_report2007.pdf  
8 COM (2002) 704 final, Communication from the Commission: Towards a reinforced culture of consultation and 
dialogue - General principles and mini mum standards for consultation of in terested parties by the Commission  
EN 7   EN stakeholder consultation has been on-going with a ll types of stakeholder and interested parties 
beginning in 2005 and continuing du ring the course of 2006 and 2007. 
Main results of the consultation: 
The main conclusion from the consultation exercise is that, while the Ecolabel scheme has 
significant potential, a number of changes would be necessa ry for a more successful 
implementation: 
• There is a strong need to integrate different  instruments for environmental product policy. 
The EU Ecolabel scheme therefore has to be revi sed in such a way as to best fit within the 
mix of other environmental and sustainabl e product policy instruments. The Ecolabel 
cannot be a stand-alone instru ment, but part of a well orga nised Sustainable Consumption 
and Production policy9, where outputs such as Ecolabel criteria, Green Public Procurement 
criteria, ETAP performance targets and Eco-desi gn criteria etc. are linked closely together. 
• The management of the scheme needs to be  improved. In other words, who does what 
needs to be more clearly defined and the bur eaucratic processes imbedded in the scheme 
need to be rationalised, allowing it to be run in a more business-like way. 
• The bureaucracy linked to criteria developm ent for product groups and to application 
procedures needs to be reduced whilst at the same time keeping the ambition level high. 
• Criteria documents have to be  much more user friendly with a standardised format. 
• The assessment and verification procedures for the scheme have to be simplified to 
improve access to the scheme and to align it with other Commi ssion product labelling 
schemes. 
• The number of product groups as well as of licence holders has to  be substantially 
increased, targeting those areas of highest environmental imp act and where the possibility 
of improvement is highest.  
• A more successful Ecolabel wi ll, above all, depend on a subs tantially increased marketing 
budget. 
• There is a clear need to better co-operate a nd co-ordinate with established national and 
regional ecolabel schemes. 
1.3. Impact Assessment Board 
A previous version of this IA  was sent to the Commission's Impact Assessment Board which 
delivered its opinion on 30 May 2007. This has le d to a number of changes to the text 
including the following: 
• Extending Section 3: Problem Definition, especi ally with regard to the justification for 
having a third-party-verified  ecolabel at EU level. 
• Re-arrangements of the micro-optio ns in Section 5: Policy Options. 
                                                 
9 The June 2006 European Council conclusions9 on the EU SDS established SCP as a new key priority 
policy area for action alongside climate change, clean energy, sustainable transport, natural resources 
and public health. It called for the Commission to put forward an Action Plan by 2007 to  "help to 
identify and overcome barriers for SCP, ensure better coherence between the different related policy 
areas, and raise awareness among citizens and change unsustainable consumption habits".  
EN 8   EN • Deepening the analysis of imp acts in Section 6, amongst othe rs concerning Ecolabel as a 
driver for innovation, social impacts and macr o-options 1 and 2 (business as usual and 
phasing out the scheme). 
• Adding more substance to th e description of administra tive costs in Section 8. 
EN 9   EN SECTION 2: POLICY BACKGROUND  
To understand the possible need for a revision of  the Ecolabel Regulation we first need to 
develop an understanding of how  the current scheme works. The following gives an overview 
of the structure, procedures and bodies of th e EU Ecolabel under th e current Regulation: 
European Union Ecolabel scheme – an overview 
THE MAIN ELEMENTS OF THE SCHEME 
Being a voluntary, market-based in strument, the primary function of the EU Ecolabel is to 
stimulate both the supply and demand of product s that have a lower environmental impact 
compared to others in the same category. On  the demand side, the scheme gives European 
consumers the means to make informed envi ronmental choices when purchasing products. 
With respect to supply, the EU Eco-label has the clear objective of encouraging businesses to 
market greener, officially licensed, products. The "Flower" is the a ssurance that a product 
which is marketed as "green", really belongs  to the high end of the environmental market. 
The Europe-wide coverage of the scheme me ans that companies do not have to make 
applications in every country where they wish to market their products, and thus avoids time-
consuming and costly procedures. The same logo  is used regardless of the product group in 
question, thereby reducing consumer confusion due  to the numerous self claims and green 
logos in existence. 
The label is awarded only to those products a nd services that meet the selective criteria 
developed and decided in a transparent process with representatives from industry, commerce, 
environmental and consumer organisations. Ec olabel criteria are based on studies which 
analyse the impact of the product or service on the environment througho ut its environmental 
life-cycle, starting from raw material extraction in the pr e-production stage, through 
production, distributi on and disposal. 
It is for the producer, retailer or service provid er to decide whether or not to apply, once the 
criteria are published in the Official Journal. The voluntary nature of the scheme means that it 
does not create barriers to trade. Foreign and Community producers may apply for the logo if 
they meet the criteria and want to market their products in the EU/EEA. 
THE ACTORS 
The Commission 
The Commission is responsible for the overall ma nagement and coordination of the scheme. It 
has the power of "proposal" on every legal do cument for the implementation of the scheme 
(criteria documents, fee struct ure, rules of procedures of the different groups, standard 
contract are all published as Commi ssion Decisions in the Official Journal), as is the case with 
all legal acts coming from the EU. These proposal s, agreed via inter-se rvice consultation, are 
then submitted to a "Regulatory Committee", i.e.  a vote by Member States. Together with the 
Member States the Commission is responsible fo r marketing the Ecolabel. It gives financial 
support to NGOs to ensure a balanced stakeholder participation. 
EN 10   EN Competent Bodies 
The Ecolabel Regulation require s each Member State to designate a Competent Body (CB) 
which is responsible for implementing the Ecolab el scheme at MS level. The CBs have to 
contribute to criteria development, they have to  consult stakeholders at  MS level, market the 
scheme (shared responsibility with the Commis sion), receive applications from companies 
and they award the label after verification as to whether all the criteria have been met. 
The Consultative Forum 
The Consultative Forum is the stakeholder foru m and is composed of representatives from 
industry, trade unions, SMEs and co nsumer and environmental NGOs. 
The EU Ecolabelling Board (EUEB) 
Composed of representatives of the CBs and the members of the Consultative Forum, the 
EUEB meets 3 to 5 times a year and discusses draft criteria documents as well as any other 
issue relevant for the implementation of the scheme. The EUEB has several sub-groups: the 
so-called Management Groups (currently for Ma rketing and Co-operation and Co-ordination) 
and the ad-hoc working groups which discuss draf t criteria for product groups at expert level. 
The Commission acts as the Secretariat for the EUEB. 
The Competent Body Forum 
In this forum, CBs discuss implementation issues related to the criteria documents in order to 
ensure a harmonised approach across the EU. 
The Regulatory Committee  
Representing the MS governments, this Committ ee votes on draft criteria documents tabled 
by the Commission (after they have been prep ared and discussed by ad-hoc working groups 
and the EUEB). The voting rights are the same as in Council, and a qualified majority is 
needed. 
THE PROCEDURES 
Award criteria development 
The initiative for selecting a product group10 is taken either by the Commission or by the 
EUEB. Once a product group is se lected for the development of  new criteria, the Commission 
gives a mandate (Commission Decision) to the EUEB to proceed with  the work. After the 
completion of official tender pr ocedures, one of the Competent Bodies is awarded a contract 
to take the lead for this product group. 
The EUEB procedures foresee a certain amount of preparatory work led by this lead 
Competent Body to determine whether the produc t group falls within the scope of the scheme, 
notably representing a significant volume of sa les, involving a significant environmental 
impact and equivalent potential for impr ovement and a significant sales volume. 
A feasibility and market study is  carried out to collate data  on the following aspects: the 
market structure and the various types of produc t groups on the EU market , the opinions of all 
interested parties, the key environmental imp acts and key elements relating to the product's 
fitness for use, an inventory of eco-labels, standards, test  methods and studies. Consumer 
perception, functional differences between types of products and the need  for identifying sub-
groups will be assessed. Generally the interests of the main parties and SMEs concerned and 
                                                 
10 The Ecolabel regulation defines a product group as "any goods or services which serve similar purposes 
and are equivalent in terms of use and consumer perception." 
EN 11   EN the overall impact are key elements for the sel ection of a product group and the development 
of the scheme. 
An ad-hoc working group is organised by th e lead Competent Body. Composed of experts 
from the Member States and representatives of all interested parties concerned, the group 
evaluates the preparatory phase and discusses po ssible criteria. On the basis of these results 
and consultations (usually 3 or 4 meetings  per product group), the lead Competent Body 
drafts a criteria document which is then presen ted to and discussed by the EUEB (usually also 
3 to 4 times). Once the draft criteria are suffi ciently negotiated in the EUEB, the document 
goes into an inter-service c onsultation process within the Commission where all relevant 
Commission services either give  their agreement or require ch anges to the presented draft. 
After a consensus has been reached within the Commission, the draft document goes to a 
Regulatory Committee (Member States delegates)  where it needs to achieve a qualified 
majority for adoption (Comitology). 
After a positive vote, the document is translated into all the official EU  languages before it is 
published in the Official Journa l as a Commission Decision. This  whole process can take up 
to four years and sometimes criteria may be outdated by the time they enter into force. Even 
small changes that may turn out to be necessary as  a result of the first ap plications (see below) 
for these new product groups can take up to two years before entering into force. 
Applications and award of the label 
Companies which want to use the Ecolabel have  to apply to the Comp etent Body in the MS 
where the product is manufactured  (if it is manufactured in several MS the company can 
choose one of these MS's Competent Bodies to apply). For imported pro ducts, the application 
has to be filed with one of the CBs where the product is imported. Afte r a positive verification 
of the application, the CB concludes a contract with the company which entitles the applicant 
the use the Ecolabel for marketing purposes fo r the remaining period of validity of the 
ecological criteria. The Compet ent Body charges a harmonised f ee for the application and the 
annual use of the Flower logo. 
The award of the Ecolabel means that successful  applicants are permitted to use the official 
Flower logo on their approved product in a market of almost 500 million consumers. Thus a 
consumer in a supermarket who is faced with a line of different brands  of laundry detergents 
for instance, will be able to pick out, by check ing the Ecolabel logo, the ones which achieve a 
high standard of environmental performan ce compared with the rest of the field. 
Following the request in the Ecol abel Regulation to review the scheme after a certain time, 
the Commission launched an evaluation study which, in short, showed that  after 15 years of 
existence the EU Ecolabel has not reached its potential. 
EN 12   EN SECTION 3: PROBLEM DEFINITION  
In the context of the revision of the EU Ecolab el we have to start our analysis with two 
fundamental questions: 
1. Why an EU Ecolabel? 
2. Why is there a need for revi sing the Ecolabel Regulation? 
1. Why an EU Ecolabel? 
As highlighted in different reports published by the Europ ean Environment Agency and 
others, the state of the environment gives raise to increasing concerns. Global warming is just 
one – and currently the most prominent – key word in this context but many others would 
need to be mentioned as well – such as bi o-diversity, air and water pollution or ozone 
depletion. 
There is a clear need to re duce the negative impacts of pr oduction and consumption patterns 
on the environment, health and natural resour ces. Currently, the Commission is preparing a 
Green Paper on an Action Plan on Sustainabl e Consumption and Production (SCP) which will 
constitute the framework for an integrated im plementation of a mix of instruments aiming at 
reducing exactly this negative impact of modern life on the environment, health and natural 
resources. 
A multi-criteria, third party verified Ecolabel  based on life-cycle thinking could constitute a 
very important element of such a mix of SCP policy instruments and the importance of such 
an Ecolabel scheme has already been emphasised in earlier policy documents such as the 
Commission's Communication on Integrated Product Policy11 and the 6th Environmental 
Action Programme12 Eco-labelling also has some unique  benefits over other possible policy 
instruments such as taxes and direct regulati on – for example the direct empowerment of 
consumers themselves to drive environmental change. In this way, ec o-labels can provide 
information to consumers about what the key en vironmental issues are in relation to a product 
and what the differences between products are.  Additionally, other instruments may make use 
of the EU Ecolabel scheme in the future in terms of criteria development and stakeholder 
involvement. Examples might be lower taxes for Ecolabel products or direct regulation 
concerning non-Ecolabel products. 
Within a single market a single set of guidelin es benchmarking the environmental credibility 
of products is the logical way forward, as opposed to having different benchmarks in each 
Member State. An EU-wide scheme makes it easier for businesses wishing to market more 
"environmentally friendly" products within th e EU and it means consumers can purchase so-
called "greener" products wherever they are, sa fe in the knowledge th at these products share 
common environmental credentials. The EU Ecolab el is the only such label for the entire 
internal market - existing national or regi onal eco-label schemes c over it only in part. 
If consumers, as well as private and public purc hasers are to take environmental criteria into 
consideration when they choose their products and se rvices in the market, it is important that 
they can find easily understandable and credible  guidance to enable them to distinguish the 
truly "green" products from their competitors. Ec o-labels can play a very important role in 
any package of measures aiming at promoti ng development and sales of greener products; 
                                                 
11 (IPP) (COM (2003) 302 final) 
12 (Decision No 1600/2002/EC) 
EN 13   EN they set a clear benchmark for the market and, for example, eco-label criteria can also be 
included in calls for tender in green public procurement. 
The EU Ecolabel also provides a useful benchmark of envir onmental performance in other 
ways: 
• The EVER study confirms that the EU Ecolabel  criteria are used ev en by non-participating 
companies, with more than half of such comp anies interviewed declaring that they use the 
Ecolabel to benchmark their environmental pe rformance, even when they do not apply for 
the label. 
• Under the Eco-design Direc tive for energy-using products13, any product which has been 
awarded the Ecolabel is automatically cons idered as compliant with the implementing 
measures. 
• EU Ecolabel criteria have also been used in  some cases by other eco-label schemes like the 
Austrian Ecolabel or the Nordic Swan. Both ha ve chosen to directly adopt the EU criteria 
word-for-word for some of  their own product groups. 
As a voluntary instrument, an eco-label can have net economic  benefits for the EU economy, 
potentially increasing both competition and competitiveness. The Ecolabel will reward 
innovation with increased profits, providing mark et incentives for grea ter innovation in the 
EU economy. 
The obligatory life-cycle approach ensures the consideration of relevant impacts across the 
different environmental problems and from cradle  to grave therefore avoiding the mere shift 
of burdens. 
2. Why is there a need to revis e the Ecolabel Regulation? 
The main problems identified with the current scheme are: 
Low awareness  
The EVER study mentions low awareness as the mo st significant barrier in using the Ecolabel 
for marketing purposes. According to a recent Eurobarometer Survey14, 48% of Europeans do 
not know what the logo means wh ile only 11% correctly said that  it is a labe l for ecological 
products and services. In comparison, 80% of Germans know the Blue Angel and 67% of 
people in the Nordic count ries understand the Swan.15 The Eurobarometer also finds that, 
apart from being widely unknown, the logo is al so confusing to consumers. Many respondents 
think either it stands for organic f ood or just for high energy efficiency. 
                                                 
13 See http://ec.europa.eu/enterprise/eco_design/dir2005-32.htm  
14 http://ec.europa.eu/environment/ecolabel/pdf/studies/eurobarometer_survey.pdf  
15 Source: http://www.svanen.nu  
EN 14   EN Low uptake by industry  
Over the 15 years of its exis tence the EU Ecolabel has attr acted some 470 companies (many 
of which are SMEs). Beginning of 2007, the Blue Angel had 560 companies16 and the Nordic 
Swan 680 (These being the biggest two national ecolabelling schemes). 
While those using the scheme point out the positive environmental benefits they have 
brought, and while the scheme continues to grow steadily with around € 800 million of sales of eco-labelled products, it still commands a very  small EU market share in relative terms. 
What are the underlying drivers of these problems? 
a) Regulation too restrictive 
A general lack of flexibility of the scheme due to the restrictive way in which the Regulation 
is written is also seen as a problem. Th e EU Ecolabel is unable to respond to new 
environmental challenges for this reason. Some examples of this are: 
– It is difficult to develop Ecolabel criteria alongside cr iteria for other Commission 
instruments – both existing, eg. Eco-desi gn of Energy using Products Directive, 
ETAP Performance Targets or future e g. possible proposals coming from the SCP 
Action Plan 
– All food products and medical devices are cu rrently excluded from the scope of the 
EU Ecolabel. However, food production has been highlighted as having one of the 
greatest environmental impacts17 in terms of production and consumption. A number 
of new schemes are being developed in th e EU looking at the "carbon footprint" of 
food products, but the current EU Ecolabel is  unable to offer its expertise in this 
field. 
– Calls for an EU Ecolabel for sustainable fisheries are also impossible to respond to 
by the scheme. 
b) Insufficient co-operation and harmonisati on with other ecolabel schemes at national 
and regional level 
This issue has been discussed at length during the last revision of the Ecolabel Regulation and 
subsequently in the EUEB and its Co-operati on and Co-ordination Management Group. It has 
always been seen by all as being of crucial importance to give the Ecolabel real "added 
value", however up to now only occasional measures have been implemented on a voluntary cooperation basis. In a few cases other scheme s have adopted EU criteria documents which 
gives companies the opportunity to get both la bels through one application and also save 
money on fees, but most of the time criteria de velopment in the different schemes is quite 
independent of what happening at EU level. This makes it necessary for companies willing to market their products with an eco -label to adjust to  different requirement s and to apply for 
different labels separately (given the still low level of awareness of the EU label, companies 
still have an interest in also  using the well-known labels in so me countries – see above "level 
of awareness"). 
c) The Ecolabel faces strong co mpetition from green self-claims 
                                                
 
16 Source: www.blauer-engel.de  
17 See EIPRO study, Environmental Impacts of Produ cts – Analysis of the life cycle environmental 
impacts related to the final consumption of the EU-25  
(http://www.jrc.es/publications/pub.cfm?id=1429 ) 
EN 15   EN The consumer is confronted with numerous green claims on products  without knowing on 
what criteria development process these claims  are based. The number of these self-claims by 
industry suggests that the current legal fram ework seems inadequate and the consumer is 
often left in confusion or uncertainty. 
d) Insufficient stakeholder involvement  in product group criteria development 
The evaluation study on the Ecolabel highlighted the fact that many stakeholders, such as 
industry, do not feel fully invol ved in the scheme because, while  they can contribute to the 
working groups on the developm ent of the criteria documents , their comments are often not 
responded to. 
e) Procedural and organisational pr oblems – i.e. excessive bureaucracy 
The evaluation study highlights the complexity of the Ecolabel structures and procedures as a 
barrier for the development of the scheme. With in the current organisational framework of the 
EU Ecolabel it is possible to develop one  or possibly two new product groups a year. 
However, as the total number of product groups increases there are an increasing number of 
product group criteria that need  to be revised leading to a subsequent reduction in the 
resources available for the development of ne w products groups. Simple revisions of criteria 
take years to complete and th e final decision-making process on criteria is l ong and political. 
For fast-changing products such as  electronic devices it is cruc ial to have a framework which 
allows a frequent and quick up -date otherwise criteria would, in  a short space of time, be 
unable to keep up with market developments. 
f) Low number of product group categories At the beginning of 2007, 23 product groups were in force
18. A rather modest number 
compared to 80 in the German Blue Angel system and the 60 in the Nordic Swan. 
g) Problems in using the Ecolabel in green public purchasing activity 
Currently, there are two problems:  Firstly, criteria documents are not easily usable for public 
procurement purposes because they are often lo ng and complicated which makes it difficult to 
extract the relevant parts for calls for tender. Secondly, the procurement directives do not 
allow those involved in the proc ess to directly ask for Ecolab elled products but only to use 
Ecolabel criteria for the technical specifications. 
h) Fees and cost of getting the label The annual fee is currently a % of sales of the Ecolabelled product, this can scare off potential 
applicants, because the more they sell the higher  the fee will be. This seems to go against the 
idea of the polluter pays principle, with thos e companies making the effort to produce more 
environmentally sound products, paying for the label.  It also requires a bureaucratic process at 
the end of each year. On top of the fees, co mpanies have to bear costs for testing and 
verification which, for some produc t groups, can be considerable – in certain cases more than 
€10,000. The criteria themselves are often co mplex and difficult to work though, so the 
application process can take some time. 
i) Lack of funding for marketing and running the scheme The EU Ecolabel budget for marketing in the whol e of the EU directly from the Commission 
is around €460K per year with  5 dedicated staff helping to  run the scheme. (with around 
€150K per annum on product group development and revision) Member States spending on 
marketing of the Ecolabel varies year on y ear around an average figure of approximately 
                                                
 
18 See list of product groups in Annex. 
EN 16   EN €1.5m. Within the Member States there is a total of 36 staff, with an annual running cost of 
about €2.3m. Income from fees was around €260K  in 2004. This is clea rly insufficient to 
make a brand – and from a marketing perspectiv e the Ecolabel can be seen as a brand – well 
known in the market. 
As a comparison, the Nordic Swan's current annual budget in Norway, Sweden, Denmark and 
Finland is about €7.5m and the scheme is run by around 70 employees. Additionally they have a budget of €3m for marke ting, information and sales in 4 countries comprising about 25 
million people altogether. 
According to the EVER study "95% of the compan ies participating in the EU scheme use the 
Ecolabel in their marketing campaigns (TV and press advertising, promotion initiatives on the 
point-of-sale, etc.)". However, as  long as the total number of companies is low, the impact of 
their individual marketing activities is limited. Th ere is a clear need for money for an initial 
period to boost knowledge of the label to a point where compan ies can clearly see benefits 
from using it. 
j) Lack of transparency with regards to  implementation of the regulation in MS 
Competent Bodies are responsible for the assessme nt and verification of the applications they 
get from companies wanting to use the label. Currently, there is no systematic information on the consistency in which the Regulation is app lied by the different Comp etent Bodies. Usually 
three times a year there is a CB meeting in orde r to discuss issues of implementation, but only 
a limited number of CBs participate in these mee tings and, in general, it is unclear if the 
Regulation is implemented in a consis tent and harmonised way across the EU. 
k) The harmful environmental impacts over the life-cycle some products can be much 
greater than other products on the market whic h serve the same function, yet there are often 
no reasons for manufacturers to improve the en vironmental performance of their products. 
As the market price does not reflect the envi ronmental damage caused during the life-cycle, 
more harmful products compete at an advant age against similar products with improved 
environmental performance – with two potential results: a) there is 'unfair' price competition 
to the disadvantage of products which are more expensive because they have improved 
environmental performance, which limits the commercial rewards for manufacturers who 
improve their product's performance – and th is acts as a break to innovation; and b) 
consumers unknowingly purchase products whose a dditional environmental harm to society 
outweighs the cost savings to the consumer. 
Manufacturers of products with worse life-cycle impacts have few or no reasons to try to 
improve those products performance, which th erefore may slow improvements in the product 
group as a whole. This is likely to limit the e ffectiveness of Ecolabel as an instrument 
promoting gradual improvement of product environmental performance. 
The EuP Directive is de signed to tackle these problems, but has a scope limited to products 
which use energy. The possibility of introduc ing implementing measures for removing the 
worst performing products from the market in  terms of their environmental performance 
could also be desirable and th e Ecolabel scheme could act as  a benchmarking tool for any 
such policy. Any of the current ra nge of Ecolabel product groups could be used as an example 
such as using the Ecolabel criteria to reco mmend standards on the environmental impact of 
cleaning products on the market, helping to reduce the levels of toxic compounds found in 
such products. 
EN 17   EN Who is affected, in what ways, and to what extent?  
The Ecolabel has failed to provide the intended se rvice to a number of stakeholders who could 
have benefited from using it: 
• Consumers who would like to have clear  guidance on which products are more 
environmentally friendly hardly find the EU Ec olabel on products. In many countries, they 
will also not find any other third-party label available. 
• Companies wanting to use the Ecolabel as a benchmark fo r product development can only 
do so for a limited number of product groups. 
• Those companies wanting to use the label as a credible marketing tool for promoting their 
green products are restricted to the same small number of  product groups and have little 
added value from the label due to the fact  that it is only known to about 10 % of the 
European population. 
• Public purchasers are also affected. They are l ooking for simple criteria which they can put 
into their calls for tender, but either the Ec olabel criteria do not exist or they are over-
complicated. Instead there are very different ru les and guidelines, in different stages of 
development in different Member States. 
• Policy makers, wishing to find understandab le life-cycle inform ation on products and 
looking to find out what the key environmenta l impacts are for linking to other policies 
(for example for setting mandatory minimu m criteria under the Energy-Using Products 
directive) often have to start from the begi nning because they cannot use the Ecolabel as a 
source of such information. 
How would the problem evolve, all things being equal? 
Basically, the above mentioned problems would pe rsist and be aggravated. There would be no 
coherent EU-wide policy setting environmenta l benchmarks for products. The different 
Member States would continue to develop thei r own very different labelling and green public 
procurement systems and this would mean add itional confusion for consumers and additional 
bureaucracy for companies. In the end it would lead to less pr ogress in terms of sustainable 
production and consumption that would, in tur n, mean less economic growth. See also, Policy 
Option: "Leave the scheme as it is". 
Does the EU have the right to act - Trea ty base, "necessity test" (subsidiarity) and 
fundamental rights limits? 
Yes. Most of the issues describe d in this section are fundamental  problems that lie within the 
Ecolabel Regulation itself. To tackle these problems requires ch anges to the Regulation that 
cannot be dealt with by Member States themse lves. Indeed, the right to act is already 
mentioned in Article 20 of the current Regulation, where it states: " the Commission shall 
review the Scheme in light of the exper ience gained during it operation…and propose any 
appropriate amendments to this Regulation" . 
EN 18   EN SECTION 4: OBJECTIVES  
The overall objectives of the revision of the scheme are: 
1. To encourage the sustainable producti on and consumption of products, and the 
sustainable provision and use of services, by settin g benchmarks for good 
environmental performance. By guiding consumers towards them, the Ecolabel should promote those products and servi ces that have met these benchmarks 
compared to others in the same category. 
2. The revised Ecolabel scheme needs to be de signed in a way to ensure that is usable 
as an integral and effective part of  the wider Sustainable Consumption and 
Production policy framework of the Eur opean Commission. The new Regulation 
needs flexibility to link easily with othe r instruments, such as GPP, EMAS, Eco-
design, ETAP, etc. 
3. A much more influential Ecolabel in terms of supporting other SCP policies and 
setting benchmarks for good environmenta l performance for policy makers, for 
companies or for educating the public. 
Operational objectives are: 
• High awareness, understanding and respect in the EU-27 and around the world. The 
medium-term benchmark for success should be  that the Ecolabel is recognised by 
consumers and by companies throughout the EU at  a similar level to the recognition of the 
Blue Angel or Nordic Swan in th eir respective count ries of operation. 
Indicators: % of population t hat know the Ecolabel and its meaning within ten years  
% of companies that know the Ecolabel within ten years 
• Building up trust in the label and maintaining its credibility is also vital. The label must be 
a highly respected benchmark of  environmental performance. 
Indicator: Level of credibility when co mpared with other environmental labels 
• Criteria are needed for all products and servi ces where the Ecolabel can provide benefits, 
especially product groups with a substantial environmental imp act and therefore with high 
potential for improvement. 
Indicators: Number of product groups; number of companies per product group; number of 
items sold per product group; sales volume per product group. 
• Many more Ecolabel products on the sh elves for consumers to choose from; 
Indicator: Ecolabel sales as a percentage of total retail sales in this product group. 
• Criteria documents which can eas ily be used by public purc hasers and policy makers. 
Indicator: Use and uptake of Ecolabel criteria by public purchasers monitored by questioning 
Member States, also hits on GPP webs ite and on Ecolabel criteria documents. 
Indicator: Number of policies that can be attributed to having used the Ecolabel product 
information work. 
• An Ecolabel very well harmonised with other labels, globally and nationally. 
Indicator: Frequency of nati onal labelling schemes directly  taking on the Ecolabel criteria. 
EN 19   EN • An Ecolabel that can be attained by compan ies with limited costs and efforts for them 
while still maintaining a high ambition in orde r to ensure credibility of the label with 
consumers and environmental groups. 
Indicator: Number of licences Consistency of objectives with other EU policies 
The Commission's Communication on Integrated Product Policy
19 analysed the need for a 
product dimension to environmen tal policy and acknowledges the ro le the EU Ecol abel has to 
play in a mix of product related instruments. 
One of the overall object ives of the Sustainable Development Strategy (SDS)20 is the 
promotion of sustainable consumption and prod uction patterns. Being an important tool for 
improving the environmental performance for products and processes and for encouraging 
their uptake by business and consumers, a we ll-designed Ecolabel scheme is directly 
contributing to this SDS objective. The aim of better serving the needs of green public 
procurement (GPP) will also contribute to reaching the relevant SDS objective. 
The Ecolabel provides a mean s by which market forces can reward products and services 
which meet consumer demand in less environm entally damaging ways. This will typically be 
through innovation either in pr oduct design or in the produc tion process. The Ecolabel 
therefore promotes and supports innovation, whilst  at the same time increasing the efficiency 
of resource use in the economy, both of whic h are key goals of the "Lisbon" Strategy for 
Growth and Jobs. The majority of firms taki ng up ecolabels are typically SMEs, which shows 
the potential of the Ecolabel to support SME development pr ovided that the issues of 
implementation of the scheme by SMEs are addr essed. Thus a strong a nd efficient Ecolabel 
would boost EU industrial policy.  
Furthermore, the life-cycle approach followed fo r the development of Ec olabel award criteria 
ensures that due account is taken of the impact of certain a product or service on themes which are high up on the political agenda, such as  climate. At the same time, this approach 
avoids that concentration on just one enviro nmental theme leads to solutions which would 
have a high impact on other environmental themes. 
The objective of better integrating the Ecol abel with other environmental product policy 
instruments also contributes to "better regulation". 
                                                
 
19 (IPP) (COM (2003) 302 final) 
20 SDS reference to be included 
EN 20   EN SECTION 5: POLICY OPTIONS  
Possible options for meeting the obj ectives and tackling the problem. 
(Note: The following options have been broken down to two levels: macro-options, such as 
keeping, dropping or modifying the Ecolabel sche me are presented, and then micro-options, 
where considerations of individual areas of change to the current sc heme are presented. 
These micro-options are relevant if the macr o-option of "modifying the current scheme"  is 
chosen – in this case some the micro-options may be accepted or rejected to make up a 
package of measures for the modification of the scheme. 
Macro-option 1 – Continue with the present approach = Business as usual 
Changes required: 
None – the current Regulation would remain in force and work would continue as now. 
Macro-option 2 – Phase-out the scheme 
Changes required: 
– Stop Commission funding for developmen t of new product groups and marketing.  
– Let the current criteria documents expire.  
– Slow down and eventually st op having Ecolabel meetings.  
– Stop taking on new Ecolabel customers.  
– Finally, withdraw the Regulation. 
Macro-option 3 – Modify the scheme 
Changes required: 
A number of micro-opti ons are available for modifying the scheme in different areas of its 
operation. Modifications range fr om the administrative to th e political, looking at how the 
scheme is run and how decisions are made, as well as considering modifying how the 
Ecolabel criteria are used in relation to othe r ecolabelling schemes and in relation to other 
environmental tools. These micro-options are de rived from a wide cons ultation exercise with 
all stakeholders, from the evaluation study (EVE R), and from the attempt to respond to the 
problems with the current Ecolab el scheme. The impacts of these micro-options need to be 
considered both individually and in synergy with  each other. If macro-option 3 is chosen, then 
the best package  of measures suitable for achieving the objectives of the Ecolabel would need 
to be selected. 
The following table gives an overview of the re lationships between the micro-options and the 
problems presented in section 3. (For the sake of simplicity, only the main links are 
highlighted even if some micro-options are link ed to various problems. In order to further 
readability, at each heading of the detailed description of the mirco-options there is a 
reference to the problems presented in section 3.) 
EN 21   EN  
Micro-options Problems 
Introduce fiscal incentives for the
Ecolabelled products and services. Especially low uptake by industry but also 
problems in using Ecolabel in green public purchasing activity. 
Open up the scope of the labe l. Regulation too restrictive 
Introduce measures to encourage 
harmonisation with other eco-labelling schemes. Insufficient co-operation and harmonisation 
with other eco-label schemes at national and regional level. 
Introduce a new standard for making green claims in Europe. Insufficient co-operation and harmonisation 
with other eco-label schemes at national and regional level. 
The Ecolabel faces strong competition from 
green self-claims. 
More direct stakeholder involvement. In sufficient stakeholder involvement in 
decision making on product group criteria. 
More product groups; quicker criteria development; better decision making procedures; better criteria documents. Insufficient stakeholder involvement in 
decision making on product group criteria; procedural and organisational problems – i.e. excessive bureaucracy; low number of product group categories. 
Incorporate guidance for green public purchasing into criteria development. Problems in using Ecolabel in green public 
purchasing activity. 
Change of rules for public procurement to favour products or serv ices meeting Ecolabel 
criteria. Problems in using Ecolabel in green public 
purchasing activity. 
Simplification of the fee structure. Fees and cost of getting the label. 
Abolish third-party verification. Pro cedural and organisational problems. 
Accredit bodies outside the EU to deal with 
Ecolabel applications. Procedural and orga nisational problems. 
Boost marketing. Lack of funding for marketing. 
Peer reviews for Competent Bodies. Lack  of transparency with regards to 
implementation of the Regulation in MS. 
Provision of information by the EUEB on appropriate future minimum environmental standards for products Often no reasons for manufacturers to 
improve the environmental performance of their products 
EN 22   EN  
Micro-options: 
micro-option i. Introduce fiscal incentives for the Ecolabelled products and services: 
(See Section 3.2 –"main problems identified with the current  scheme") 
This option would see a system put in place to  allow the possibility for Value Added Tax 
breaks to be introduced at the EU  level for products bearing the Ecolabel, or that meet some 
or all of the criteria. These savings could boost the profits of participating companies either 
through increased sales of lower priced goods or  by allowing them to add a premium to the 
price of the product without this being reflected  "on the shelves" when compared with other 
products. 
micro-option ii. 
Open up the scope of the label 
(See Section 3.2.a) All food products and medical devices are curr ently excluded from the scope of the EU 
Ecolabel. This option will remove the restrictio ns on scope within the Ecolabel allowing for 
any product which can meet the aims of the la bel to have the potential to be labelled.  
micro-option iii. 
Introduce measures to encourage harmonis ation with other eco-labelling schemes 
(See Section 3.2.b) There are a number of other ISO type I (third-p arty-verified) labelling schemes in different 
Member States running schemes similar to the EU Ecolabel, but criteria and their development, application procedures and fees  are not harmonised. This option sees various 
possible sub-measures: 
a) EU Ecolabel criteria as a standard for other ecolabels: 
Specified Ecolabel criteria, agreed by Commi ssion Decision, will have to be adopted by other 
schemes within a certain time if those schemes wish to cover the product group in question 
combined with a rule th at if a national scheme wishes to develop a new product group that is 
already covered by the Ecolabel, they mu st take on the Ecolabel criteria. 
b) Accreditation of national/regional IS O type 1 schemes to use the Flower: 
By Commission Decision, other European ISO t ype 1 eco-label schemes can be "accredited", 
if that scheme can demonstrate fully its ability to meet the aims of the Ecolabel scheme. An 
accredited scheme then has the right to offer, to companies under its scheme, the use of the EU Flower logo, for any of its product groups no t covered by the EU scheme at the time. For 
example, if the Nordic Swan scheme were to be accredited, then any companies currently 
bearing the Swan logo for any product group not covered by the EU Ecolabel, could use the Ecolabel Flower logo for their marketing. 
c) Eventually ban national labels from operating when Ecolabel criteria exist 
At a fixed time after the adoption of Ecolabel criteria national la bels would have to withdraw 
their product groups altogether, al lowing the EU Ecolabel to be the only label available for 
the product groups it covers. 
d) Fast track procedure to a dopt criteria developed by nati onal/regional ISO type schemes 
EN 23   EN In order to increase the number  of product groups for the EU Ecolabel, a shortened criteria 
development process for criteria that have al ready been developed by another ISO type 1 
labelling scheme can be established. 
micro-option iv. 
Introduce a new standard for making green claims in Europe 
(See Section 3.2.b+c) Companies wishing to write "bio " or "organic" on food in the EU  must meet EU standards to 
do so. No such standard exists for green clai ms like "environmentally friendly" and "eco". 
The new Ecolabel Regulation will use selected "c ore" Ecolabel criteria as a basis for setting 
minimum standards for general environmental claims on products. Commission Decision will 
determine the most relevant criteria per product group, that will then have to be met in order 
for a product to be allowed to make green claims  about itself. Member States will be required 
to ensure, through market survei llance, that companies making general green claims are in 
line with these criteria, in the same way that they must prevent the use of any other false 
claims on products. 
micro-option v. 
More direct stakeho lders involvement 
(See Section 3.2.d) This option will see the final decision making on  criteria pass from Regulatory Committee to 
a stakeholder body comprising balanced composition ensuring all the interests are represented 
in an appropriate way. 
micro-option vi. 
More product groups / quicker criteria development / better decision making procedures / 
better criteria documents 
(See Section 3.2.d+e+f) This option will introduce the possibility for criteria development
 to be managed by any 
interested stakeholder, (eg. industry or NGO as well as Member States) under specified 
conditions ensuring full open consultation and appropriate life-cycle considerations. The 
option will allow for the adoption of criteria from  other schemes, if they  can be shown to have 
been well developed. 
Specific guidelines for criteria development w ill be included in the Ecolabel Regulation. 
These guidelines are a practical manual setting out each procedural step required to develop 
criteria (e.g. who is to be consulted and when, how the different actors and bodies have to be 
informed and when), as well as the contents of the background report and the final criteria document. Any new product group criteria submitted to the stakeholder body for a vote is, therefore, accompanied by a standardised repo rt showing how each of the steps had been 
completed, answering specific questions and i ndicating how the criteria were derived. 
Sections shall include: 
– Reasoning for choice of product group / scope of product group
21, 
– Standardised market analysis;  
                                                 
21 The Commissions Integrated Product Policy work on "Identifying products with the greatest potential 
for environmental improvement" can give guidance for the selection product groups: 
http://ec.europa.eu/environment/ipp/identifying.htm  
EN 24   EN – Consideration of any possible trade issues; 
– Analysis of criteria of other labels; 
– Setting of ambition levels; 
– Life-cycle considerations (i ncluding results of consulta tion with EU Platform of 
Life- Cycle information); 
– First draft criteria – reasoning/justification for each criteria; 
– Expected environmental/economic /social impacts per criteria; 
– Assessment and verification specifications; 
– Estimated costs of tests; 
– Table: who was consulted, what they sai d, why their input was accepted / rejected; 
– Final criteria; 
– User manual. 
This option will also introduce a standard templa te for criteria documents. The template will 
ensure that the presentation of Ecolabel criter ia is standardised across product groups and that 
criteria are broken down into cl ear impact categories that are easy to understand for the first 
time reader. 
micro-option vii. 
Incorporate guidance for Green Public Pu rchasing into criteria development 
(See Section 3.2.g) The new Regulation will include new guidelines ensuring criteria documents contain specific 
simple "cut and paste" guidan ce and advice for public procurem ent officers and that key "best 
GPP criteria" are highlighted in  Ecolabel criteria documents. 
micro-option viii. 
Change of rules for public procurement to favour products or services meeting Ecolabel 
criteria 
(See Section 3.2.g) 
This option sees the introduction of new EU-wide rules within the Ecolabel Regulation that 
state that when public procurement tenders ar e made, those responding who meet Ecolabel 
criteria should be favoured, a ll other factors being equal. 
micro-option ix. 
Simplification of the fee structure 
(See Section 3.2.h) The fee for using the Ecolabel is currently a pe rcentage of sales of th e eco-labelled product. 
Two sub-options are considered: a) A simplification of the fee structure.  Under this option, only one fixed annual fee 
would be required per Ecolab el licence, unlike the curren t system where the fee is 
linked to the volume of sales of the eco-la belled product. Three fees would exist: one 
considerably reduced fee for micro enterprises, one reduced fee for SMEs and one for all other companies. 
EN 25   EN b) No annual fees are charged at all . Companies will be able to use the Ecolabel for 
free, apart from the need for a small, limited application fee. 
micro-option x. 
Abolish third-party verification 
(See Section 3.2.e) This option would be a move towa rds self-declarations for the EU  Ecolabel. Once criteria are 
set, any company that meets thos e criteria will be able to use the logo with no application 
process required. The Competent Bodies in Member States woul d then carry out  spot checks 
on products and companies to ensure th at the rules are being adhered to. 
micro-option xi. 
Accredit bodies outside the EU to  deal with Ecolabel applications 
(See Section 3.2.e) Companies from outside the EU can already a pply for the label, but must do so via a EU 
Member State and the process is expensive an d long. This option would allow, under strict 
conditions, for governmental bodies outside the EU to  be authorised to de al with applications 
for the Ecolabel. 
micro-option xii. 
Boost Marketing 
(See Section 3.2.i) This option would see a big marketing push for the EU Ecolabel in the short-term to increase 
public and industry awareness of the scheme to levels comparab le with the most successful 
national schemes. The marketing push would be tim ed in line with the revision of the scheme 
if other micro-options are chosen. The initial financial input would be in the order of €5 
million per year for five years for professional promoting of the Ecolabel brand. During this 
time periodic assessment of the knowledge of th e label would be made . At the end of the 
period a re-assessment of the need for direct ma rketing input would be made. This marketing 
push will be combined with the development of the new or modi fied logo, designed to be self-
explanatory and to thus avoid confusion with other schemes. 
micro-option xiii. 
Peer review for Member States 
(See Section 3.2.j) In order to make the way the scheme is implemen ted in Member States more transparent, they 
should carry out mutual peer review visits and produce follow-up reports and 
recommendations for any changes that could he lp with the harmonised implementation of the 
scheme. This system would be comparable to  the current peer revi ew amongst accreditation 
bodies under the EMAS Regulation.  Representatives from two or  three Member States would 
visit another in order to get an understandin g of the way applications by companies are 
assessed and compliance is monitored by them. Re sults would be discussed at Member State 
meetings. 
micro-option xiv. 
Provision of information by the EUEB on  appropriate future minimum environmental 
standards for products 
EN 26   EN (See Section 3.2.k) 
When considering Eco-label criteria, the EUEB gathers considerable information about 
products' environmental performance and market  trends. Under this option, the EUEB would 
also use that information to provide r ecommendations on future mandatory minimum 
environmental performance requirements, in the sa me format as core Ecolabel criteria. They 
would also provide a recommendation on the timetable to which these minimum requirements should be implemented. These recommendations would be public  and the Commission would 
consider these recommendations and make pr oposals for their implementation within the 
framework of an appropriate  existing legal instrument. 
EN 27   EN SECTION 6: ANALYSIS OF IMPACTS  
The Ecolabel will tend to produce two e ffects where used for any product group: 
a) an increase in sales of products that have better environmental performance (as a 
proportion of sales of that product group); and 
b) provide an incentive to some firms to innovate in their pro duct design or production 
processes, so that they can gain the Ecolabel award in future for their product, together with 
the economic benefits that this may bring. 
The first of these effects leads directly to environmental benefit. The second, through 
promoting innovation and dynamic improvement of  resource use, brings both economic and 
environmental benefits. The extent of both ef fects will depend on th e number of products 
using the Ecolabel and the success of the Ecolabel in increasing either the sales or the price premium of the products  it is awarded to. 
The extent of these effects is  impossible to judge from the Ecolabel policy itself – the 
Ecolabel is only one of severa l EU policies that provides incen tives for the uptake and design 
of environmentally better produc ts. Many Member States also have national policies which 
promote greener products, whilst private policies, for example by large reta ilers or purchasers, 
will also have a great effect on the success of the Ecolabel. 
The forthcoming Commission's Sustainable Consumption and Production Action Plan will 
examine how a range of product policy instrument s can work together to more effectively 
provide dynamic incentives for eco-innovation in pr oducts and to increase the sales of better 
environmentally performing products. This Action Plan will look at how arrangements can be 
put in place to apply the optimum  mix of policy instruments to particular product groups – to 
maximise the complementarity of the instruments as a whole. Just as a hypothetical example, 
to provide incentives for development of be tter environmentally performing [shampoos], 
policy instruments from Ecolabel, Green Public  Procurement, a "top runner"/performance 
standard and fiscal incentives, might all work together effectively. The Ecolabel and the information about product performance and future  sales generated to inform development of 
Ecolabel criteria could be a cr ucial part of that product packag e, but it would be difficult to 
attribute the environmental and economic impact s that resulted to the Ecolabel alone. 
The costs of the Ecolabel scheme will also be dependent on the extent of its use and the co-
ordination of the scheme's activities with othe r policy instruments. Enforcement activities in 
Member States, for example, to check the market  for unauthorised eco-labels, are likely to be 
less expensive if co-ordinated with other mark et surveillance activities. The costs of the 
administrative activity, including information ga thering, to set the criteria for the Ecolabel 
might also be shared with co-ordinated inform ation and decision making in relation to the use 
of other product relate d policy instruments. 
Bearing this in mind, and taking into account the need for proportionality in assessing the 
impacts of a voluntary instrument, this impact assessment will look mainly at the impacts of 
options on the potential of the Ecolabel, rather than try to estimate certain effects. For 
instance, a policy option that reduces administ rative procedures may be certain to make 
application for the Ecolabel more appealing – and therefore will increase the potential of the Ecolabel to perform effectively. This impact a ssessment examines that effect on potential, but 
does not try to quantify the possible resulting economic, social or environmental effects for 
individual options. 
However, it is possible to provide information th at gives a perspective of  the potential benefits 
of the Ecolabel scheme as a whole, in various situations: 
EN 28   EN Potential Direct Environmental Benefits 
A study commissioned by DG Environment22 calculated the potential direct benefits that 
could be expected if the cu rrent product groups had a market  take-up of 5%, 20% or 50% 
respectively. The amount saved was calculate d as difference between the environmental 
performance of an eco-label product and that of an average product on the market times the 
number of products sold in each scenario: 
AMOUNT SAVED PER YEAR BY SCENARIO 
% 
Resource saved /avoided per year 5% Take-up 20% Take-up 50% Take-up 
Electricity, GWh 14,700 59,000 147,600 
CO 2 produced from energy use, tonnes 9,318,000 37,270,000 93,175,000 
Water Use23, Megalitres  12,285,000 49,138,000 122,846,000 
Reduced Hazardous Substance Use, 
tonnes 13,800 55,400 138,400 
Material Savin gs (other than Hazardous 
Substances), tonnes 530,700 2,122,700 5,306,700 
Reduced discharges to water, tonnes 
COD  30,400 121,700 304,200 
Reduced Air Pollution, tonnes  17,500 70,100 175,300 
Source: AEAT, "Final Report", November  2004, Report produced for DG Environment 
Starting from the fact that criter ia are set at levels that promot e the labelling of products that 
have a low environmental impact and that the aim of the Ecolabel is to encourage improvements in the environmental performan ce of products during the whole life-cycle of 
the product it is assumed in the study that comp anies choosing to sign up to the Ecolabel may 
have to make some adjustments to their pr oduction behaviour, result ing in environmental 
benefits in terms of restrictions on certain polluting chemicals, improvements in recyclability, introduction of waste management system s, limits on chemical emissions, etc. 
                                                
 
22 AEAT, "The Direct and Indirect Benefits of the European Ecolabel – Final Report", November 2004, A 
Final Report produced for DG Environment. It should be noted that this study was not peer reviewed. 
23 Water Use includes savings due to more efficient appliances and savings due to the reduced CDV value 
of ecolabelled detergents. 
EN 29   EN  
Source AEAT, "The Direct and Indirect Benefits  of the European Ecolabel – Final Report", 
November 2004, A Final Report produced for DG Environment 
Potential Indirect Benefits (Environmental and Economic) 
On top of these direct environm ental benefits the Direct and I ndirect Benefits study, based on 
consultation with EUEB members, identified ni ne indirect impacts from the Ecolabel, looked 
at known instances, success stories and calculat ed their potential impact which could be 
expected by taking measures which would lead to replication of these examples24. 
1. The use of the Ecolabel criteria by anothe r eco-label scheme. Criteria may be copied 
directly or used as a referen ce point before local adaptation. 
2. The use of the Ecolabel criteria in  public procurement calls for tender. 
3. The use of the Ecolabel criteria in  private procurement calls for tender. 
4. The use of the Ecolabel cr iteria by companies as a benc hmark for their own products 
or as a target to improve their environmental performance. 
5. The use of the Ecolabel criteria to gene rate Type III labels (environmental product 
declarations), or recommendations on how to make green claims (Type II). 
                                                 
24 For more detailed explanations of the assumption and methodology we have to refer to the study itself: 
http://ec.europa.eu/environmen t/ecolabel/pdf/market_study/b enefitsfinalreport_1104.pdf   Environmental Improvement attributable
to the 
ecolabelled product, (delta)  Standard    
Product    
Footprint    Ecolabelled    
Product    
Footprint    
EN 30   EN 6. The use of the Ecolabel criteria and pr ocedures/structures to generate minimum 
environmental requirements applicable to  all products of a product category on the 
market. 
7. The use of the Ecolabel criteria in the “n ew approach” as a basis for establishing 
whether companies have complied with “essential requirements”. 
8. The use of the Ecolabel logo, Ecolabel  criteria and related discussion, to raise 
stakeholder awareness of the environmental impact of products, with stakeholders 
including manufacturers re tailers, consumers, environmental NGOs and public 
administrations. 
9. The use of the Ecolabel and its criteria as a basis for establishing fiscal measures to 
promote green products, (e.g. criteri a for energy rebate schemes) 
Indirect Environmental Benefits of the Ecolabel within the EU25 
Item Amount saved per year 
Money  €763 million 
Energy saved  43 TWh 
CO 2 saved 27 million tonnes 
Water saved25 35 Tera litres 
Hazardous substances avoided 39 thousand tonnes 
Materials saved 1.5 million tonnes 
Reduced discharges to water 85 thousand tonnes COD26 
Reduced air pollution 49 thousand tonnes 
 
                                                 
25 Water Use includes savings due to more efficient appliances and the reduced CDV of ecolabelled 
detergents. 
26 Chemical Oxygen Demand 
EN 31   EN  
Indirect Environmental Benefits of the Ecolabel Outside the EU2527 
Item  Amount Saved per Year 
Energy saved 2.9 TWh 
CO2 saved 1.9 million tonnes 
Water saved 2.5 Tera litres 
Hazardous substances avoided 2.8 thousand tonnes 
Materials saved 106 thousand tonnes 
Reduced discharges to water 6 thousand tonnes COD28 
Reduced air pollution 3.5 thousand tonnes 
 
Economic Benefits 
The indirect benefits above indi cate some of the economic bene fits that should result from a 
successful Ecolabel scheme – improvements in  resource use, reductions in economic damage 
and reductions in damage to health (and therefore productivity  and treatment costs) from 
pollution. 
However, the greatest economic benefits are likely to come from the promotion of innovation 
in both process design and production techniques . Such innovation is very likely to reduce 
both resource use in production and increase e fficiency – and therefore provide both direct 
and indirect benefits to the EU economy as successful technol ogies grow in niche markets, 
then spread more widely. All of this would increase interna tional competitiveness, both of 
individual firms and the EU economy as a whol e. The Ecolabel is often used by SMEs to 
develop their market share – one of the im portant breeding grounds for entrepreneurial 
activity and innovation that is particularly im portant to encourage. The benefits that may 
result from a successful Ecolabel are hard to quantify, either beforeha nd, or afterwards, but 
would be nevertheless real. 
Innovation is likely where market demand w ill reward that innovation, through greater 
economic returns for the innovator. Most simply, where there is consumer demand for a product that is "greener" than the others, there is  a market there for greener products. It can be 
seen as a differentiated product market. For produ cers to get, or retain a share of that product 
market, they will need to innovate - because the Ecolabel criteria will be revised over time to 
ensure that only the best products are awarded eco-labels. But if consumers cannot be sure 
which the greener products are - if they have no  reliable information on that, the demand that 
creates that differentiated market will not aris e and there will be no benefits from the eco-
innovation. 
                                                
 
27 Considers the EU Ecolabel to influence the national schemes of Australia, Canada, New Zealand and 
the United States. 
28 Chemical Oxygen Demand 
EN 32   EN One good example of how the Ecolabel can dr ive innovation is that  of the MicroPro 
Computer29 To quote their own marketing: "M icroPro Computers introduces an 
environmentally-friendly PC, called Iameco, wh ich is developed as a zero-waste personal 
computer. The company is striving to become the only PC maker in the world to earn the 
European Union's prestigious Ecolabel mark, fo r high-quality consumer products that meet 
the highest environmental standards". 
There are also many examples of innovators seeking to use the Ec olabel as a reward for their 
innovation. One good example of this in practice is  that of Boston Power batteries, who have 
just been awarded the Nordic Swan eco-label30. The Swan was able to rapidly provide a 
reward for the company's innovative product. Th e company website says , in relation to the 
award: "It is an achievement that is well-deserved and also  a testimony to their commitment 
to combine technical knowledge with environmenta l quality standards". It  is by this type of 
link that the eco-labels can also help drive innovation. 
By working with the market, the Ecolabel is de signed to be used where it offers net economic 
benefits to enterprises – and it stands or fa lls on that criterion: if the scheme is not 
economically beneficial to a particular enterpri se, it will not be taken up. Maximising the total 
economic benefit from the scheme is therefore one  of its goals, and one of the goals of its 
revision. 
As a whole, the Ecolabel is one of the instru ments aimed at achieving th e goals of the revised 
Strategy for Jobs and Growth (Lisbon Strategy). The Ecolabel policy cont ributes to 6 of the 
10 Mirco-economic guidelines of the Integrated Guidelines.31 
(7) To increase and improve investment in R&D, in particular by private business; 
(8) To facilitate all forms of innovation; (10) To strengthen the competitive advantages of its industrial base; (11) To encourage the sustainable use of re sources and strengthen the synergies between 
environmental protection and growth; 
(14) To create a more competitive business e nvironment and encourag e private initiative 
through better regulation; 
(15) To promote a more entrepreneurial cu lture and create a supportive environment for 
SMEs. 
Administrative Costs 
The Ecolabel scheme requires some procedures  to work effectively and these inevitably 
involve some administrative activ ity by both enterprises applying for, or using eco-labels, and 
for the Commission, national authorities and th e organisations involved in decision making on 
Ecolabel criteria. 
For any enterprise applying to the scheme, the ad ministrative costs of the application must be 
smaller than the economic benefit that enterprise  expects to receive from applying for an eco-
label. The lower these administrative costs are,  the more attractive the scheme becomes for 
potential applications and the grea ter its success is likely to be. 
                                                
 
29 http://greentechnolog.com/2006/ 11/zero_waste_computing.html  
30 http://www.boston-power.com/  
31 Integrated Guidelines for Growth and Jobs (2005-2008) , European Commission, 2005 
EN 33   EN Whilst it is not possible, for the reasons stated above to quantif y the total administrative costs 
associated with the voluntary sc heme, it is possible to look at  the impact of  options on the 
administrative costs of individual procedures. 
Social impacts 
Given that criteria also  include aspects related to human h ealth, this can be considered as a 
positive social impact, but apart from this, no other relevant social impacts are expected. The positive impact on health is underlined by a BEUC (Bureau Européen des Unions de 
Consommateurs) study  which concludes : "The Ecolabel was original ly conceived to reward 
products having a reduced environmental impact . Studying what the Ecolabel criteria say 
about the content of hazardous ch emicals in the final products  allows an additi onal important 
dimension to be included: health."
32  
Assessment of the Impacts of Options 
The better the Ecolabel scheme is designed and implemented the higher the probability that 
these potential benefits become real and that the policy objectives desc ribed in section 4 are 
achieved. Keeping this in mind, the aim of the following assessmen t of the different options is 
to identify the impacts of different macro and micro options on the potential of the Ecolabel 
scheme.  
                                                 
32 See: http://ec.europa.eu/environment/ecolabel/pdf/studies/beucstudy2004_en.pdf  
EN 34   EN  
Macro-option 1 – Continue with the present approach. i.e. Business as usual 
The analysis of the impact of this option can be made by analysing th e impact of the current 
scheme. Fundamentally, if no action is taken then the scheme can be expected to continue to 
operate as it has done up  until now. It would continue to gr ow steadily but very  modestly with 
some small environmental economic and social be nefits, but with a number of barriers to its 
development. 
The EVER study33 outlines the main plus and minus points about the current scheme, that can 
be summarised as follows: 
On the one hand: 
• Low awareness; 
• Insufficient product group categories; 
• Low up-take by industry; 
• Procedural and organisational problems – i.e. bureaucracy; 
• Costs for participating companies; 
• Lack of perceived public  purchasing benefits. 
On the other hand: 
• Around three quarters of users thi nk that the EU Ecolabel has c ontributed to setting targets 
for the improvement of product environmental performance; 
• A large majority also say that the Ecolab el influenced the demand on their suppliers 
concerning the environmental performance; 
• Almost all of the companies participating in  the EU scheme use the Ecolabel in their 
marketing campaigns; 
• More than half of the non-Ecolab el participants declare they use the Ecolabel criteria as 
benchmarks to for the environmenta l performance of their products; 
• Neither users nor non-users of the Ecolab el want to see the label abolished; 
• National labels are not prefe rred over the EU Ecolabel. 
Continuing with business as usual would mean that the positive effects in environmental, 
economic and social terms would remain. 
The EVER project questione d actual participants of the EU Fl ower as to their opinion of the 
label’s influence on environmental performance  and found that:  " Nearly 2/3 of the 
participants indicated that the objective to im prove environmental performance was very or 
fairly important for their application for the Flower. (…)About every second interviewee 
indicated that the Flower had so me effect on the environmental performance of the product in 
the areas of air and water emissions, waster/rec ycling and water/material use; improvements 
with regard to accidents/spills were rare and for noise/smell observed by ¼ of interviewees".   
In addition, there is anecdotal evidence from the practice of Ecolabel  implementation that 
companies – maybe not all – actually have to do  some effort in improving the environmental 
                                                 
33 For more details see EVER study see: http://ec.europa.eu/environment/ecolabel/revision_en.htm  
EN 35   EN performance of their products or services. A statement from Hilton Ho tel Malta can serve as 
an example: “The accomplishment of this task is by no means an easy exercise. It is, in fact, 
time consuming but certainly an interesting, inte ractive learning experience. To start with, we 
set a target date, and used a textbook approach to deal with the criteria. It is the continued 
implementation and refinement that is most ch allenging for the com pany. Investing in such 
ongoing actions creates short-term costs in setting up the systems but is rewarded with long–
term benefits".34 
Apart from improving the product or service itself , there is a second aspect which has to be 
considered in this respect: the increased sale s of eco-labelled products. According to the 
EVER study, 53% of the interviewed companies e xperienced an increase in the market share 
or in the number of new customers tha nks to the adoption of the EU Ecolabel35. 
However, with such a low uptake overall of the scheme such environmental benefits are 
limited mainly because of the persistence of th e problems described in section 3: consumers 
would largely remain unaware of the label, business interest in the label would will remain limited, the number of product groups would grow at  a very slow pace, if at all, criteria 
documents often could not be revised in due ti me, development of new or revision of existing 
product groups would continue to take too long (some 3 to 4 years) wasting scarce resources 
of all the parties involved, the fee would remain complicated and inflexible, stakeholders 
would not feel to have real ow nership of the scheme, purchasi ng officers would continue to 
show little interest in the labe l, the Ecolabel could not be c onsidered for food products, etc. 
In terms of the objectives of success outlined in  Section 4, we might therefore expect the 
following results by 2017 if we extra polate from the last ten years: 
• 10-20 % of population that know the Ecolabel  and its meaning within ten years. 
• 10-20 % of companies that know th e Ecolabel within ten years. 
• Reasonably rated in terms of cr edibility when compared with other environmental labels. 
• 30 product groups; 600 pa rticipating companies; €1.5 annua l sales volume of Ecolabelled 
goods. 
• Ecolabel little used by p ublic purchasers monitored. 
• Few, if any, policies that can be attributed to having used the Ecolabel product information 
work. 
• Limited number of Ecolabel criteria adopted by other labelling schemes. 
Macro-option 2 – Gradually phase out the scheme 
Phasing out the scheme could lead to some benefits but would mean losing the positive 
impacts analysed for the current scheme – see a bove – and the potential for further developing 
these benefits. The EVER study highlights th e main motivations for shutting down the 
scheme as the lack of success of the current sc heme and the fact that Member States already 
have their own national schemes. Phasing out the Ecolabel scheme would free up resources 
associated with the Ecolabel for use on other initiatives. 
At the same time the EVER study points out the potential impacts of the shutting down the 
scheme as a lost opportunity to im prove it and to gain th e potential benefits that it has to offer. 
                                                
 
34 Source: Flower News, July 2006: http://ec.europa.eu/environment/ecolabel/news/index_en.htm  
35 http://ec.europa.eu/environment/ecolabel/revision_en.htm  : Report 2, p. 118 
EN 36   EN The study looks at the views of the industry, both participating in, and not participating in, the 
Ecolabel scheme, and their views as to  the Ecolabel vers us national labels36 – the study states: 
"when asked, over 70% of the interviewed stakeholders do not  recommend a national rather 
than a European label. While some believe more  in an EU Ecolabel in the long run, others 
see them as supplementary". Overall, the study concludes:  "(…) harmonisation is seen as 
being the only effective solution to be pursued. There is very little support for the options of 
abolishing either the EU Eco-label or the national labels". 
Importantly, no Member States have expressed a de sire to abolish the Ecolabel, but rather to 
improve the scheme, which suffers from some very obvious problems. In those Member States where there is no national scheme the poten tial of the EU Ecolabel is seen as important 
because, without it, they would have no sim ilar third-party labelling scheme. The UK for 
example considers the existence of the EU Ecol abel scheme the reason that they have not 
developed their own scheme. If the EU Ecolabel  were phased out, it s eems likely, therefore, 
that in time national labelling schemes would e volve in most Member States. What is clear 
from looking at the different national schemes currently in place is that the schemes in the 
different Member States would be very different. So for comp anies marketing their "green" 
products throughout the single market they woul d need to meet the different criteria and 
different assessment and verification procedures for all schemes. It is for this reason that 
companies who support the idea of ISO type I labelling schemes,  support the idea of 
harmonised EU criteria. 
The only cases of harmonised criteria so far are those cases where national schemes have 
voluntarily taken on Ecolabel cr iteria word for word – some examples being those of the 
Austrian Ecolabel which has taken on crite ria for light bulbs and cleaner or that37 of the 
Nordic Swan which has taken on the EU criteri a for Indoor Paints and Varnishes in their 
entirety38. They then offer applicants a discount: 
"Since the criteria are identical to the EU ecol abelling criteria, a producer may, if he so 
wishes, apply concurrently for both Swan and EU -Flower ecolabels and thus gain permission 
to use both labels." 
"Applications for both the Swan and EU Flower ecolabels for a single product are entitled to 
a discount. Please contact Nordic Ecolabelling in your country for further information." 
The potential to develop these types of synergies between nati onal labelling schemes and give 
and level playing field for companies operating in Member States with and without national 
schemes would be lost if the Ecol abel were to be phased out. It  is therefore one of the most 
important features of the EU Ecolabel in compar ison to other labels that it is EU-wide. It 
offers companies the opportunity to have one single label for all of the Internal Market, 
instead of having to apply in a number of di fferent countries for different labels (with 
different procedures, different criteria, di fferent logos, etc.). 
Equally, for consumers it is much easier in an Internal Market to be able to rely on one major 
label which is used everywhere. Moreover, there is the potential for cons iderable cost savings 
if one scheme is used instead of every country having to develop its own scheme. 
On top of this, those companies which have al ready invested in the Ecolabel would not get 
any further benefit and would have to consider their investments as wasted to a large extent. 
There are also a number of product group specific eco-la bels developed by industry 
                                                 
36 http://ec.europa.eu/environment/ecolabel/revision_en.htm - see report on research findings, p.100 -104  
37 http://www.umweltzeichen.a t/filemanager/list/15672/  
38 http://www.svanen.nu/DocEng/096e.pdf  
EN 37   EN associations or groups of NGOs. These schemes vary widely, ranging from labels based on 
environmental management systems (for ex ample the A.I.S.E. Sustainable Cleaning 
Scheme39) to single issue specific labels (like the Forest Stewardship Council label40). A 
balanced participation of different interest grou ps – crucial for the credibility of a scheme – 
seems to be difficult to guarantee without clear ex ternal rules. No other label currently serves 
the same purpose as the EU Ecolabel which ai ms to set the benchmarks across product groups 
and throughout the life-cycle of those products across the EU . Phasing out of the scheme 
would mean the potential benchmarking tool, setting out "what make s a good scheme" would 
be lost. It is likely that, due to increasing consumer demand for information, many more 
product group specific labels would be develo ped, often Member State by Member State. 
Consumer confusion at the basis for the different labels would increase. 
The EU Ecolabel is intended to add value, not  add "another label" – the potential of the 
scheme will help achieve this, with better measures on harmonisation and more industry involvement. This is explored  in the next Macro-option. 
Macro-option 3 – Modify the scheme 
A number of micro-options are presented in Section 5, each of which may have its own 
environmental, economic and social impacts. Th e impacts of each of these micro-options is 
considered in turn and then the overall impact of selecting the best package of modifications
 
is considered for the purposes of going on to choose the best macro options in Section 7. 
Impacts of the micro-options: 
micro-option i. Introduce fiscal incentives for the eco-labelled products and services: 
Pros: Tax breaks (e.g. a reduced VAT rate) would enable producers to lower prices for eco-
labelled products, or to increase their profit margins with the price kept constant, or for retailers to apply a larger mark-up whilst keepin g the price constant – wh ich is likely to lead 
them to take steps to increase sales, which woul d offset the costs involve d in getting the label 
(cost for adjustments of the product, for testi ng, for fees, etc.). Through such a comparative 
advantage, the Ecolabel would become more attractive to companies which would lead to 
more licence holders and labe lled products on the market. 
Cons: The increased economic advantage from th e tax break attaching to the award of eco-
labels could also lead to much more difficult ne gotiations in the criteria development process. 
Intensified lobbying is to be expected which will  slow the process and eventually could cause 
deadlocks in negotiations. The idea of a ta x break for eco-labelled  products was already 
discussed in the framework of the Commi ssion's Communication on Integrated Product 
Policy
41 in 2003 where most Member St ates were not in favour. 
Option accepted/rejected: Rejected . Although enjoying such an impressive support amongst 
respondents to the internet consultation as we ll amongst interviewees in the EVER study (in 
the internet consultation, more than 67 % were in favour of fi scal measures and 76 % of the 
interviewees in the EVER study considered it fa irly or very important),  fiscal measures are 
considered beyond the scope of the Ecolabel Regulation at this time. Nevertheless, the 
Regulation could encourage Member States to c onsider fiscal incentives at MS level where 
                                                 
39 http://www.sustainable-cleaning.com/  
40 http://www.fsc.org/en/  
41 Communication from the Commission to the Council and the European Parliament, COM (2003) 302 
final 
EN 38   EN appropriate and foresee collection and dissemination of best practice examples in this field. In 
cases where tax differentials are granted on the basis of environmental considerations this 
should be clearly communicated to  the consumer. Fiscal incen tives at Community level will 
be considered in the wider policy framework of the SCP Action Plan.  
micro-option ii. 
Open up the scope of the label 
Pros: This will allow developing criteria for product groups with the greatest environmental 
impact (according to the EIPRO study) such as food where "carbon labelling" schemes for 
food products are now being develo ped by large retailers and othe r organisations but there is 
no mechanism in place to offer any form of EU standardisation. Opening the scope would 
allow identifying the areas with the greatest environmental foot print and setting criteria in line with the aims of the scheme.  
Cons: None Option accepted/rejected: Accepted
. Making good decisions on which product groups to 
develop ecolabels can be built into the Regul ation without having to specifically rule out 
certain groups directly in the Regulation   
micro-option iii. 
Introduce measures to encourage harmonisation with other ecolabelling schemes: 
(a) EU Ecolabel criteria as a standard for other ecolabels; 
(b) Accreditation of nati onal/regional ISO type 1 schemes to use the Flower; 
(c) Eventually ban national labels from operating when Ecolabel criteria exist; 
(d) Fast track procedure to a dopt criteria developed by nationa l/regional ISO type schemes. 
Pros: The Ecolabel will set the standard for e nvironmental product criteri a in the EU, while at 
the same time giving companies a wider choice  of product groups for which they could use 
the EU Ecolabel. With one procedure they can get the EU label and a national label if they 
wish to do so – without any additional cost. Th ey can use the national label where this is 
better known than the EU label (home market) and the EU label for exports to markets where 
the national label is not known. 
Cons: Competition between labels can encour age them to increase their environmental 
stringency to prove they are "the best", which can help keep standards high – this may be lost 
if the one label becomes the only labe l setting the standards on the market. 
Option accepted/rejected: (a + d) accepted, (b + c) rejected . These measures will be better 
for businesses, who can use the EU Ecolabel fo r EU marketing and better for consumers, who 
will find more Ecolabel products on the shelves.  The "fast track" adoption of criteria from 
other schemes will allow other schemes to operate  at the national level, while at the same time 
increasing the number of product groups for the EU label. 
Banning other ecolabelling schemes is likely to reduce the total benefits from eco-labelling 
schemes in Europe. National labelling scheme s have, in some cases, been much more 
successful than the Ecolabel scheme, as they meet  the specific needs of the Member States in 
which they operate. Accreditation of national schemes as a whole to use the Flower would 
involve assessing the overall credibility of these schemes, an exercise which is likely to be 
much more complex and political ly sensitive than allowing a fa st track adoption of individual 
criteria documents developed by other schemes. 
EN 39   EN The accepted options were the most strongly supported by respondents to the internet 
consultation. On the rejected options serious co ncerns were raised by re presentatives of some 
national labelling schemes. 
micro-option iv. 
Introduce a new standard for making green claims in Europe 
Pros: Consumers will be able to rely on green claims made on products. There will be a level 
playing field for industry, prev enting misleading green claims and offering a clear benchmark 
for good environmental performance of products. This may avoid unwarranted green claims 
for products, which would damage the market for greener products as a whole. 
Cons: The standard will only be available for pr oduct groups for which co re criteria have been 
adopted. This measure could discourage some co mpanies, not wishing to see a standard for 
green claims from taking part. (Although the oppos ite may also be true in some cases, as 
companies want to be involved in the process to give their voice to the resulting criteria.) 
Option accepted/rejected: Rejected . While this option is str ongly supported by  internet 
consultation respondents and would ensure that  green claims be made based on sound and 
stringent environmental criteria which would help the Ecolabel reach its aim of  providing the 
benchmark for the environmental performance of products, and would encourage companies 
already meeting the core criteria to improve further their performance to apply for the 
Ecolabel, it is considered beyond the scope  of the Ecolabel Regulation as it would 
considerably change the voluntary nature of this instru ment. It is suggested  that the issue of 
green claims be considered in the wider framework of sustainable consumption and 
production. 
micro-option v. 
More direct stakeholder involvement 
Pros: An option is strongly supported in the inte rnet consultation that would see stakeholders 
better involved and perhaps more committed to the scheme. The process of decision making 
will be shortened compared to the current system  by up to two years. The system will be able 
to adapt to change and the Ecolabel 'brand' will be able to operate in a more business-like way 
leading to increased interest in the scheme , more licences and bigger environmental and 
economic impacts. 
Cons: The challenge will be to find a well balanced composition of the stakeholder body. 
Additionally there is a risk that some Member States, with reduced dire ct power over Ecolabel 
criteria decisions, will lose interest in the sc heme and will decrease the resources allocated to 
it. Furthermore, if the revised Ecolabel does not share the same decision making procedures 
as other SCP policies under Ecodesign, i.e.  Commission Decision, it will be make 
harmonisation of criteria and test methods for different policies more difficult.  
Option accepted/rejected: Rejected . Bureaucracy is a problem fo r the Ecolabel and must be 
tackled but moving away from Commission Decisi on, while it might help the 'branding' of the 
label, would essentially take away the 'EU' aspect of the label, which is a major part of its unique appeal and usefulness. The label needs to be integrated with other policies, and 
keeping Commission Decision, which is the same  decision making procedure for Ecodesign, 
will allow this to happen more smoothly. Stakeholder involvement should be enhanced by ensuring that the criteria development proces s openly and transparentl y takes into account 
their views, and that transparency is given as  to why any input made  has been accepted or 
rejected during the process. At the same  time bureaucracy surrounding the criteria 
development process should be focused on, along with other aspects of the way the label 
EN 40   EN operates, such as for assessment and verification  procedures. These issues then are dealt with 
in other micro-options.  
micro-option vi. 
More product groups / quicker criteria development- 
Pros: The scheme will be much more efficient a nd flexible, therefore allowing to adapt easily 
to changing needs and to adopt changes to criter ia which become necessary as a result of the 
experience in implementing them in practice. Synergies with other instruments as well as 
relevant work carried out elsewhere can be used. Improved criteria documents following a 
common structure will be easie r to understand and implement for companies. Consumers and 
policy makers will also find criteria documents eas ier to digest, thus allowing the Ecolabel to 
better act as an education and information tool. 
Cons: Developing more product groups may bear th e risk that some stakeholders or Member 
States will not have the resources to follo w criteria development fo r every product group, 
unless they increase their resources. 
Option accepted/rejected: Accepted . Linked to the previous micr o-option, this option is about 
using common sense to ensure the scheme is run efficiently and to allow interested stakeholders to help with the development of crite ria. Quality control of criteria would need to 
be enshrined in the develop guidelines for them . This option was very strongly supported in 
the internet consultation. 
micro-option vii. 
Incorporate guidance for Green Public Pu rchasing into criteria development 
Pros: The Ecolabel scheme will deliver ha rmonised environmental criteria for public 
purchasing which can easily be introduced into technical specifications. The Ecolabel will be a reliable instrument for checking a product ag ainst specifications. E nvironmental benefits 
could be high as companies move to meet th e basic GPP criteria. Again, this was strongly 
supported by respondents to the internet consultation. 
Cons: None. 
Option accepted/rejected: Accepted
. This should have been incorporated since the beginning 
of the operation of the Ecolabel scheme. 
micro-option viii. 
Change of rules for public procur ement to favour the EU Ecolabel 
Pros: Making it mandatory to include Ecolabel criteria into calls for tender or simply to 
request Ecolabelled products would give a st rong boost to the Ecolab el and would reward 
companies with environmentally  improved products. The number of Ecolabel licences could 
be expected to increase strongly, as would th e associated environmental benefits as the 
incentive for going for the Ecolabel would be significantly increased. 
Cons: As with tax breaks, this strong incentive ch anges, to an extent, the nature of the scheme 
as "voluntary" and the idea of  moving away from "command a nd control" type legislation. 
Option accepted/rejected: Rejected . The EVER study found that green procurement (both 
public and private) has been judged as crucia l for stimulating eco-labelling performance and 
more than 61 % of the respondents to the intern et consultation agreed or  strongly agreed that 
it should be mandatory for Member States to use Ecolabel criteria (or equivalent) where 
possible in calls for tenders. While it is clear that this revision of the Ecolabel Regulation has to ensure that the Ecolabel scheme is attractive for public purchasers and that Ecolabel criteria 
EN 41   EN are as easy to use for this purpose as possible, a change of the public procurement legislation 
is beyond the scope of the Ecolabel Regulatio n. The issue of how to foster green public 
procurement is currently being addressed by  the Commission in the framework of the 
preparation of a communicati on on green public procurement. 
micro-option ix. 
Simplification of the fee structure 
Sub-option a: Simplified fee structure. 
Sub-option b: No fees. 
Pros: According to the EVER study, cost is seen as th e highest barrier for potential applicants. 
Therefore, an increase in applications can be  expected. Sub-option b – no fees – would also 
mean reduced bureaucracy as no calculation and administration of fees are necessary. 
This sort of financial incentive for the using th e Ecolabel is much easie r to administer than a 
reduced VAT rate or any ot her kind fiscal incentive. 
Cons: This would mean a loss of  income for competent bodies. 
Option accepted/rejected: Sub-option b accepted . No annual fee for the Ecolabel will send a 
clear message that companies meeting the Ecolab el criteria will bene fit from doing so and 
will not be penalised. It will be of biggest benefit to SMEs  who find the fee as a significant 
barrier and will effectively offer a financial incentive for using the Ecolabel. A small fee, to deal with the direct costs of dealing with applicati ons, will be maintained.  
micro-option x. 
Abolish third-party verification 
Pros: Companies would be able to use the Ecol abel immediately after the publication of the 
criteria with no upfront pape rwork or bureaucracy required. Administra tive costs would be 
lower and uptake of the label would increase. Th is option would also m ean that the Ecolabel 
verification system would be the same as for the Energy label and the planned Eco-design for 
Energy Using products directive. 
Cons: Companies would have to prepare the same  documentation in order to prove that their 
products meet the criteria and they would ha ve to respond to spot checks by Competent 
Bodies at any moment. Neverthe less, many say that the credibil ity of the scheme depends on a 
third-party verification and givi ng up this crucial element would mean losing support for the 
scheme by consumer and environmental groups.  
Option accepted/rejected: Partly Accepted
. A radical simplification of the assessment and 
verification of the scheme is proposed whic h would move away fr om full third-party 
verification, but would maintain the requirement  to sign an agreement with a competent body, 
declaring accordance with the criteria. (As is, in  fact, the case for a majority of individual 
Ecolabel criteria already.) This revised system will be linked to ensuring that the criteria themselves are simpler, more focused, and eas ier in terms of on th e spot verification. 
micro-option xi. 
Accredit bodies outside the EU to  deal with Ecolabel applications 
Pros: Companies located outside the EU will have  easier access to the Ecolabel which may be 
particularly interesting for services such as  tourist accommodation or campsites. This may 
lead to an increase in numbers of licences and a better dissemination of the scheme at the 
global level. The Ecolabel, alrea dy covering more countries than any other similar label, will 
become global. 
EN 42   EN Cons: Meticulous assessment of the suitability and reliability of exte rnal accreditation bodies 
will be required to ensure the credibility of the Ecolabel is maintained – this will be time 
consuming and, although some of the costs will  have to be met by the body wishing to be 
accredited, it will still mean the use of administrative resources by the Commission. 
Option accepted/rejected: Rejected . Ensuring credibility appears to be too resource intensive. 
Instead of fully accrediting bodies outside the EU , it is suggested that Member States' 
Competent Bodies can cooperate with bodies outsid e the EU in order to facilitate applications 
from third countries. 
Micro-option xii. 
Boost marketing  
Pros: A considerably increased  marketing budget would allow for professional promotion of 
the Ecolabel, thus increasing know ledge of it and what it stands for. In combination with the 
other measures described above the label will become more attractive for companies, which 
will lead to more Ecolabelled products on the market, which, in turn, will lead to a higher 
demand from consumers due to the increased k nowledge. The more money that is invested, 
the higher the value of the brand for comp anies will become, as consumer knowledge 
increases – this will in turn lead to more applications and greater environmental benefits 
coming from the scheme. 
Cons: Marketing investment is a risk. If the scheme is not successful, then the money will 
have been wasted. 
Option accepted/rejected: Accepted . Without marketing investment the scheme will never 
take off. The key will be to monitor the indicator s of success to ensure that any investment is 
achieving the required results . If it is not then the money should be withdrawn. 
micro-option xiii. 
Peer review for Member States 
Pros: The way the Regulation is  implemented in MS, especia lly concerning assessment of 
applications and monitoring of compliance, wo uld become more transparent and harmonised 
in order to ensure a level playi ng field for companies across the EU. 
Cons: The system will require periodic missions  between Member States to review the 
operations of others and this  will require resources. 
Option accepted/rejected: Accepted . Ensuring a level playing field is  in the overall interest of 
the Internal Market and of the credibility of  the scheme. The micro-option will also allow 
different member States to share best practic es, learning from each other to improve their 
operations – this will mean the scheme is better implemented and run overall. 
micro-option xiv. 
Provision of information by the EUEB on  appropriate future minimum environmental 
standards for products  
Pros: 
• This key impact of this option is the provi sion of additional information by the EUEB – 
which provides the potential and s timulus for better policy outcomes. 
• The benefit of the information provided by th e EUEB is likely to be  high as the criteria 
development process for the EU Ecolabel follows clear guidelines including rules on 
EN 43   EN stakeholder involvement and transparency. Th e expertise of the ecolabel community and 
the studies carried out for the Ecolabel coul d be used for other policy instruments.  
• The provision of recommendations for minimu m standards which are consistent with 
Ecolabel is efficient as it makes use of exis ting work and avoids a confusion of standards 
for stakeholders – particularly manufacturers. 
• By publicly providing indications  of future standards in ad vance – and through discussions 
of those in the EUEB stakeholder process – manufacturers have a clear indication of 
potential future requirements, giving both clarit y and incentives to facilitate improvements 
in the environmental performance of  their poorly performing products.  
• This would lead to both reducti ons in environmental harm and reduced unfair competition 
for Eco-label products, which should provide gr eater incentives for innovation to further 
reduce the impacts of products. 
• The decision making process triggered by the Eco-label process should ensure that 
standards are only in cases (or at levels, or to  timescales) which lead to environmental gain 
that outweighs costs from changing product performance. 
Cons :  
• The extent of any benefit coming from this measure depends to a large extent on the 
resulting policy decision. Minimum sta ndards may end up being set which do not 
significantly change manufacturer s performance and therefore do not tackle the problem – 
which would continue to hinder improvements in the environmental performance of products, including thos e with Eco-labels. 
• Through this approach development of mandato ry performance standards would be limited 
to product groups for which Ecolabel criteria have been developed.  
Option accepted/rejected: Accepted.  The option should allow greater effectiveness of the 
Eco-label at improving product performance, with  a mechanism that should ensure action is 
taken only when beneficial. 
EN 44   EN SECTION 7: COMPARISON OF OPTIONS  
It is clear from Section 6 that macro-option 3 "Modify the scheme" is the only approach to 
ensure that the objectives from Section 4 can be achieved. For the sake of readability the 
micro-options under macro-option 3 have been a ccepted or rejected in Section 6. In summary, 
the following package of measures is proposed: 
Accepted: 
• Design Regulation to better fit into the ot her sustainable production and consumption 
actions of the Commission; 
• Open up the scope of the label; 
• Introduce measures to encourage harmonisatio n with other eco-labelling schemes: EU 
Ecolabel criteria as a standard for other eco-labels,  fast track procedure to adopt criteria 
developed by national/regional ISO type schemes;  
• More product groups / quicker criteria develo pment / Introduce a template for criteria 
documents to ensure they are more user friendly; 
• Incorporate guidance for Green Public Pu rchasing into criteria development; 
• Abolition of annual fees; 
• Simplification of assessment and verification; 
• Boost Marketing; 
• Peer review for Competent Bodies; 
• Make recommendations for mandatory environm ental performance standards for products. 
Rejected: 
• Introduce a new standard for making green claims in Europe; 
• Change of rules for public procurement to favour the EU Ecolabel; 
• Introduce measures to encourage harmonisa tion with other ecolabelling schemes: 
accreditation of national/regional ISO type 1 sc hemes to use the Flower; eventually ban 
national labels from operating wh en Ecolabel criteria exist;  
• Introduce fiscal incentives for the eco labelled products and services; 
• Accredit bodies outside the EU to deal with Ecolabel Applications. 
EN 45   EN SECTION 8: ADMINISTRATIVE COSTS  
As explained in Section 6, it is not possible to quantify the total administrative costs, 
including costs to public authori ties of administering the scheme , because we are dealing with 
a voluntary instrument where costs to a large extent depend on the uptake by industry and the 
associated costs of market surveillance of the conformity of those using the label. 
It is also possible to look at the impact of the selected micro-options  on the administrative 
costs of individual procedures. It also needs to  be emphasised that according to the strict 
Commission definition of  administrative costs, the Ecolab el Regulation does not impose any 
administrative costs on companies because it is  a voluntary scheme where companies are free 
or not to participate. 
Design Regulation to better fit into the other sustainable production and consumption actions 
of the Commission  will mean that synergies between  different product related policy 
instruments can be enhanced and therefore mean that there is a harmonisation of the 
framework in which criteria are presented. This will reduce the administrative burden on companies. Consider for example if we have  mandatory minimum criteria (under the Energy 
using Products directive) for tele visions and at the same time Ecol abel criteria for televisions. 
If the criteria are harmonised between the tw o policies it will mean fewer assessment and 
verification requirements for a company wish ing to comply with both schemes. So 
compliance with the requirements of the different instruments is made simpler for companies, therefore reducing the overall costs for them. The detailed costs per co mpany of applying for 
the Ecolabel cannot be precisely specified as product groups vary sign ificantly, as does how 
much additional work a given company has to undertake to meet the cr iteria. However, in 
very general terms the costs of tests associat ed with applying for the Ecolabel might range 
from around €1,000 - €10,000. To calculate what th e savings might be from having better 
synergies with other environmenta l policies, we need to look at the overlap of criteria that 
these policies can have with the Ecolabel. For example, the Energy Using Products directive 
will specify between one and three criteria on  the environmental performance of products, 
focusing on energy use, whereas the Ecolabel mi ght look at five to ten criteria covering the 
life-cycle of the product in more detail. If at l east the three EUP criteria,  and their associated 
assessment and verification basis, are harmonise d with the matching criteria in the Ecolabel 
then any testing requirements can be harmoni sed – thus reducing administrative burden. The 
same could be true for recommended best Green  Public Purchasing requi rements. Considering 
these likely overlaps in criteria might range fr om 20-30% savings from better synergies of the 
criteria might be expected to be similar. 
Introducing measures to encourage harmoni sation with other eco labelling schemes: For 
companies wishing to apply for more than one ecolabel, harmonising measures can only 
reduce their administrative burden. Costs of te sts could be reduced by 100% if one label is 
already held as no additional te sting or verification would be required. This reduced financial 
burden may be particularly interesting for small and me dium sized enterprises.  
More product groups / quicker criteria development: Simplified procedure for criteria 
development would reduce costs for all partie s involved (less meetings to attend) but 
development of more product groups clearly has an associated cost. From the AEAT study an 
estimate for criteria development is as follows: 
• Two people working full-time for 2.5 months each on developing criteria, i.e. 2 x 50 man-
days = 100 man-days (this effort may be spread over 18 months or so). 
• Three AHWGs, each a day long, attended by  25 people on average, thus 75 man-days. 
EN 46   EN • Therefore 175 man-days in total, or approximately half a man-year. 
• It has been estimated that this half man-year equates to  €25,000 on average to develop an 
eco-label for a product group from start to completion (excludes overheads, travel, and 
subsistence costs that may add 100% to this figure). 
• Calculations for known examples of where EU criteria have been adopted or used as the 
basis for national eco-labels have then been  performed by multiplying the number of 
product groups used by a national scheme  by the €25,000 saving, similarly for the time 
saving. 
• For the technical potential the calculation was performed on the number of national 
labelling schemes in operation within the EU , assuming each one on  average will use the 
Ecolabel criteria for one product group.42 
This estimate of €25,000 per product group is rou ghly in line with the budget the Commission 
currently provides for Ecolabel criteria develo pment, although it should be noted that costs 
vary hugely depending on the scale, complexity  and scope of the produ ct group in question. 
The work that has previously been done in that sector and the availabil ity of data will also 
change the costs of development. (The Life Cycle Analysis budget for Energy Using Products for domestic lighting, for example, is ar ound €300,000). One of the aspects of the option 
"modify the scheme" will be allowing work that has already been done by others to be used more easily by the Ecolabel – for example by Member States' national labels, by the Global 
Ecolabelling Network or in the context of othe r Commission work such as that of the Energy 
Using Products Directive or ne w Sustainable Consumption a nd Production Action Plan. This 
will save time and money because developing Ec olabel criteria in isolation will be avoided. 
This impact assessment cannot state exactly  which product groups will be chosen for 
development over the coming years, however, it w ill be specified that priority for Ecolabel 
criteria development would be for those pr oduct groups with the highest environmental 
impact. A basis of this could be the EIPRO study, which highlights some sixty product groups 
as accounting for the vast majo rity of environmental producti on and consumption impacts. 
The overall cost of development will depend on: exactly how many product groups are developed each year; the nature of each product group in question; what other work has already taken place and what on- going work is underway elsewher e. The more money that is 
allocated by the Commission and Member States , the more product groups can be developed. 
Currently the Commission spends around €150,000 per year on criteria development and 
revision, which gives one or two new product gr oups per year, and revisions for another two 
or three. With more efficient developmen t and revision processes, and by revising the 
Regulation to allow for better co-operation wi th other instruments, this number could be 
doubled at no extra cost, although over time, with  more product groups, the administrative 
costs may increase. (One desk officer would be required for each additional ten product groups.) 
Introduce a template for criteria documents to ensure they are more user-friendly: Making 
criteria documents standardised and more user-friendly will mean reduced administrative burden for companies and purchasing bodies us ing criteria for technical specifications.  
Incorporate guidance for Green Public Purchasing into criteria development: As already 
indicated in the previous point , procurement officers will ha ve easier access to EU-wide 
harmonised criteria and companies will have a level playing field if the same criteria are used across Europe in technical specifications for co ntracts. Member States will also save money 
                                                
 
42 http://ec.europa.eu/environmen t/ecolabel/pdf/market_study/b enefitsfinalreport_1104.pdf : page 54 
EN 47   EN because the same criteria can be used for eco-labelling and public purchasing (see above "fit 
into the upcoming SCP Action Plan"). 
Abolition of annual fees: The current direct income for comp etent bodies from fees is around 
€1million per year in EU 27. This direct income will be lost if fees are abolished, however the 
administrative burden will be reduced for compan ies. The administrative savings could be 
around half a man-day per year for a company pe r year, along with the benefit of not having 
to pay an annual fee. For Member States, th e administrative burden of  operating the scheme 
will remain the same as the work required to  undertake assessment and verification in the 
current scheme will be equal to the work required to administer and undertake market 
surveillance under the new proposals. Simpler cr iteria should, however, help to reduce the 
administration required. 
Peer review for Member States: Depending on the number of reviews per year (3 to 4) and 
assuming 4 to 5 working days for the team pe r visit, with 3 team members and one person 
from the reviewed Member State this measure would mean on average approx. 3 or 4 working 
days per Member State per year. This work should be offset by better, harmonised working 
practices that result that will reduce the need for interventions to correct poor implementation 
of the scheme by the Commission at a later date. 
Boosting marketing: In this impact assessment a figure of up to €5 million per year for five 
years for professional promoting of the Ec olabel brand is propos ed. For companies a 
marketing campaign of this magnitude paid fo r by the Commission and Member States would 
increase the value of the Ecolabel brand and help to improve sales of eco-labelled products 
and might reduce the need for them to conduct their own marketing campaigns. Overall more 
companies would mean higher in come from fees, so  in the long term spending on a campaign 
could be recouped. To what extent would depend on the uptake of the label.  
EN 48   EN SECTION 9: MONITORING AND EVALUATION  
Several measures will allow the monitoring and implementation of the scheme and to evaluate 
the success of the Ecolabel Regulation: 
• The Commission will continue using the Eurobarometer surveys to get data on public 
awareness of and trust in the Ecolabel. 
• The service contract for the collection of statistical information on Green Public 
Procurement which is currently being prep ared by the Commission includes reference to 
EU-wide Ecolabel criteria. This work will pr ovide input on the use and uptake of Ecolabel 
criteria by public purchasers. 
• The annual statistics exercise will continue as before: Competent Bodies are asked to 
provide information on the volume of sales of  Eco-labelled products, the number of Eco-
labelled products, the fees received from  licence holders and the resources (staff and 
money) dedicated to the scheme. 
• On a continuous basis, the Competent Bodi es will report any new licences to the 
Commission, which will continue to publish them  on the internet in the so-called green 
store ( www.eco-label.com ). 
• The regular meetings with Member States and stakeholders will also  continue to be a 
source of information on the implementation of the scheme. 
• The proposed new peer review mechanism described in micro-option xv , aimed at 
ensuring and monitoring a harmonised impl ementation of the Ecolabel Regulation will 
make the way the different Member States deal  with issues of how licence holders are dealt 
with more transparent. 
Furthermore, the draft proposal will contain a re view clause along the li nes of the one in the 
existing Regulation: 
"Within five years after its entry into force, the Commission will review the scheme in the 
light of the experience gained during it s operation. The Commissi on shall propose any 
appropriate amendments to this Regulation." 
EN 49   EN SECTION 10: CONCLUSION  
The Ecolabel scheme has potential, particularly as  part of a coherent package of measures, but 
is over-bureaucratic and isolated from other policies. Rather th an giving up on it, it should be 
overhauled and given another chance. It is very  important, however, to continue to monitor 
the progress of the Ecolabel  against those objectives. 
This impact assessment builds on experience from operation of the Ecolabel scheme and 
extensive consultation with part ies involved in the Ecolabel scheme, including users. It 
follows a detailed external evaluation of the scheme – the EVER study – and uses the evidence produced by that study. As a result of  the analysis, we recommend a number of 
separate changes to the operation of the Ecolabel scheme that can  be put into effect through 
changes to the Ecolabel Regulation. These changes will lead to an increa se in the potential of 
the scheme to effectively achieve its objectives. 
It can be expected that this modification and si mplification of the scheme will lead, on the one 
hand to a considerable increase in companies using the label, therefore also to an increase in Ecolabelled products on the mark et and, on the other hand, to an increase in th e number of 
consumers that know about and are prepared to  buy eco-labelled products as well as to an 
increase in the use of Ecolabel criteria in public procurement, specifically over and above the 
number of licences, companies involved and ov erall environmental bene fits that would be 
achieved if the scheme was left as it is. Mo re details can be seen in the EVER study. 
Future sustainable production and consumption policy in the Commission will put in place a 
coherent package of policy in struments that provide incen tive for improvement in the 
environmental performance of products. It wi ll build-on and reinforce various existing policy 
instruments also adding a number of new en vironmental policy initiatives. The Ecolabel 
scheme will need to be a key part of such an SCP package, linking to other policies and 
providing a backbone of good quality  life-cycle based product info rmation for them to use. 
An overhaul of the way the Ecolabel Regulation is  written will allow it to be not just a stand 
alone instrument, but a usable and integral pa rt of the wider SCP fr amework. A Regulation, 
written in a more simple and open way is need ed, giving it the flexibil ity to link easily with 
other instruments as and when the need arises  and decision making structures and processes 
will be simplified so they can be speeded up removing unnecessary bureaucracy. 
The Ecolabel Regulation as it stands is overl ong and spread across six additional Commission 
Decisions, it is difficult to follow and implem ent as a result and needs to be tidied up. The 
Regulation is also too restrictive meaning th at when new innovative ideas are put forward, 
they cannot be reacted to. Improving the way the Regulation is written and how criteria can be 
developed will increase the chances that the pot ential environmental and economic benefits 
are realised – key to this will be the ability of the sc heme to respond to innovation. 
The Ecolabel will be better tailored to policy  makers and will be a useful benchmark and 
information tool on the environmental performa nce of products. In term s of the objectives set 
out in Section 4, if this package of measur es is adopted, we might  expect success rates 
comparable to those of the Blue Ange l or Nordic Swan labelling schemes. 
The economic and environmental impacts of th e scheme will depend on its success, though 
indications of the potential enviro nmental benefits at different levels of success can be found 
in the AEAT report referenced in this impact assessment. 
The success of the Ecolabel will depend, amongst other factors, on how well it co-ordinates 
with other policy instruments aiming at promo ting innovation in the lif e-cycle environmental 
performance of products. The forthcoming Commission Sustainabl e Consumption and 
EN 50   EN Production Action Plan will examine ways to us e a range of product policy instruments in a 
coherent and co-ordinated way to maximise th eir effect as a whole in driving both innovation 
and sales of better performing products. As the Ec olabel would be a part  of that package of 
instruments, its impact will need to be judged as part of that package. 
The Ecolabel imposes no administrative burden on companies in the strict definition of the 
administrative burden used by the Commission43 because costs only incur to companies that 
voluntarily decide to apply for the label. Ho wever, this is not a reason to reduce any 
unnecessary costs from the scheme's operation.  Reducing these costs will lead to a more 
effective achievement of the scheme's objectiv es, making the Ecolabel both more attractive 
and increasing its net benefits. Several of th e micro-objectives recommended to be accepted 
will reduce unnecessary administrative burden. 
In conclusion, it seems fair to say that, as a voluntary instrument, a modified Ecolabel can 
have net economic benefits for the EU economy, and increase both competition and competitiveness. The Ecolabel therefore works with the market and – with its simplified 
approach – is a model "better regulation" policy instrument. 
                                                
 
43 Administrative costs are defined in the 2007 Commission Action Plan for Reducing Unnecessary 
Administrative Burden as "the costs incurred by en terprises…..in meeting legal obligations to provide 
information on their action or production". 
EN 51   EN Annex 
List of current product groups: 
Dishwashers 
Footwear 
Televisions 
Hard Floor Coverings 
Tissue paper 
Refrigerators 
Textile products 
Soil improvers 
Growing Media 
Paints and varnishes 
Copying and graphic paper 
Light bulbs 
Bed Mattresses 
Washing machines 
Dishwashing Detergents 
Laundry detergents 
Vacuum Cleaners 
Tourist Accommodation Service 
Personal Computers 
Portable Computers 
All-purpose & sanitary cleaners 
Hand dishwashing detergents 
Camp Site Services 
Lubricants 
Soaps, shampoos & hair conditioners