Opinion of the Economic and Social Committee on the "Green Paper on Integrated Product Policy"

(2001/C 260/06)

On 13 February 2001 the Council decided to consult the Economic and Social Committee, under Article 262 of the Treaty establishing the European Community, on the "Green Paper on Integrated Product Policy".

The Section for Agriculture, Rural Development and the Environment, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 21 June 2001. The rapporteur was Mr Pezzini.

At its 383rd plenary session (meeting of 11 July), the Economic and Social Committee adopted the following opinion by 108 votes to one, with three abstentions.

1. Introduction

1.1. The Committee is examining the Green Paper in connection with the Environmental Action Programme's(1) new approach which highlights, in tandem with implementation of the existing legislative instruments, the mainstreaming of environmental considerations in EU policies, involvement of the various stakeholders and the voluntary dimension. Further, the Committee regards this Green Paper as an auxiliary instrument for the "sustainable development" strategy, also from the economic and social angle(2). It would refer to the comments made in its opinions on related subjects, pointing out that this instrument can only be implemented satisfactorily in this broader context.

1.2. The Green Paper on Integrated Product Policy (IPP) proposes a strategy to strengthen and refocus product-related environmental policies with a view to promoting the development of a market for greener products (see 1. Introduction).

1.3. The proposed approach is based on a wide mix of instruments but does not go into the details of the link-up between the new IPP paradigm and existing environmental policies organised along sectoral and vertical lines. IPP is instead defined as being "complementary" to existing legislative instruments; further study is needed of the interaction between vertical regulation and voluntary instruments or agreements so as to ascertain whether the latter could be deployed in the absence of relevant legislative instruments and be geared to more ambitious "green" solutions than the current rules and standards. The Committee would point out that it has in the past made suggestions to this effect with a view to improving the environmental performance of products and services, notably in its opinions on the "eco-label", the "Community eco-management and audit scheme" (EMAS) and, most recently, the directive on "waste electrical and electronic equipment"(3). Point 2.3 of this last opinion pointed out that the eco-label and EMAS could serve a useful purpose in encouraging more advanced solutions than those envisaged in the directive.

1.4. The hearing organised by the Commission on 8 and 9 March showed clearly that the United Kingdom, Germany, the Netherlands and Denmark are forerunners in the field of IPP, often on the initiative of their national environmental agencies, while other Member States have more limited experience. Difficulties therefore arise in devising a European reference framework and disseminating experiences geared to the differing situations; support mechanisms must be devised for the dissemination of good practice, involving organisations representing businesses, especially SMEs.

1.5. Further, the examples given all relate to the industrial sector whereas the mainstreaming exercise could perhaps be extended to other sectors, especially as the scope of the EMAS(4) regulation on environmental certification has already been enlarged and the services, tourism and agri-food sectors are now fully involved in a drive to update environmental standards and to define sustainability indicators.

2. Role of stakeholders and local initiatives

2.1. The Green Paper highlights the role of the various stakeholders and the importance of local initiatives in meeting the challenge to produce greener products (see chapter 3).

2.2. In this connection the Committee would stress the importance of adopting measures to educate and train stakeholders, partly with a view to fostering a sense of responsibility among businesses in the adoption of IPP.

2.3. Consumers, NGOs, industrial firms and retailers are listed among the stakeholders bearing most responsibility for developing the IPP process. It is worth noting that no mention is made of workers' representatives, whose contribution is vital to the debate on the changes needed in production cycles. Bearing in mind the thrust of point 1.5, efforts must also be made to boost participation by the services, tourism and agriculture sectors, especially in terms of rural development.

2.4. Product panels (see point 4.3.4) composed of stakeholders, and based on the Danish model, are a suitable tool. However, there is no indication as to what authority or legal basis is required to set up a specific product panel, once it has been ascertained that broad consensus exists regarding the proposed subject to be studied. It is presumed that businesses will conduct this exercise but to avoid it remaining limited to large businesses, it is essential to involve SME and workers' representative organisations. The Commission's proposal is also unclear regarding how to proceed if a panel, on concluding its work, fails to reach agreement. On the other hand, small panels could be envisaged, bearing in mind at all times that such bodies must promote, and not impede, innovation.

2.5. There is probably a need to step up tried and tested forms of partnership, along the lines of the dialogue conducted within the ESC, so as to draw on lessons learned in the field of dialogue and stakeholder participation and avoid discrimination regarding the level of involvement and participation among the various parties involved. Existing partnership schemes (standardisation, product labelling and environmental assessment) and spatial planning arrangements (local agenda 21 programmes, Leader Plus, in support of rural development) would seem best suited to provide the necessary stimulus.

2.6. Unless they are coordinated within a specific reference framework (regional and/or rural development, research and innovation for SMEs, cohesion policy, and so on) and receive support at the preparatory, adoption and dissemination stages, local initiatives will find it hard to be the "major building block" for IPP claimed by the Commission.

3. Strategy to implement the IPP approach

3.1. In the Commission's view, improving the environmental quality of goods and services presupposes exploiting market forces to the full and applying the "polluter pays" principle (point 4.1). Here an incentive scheme could be considered to encourage those who, in contrast, undertake to take voluntary action to consistently improve environmental performance, viewed as a means of giving a competitive edge.

3.2. The Commission accurately states that the environmental performance of products can be optimised by the market if prices reflect the true environmental costs of products during their life cycle. Here the Green Paper points to the need to draw up objective criteria for evaluating the environmental performance of products.

3.3. Here again the document is vague when it comes to specifying who is to be responsible for framing and proposing these criteria, and how and when this is to be done. In addition, taxation, fuel taxes and charges are the tools indicated as examples of possible factors for incorporating the true environmental costs of products. The single example of a selective approach to the problem would seem to be the proposed reduction of VAT rates on products carrying the European eco-label.

3.4. The Green Paper is therefore once again advocating broad tax instruments which have consistently generated controversy in an environmental context and have proved ineffective in substantially curbing the environmental impact of production activities.

3.5. The suggestion of "reducing as far as possible" the subsidies currently available to encourage products and methods of production which are harmful both to the environment and to human health should instead become a priority mandatory obligation. The withdrawal of these "perverse" subsidies, in a drive to target state aids on environmentally friendly processes and products, would in itself be a major step forward in refocusing the Community economy on sustainable development.

3.6. However, in view of the Green Paper's stress on the importance of the eco-label scheme in developing IPP, it would seem logical to suggest, at least as concerns the framing of criteria for evaluating the environmental performance of products, that full advantage be taken of the experiences of the EU eco-labelling Board (EUEB) set up further to the Commission decision of 10 November 2000.

3.7. The Committee observes that debate has started on the interaction between product standardisation and environmental policies, the binding force of such standards and involvement of stakeholders in framing them. The issue is highly complex. The Commission is therefore encouraged to study the matter in depth and to suggest points for future discussion.

4. Green consumer demand

4.1. Green consumer demand will be a major driving force in persuading industry to step up environmental efforts and improve the life cycle performance of their products and services (point 4.2.1).

4.2. Promotion of environmental information by business and stimulating greater demand for environmentally friendly products among consumers are the two key components of "informed consumer practice", which the Commission views as a pillar of IPP.

4.3. Here again the introduction of environmental labelling along the lines of ISO and the eco-label is specified as a key measure in supporting IPP. However, the Commission acknowledges that these schemes are complex and have not yet exploited their full potential to influence the market. Here the Commission announces its intention to review its own eco-labelling strategy so as to broaden its scope to cover as many products as possible. More detailed information must also be provided on products with a consumer guarantee.

4.4. The reference to adoption of different systems of environmental labelling (including green claims and self-declarations) prompts certain reservations owing to the need to provide for further instruments and monitoring mechanisms at national level to assess their validity.

4.5. In this connection, it should be remembered that the ESC, in its opinion on the new eco-label Regulation(5), expressed its opposition to the "proliferation" of green labels because they could generate confusion in consumers and prove misleading.

4.6. Consumer information procedures and education campaigns organised by consumer organisations make a vital contribution in this sphere.

4.7. Public procurement is another major tool in promoting green products and services (see point 4.2.2); the ESC has already stated its views on this subject, notably in its opinion on EMAS (points 2.1.2 and 2.1.3), where it calls for public authorities to play a catalyst role in prioritising sustainable products.

5. Information on product life cycles

5.1. The Commission stresses the need (point 4.3.1) for information on the life cycle environmental impact of products and components.

5.2. Life Cycle Analyses (LCAs) are the main instrument in developing IPP. The Commission recognises the complexity of such assessments and the relatively high costs of adoption. It therefore recommends the setting up of publicly available databases to collect the fullest possible information on product lifecycles which can be of use to designers, manufacturers, retailers and consumers for the purposes of evaluating the environmental impact of products. The European Environment Agency (EEA) and national environment agencies will play a leading role in the compilation and circulation of these databases, taking care to ensure that all links in the production chain, in particular the workforce, are asked to contribute.

5.3. One possible way of increasing the generation and availability of data is to encourage and where appropriate require, producers to supply key data along the product line and to consumers.

5.4. Bearing in mind the differing and complex structures of the EU economy and the additional costs SMEs will obviously incur in developing and adopting LCAs, the emphasis should essentially be on encouraging the dissemination of information by and for SMEs, especially at local level or zones in which similar types of production activities are concentrated.

5.5. The adoption of guidelines for eco-design is also an important factor in gradually moving towards more environmentally friendly production.

5.6. The Green Paper seems to underplay the fact that the adoption of such vitally important measures as LCAs and eco-design necessitates major financial and managerial efforts. Concurrently they are a key factor in stimulating research and innovation.

5.7. Stronger action is therefore called for in promoting policies to support research and innovation tailored to SMEs; these should focus on disseminating information and on framing innovative processes to develop greener products. The tools currently available are underfunded and it is difficult for companies to trace and access them.

Brussels, 11 July 2001.

The President

of the Economic and Social Committee

Göke Frerichs

(1) COM(2001) 31 final; Committee opinion OJ C 221, 7.8.2001.

(2) Committee opinion on the Preparation of a European Union Strategy for Sustainable Development-OJ C 221, 7.8.2001.

(3) OJ C 296, 29.9.1997, p. 77; OJ C 209, 22.7.1999, pp. 43-44; OJ C 116, 20.4.2001, pp. 38-43.

(4) OJ L 114, 24.4.2001, pp. 1-29.

(5) Point 3.2.4, OJ C 296, 29.9.1997, p. 77.