COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE - Integration of Environmental Aspects into European Standardisation {SEC(2004)206}

1. INTRODUCTION

The majority of goods and services around us have now been standardised, although this goes largely unnoticed in most cases. Standards are unseen forces that ensure that things work properly.

In the European standardisation system, standards have developed in areas where the stakeholders concerned have identified and pursued common interests in the definition of technical solutions. A main driver for the development of European standards is their uniform applicability throughout the European Single Market, as they replace national standards. Wherever possible, they are also based on international standards, which facilitate international trade. An extra incentive for the creation of European standards has been, for some product areas, a harmonised and stable legal framework that allows European standards to develop technical solutions to demonstrate compliance with the law.

Box 1: The European Standardisation System

The European Standards Organisations are CEN [1] (European Committee for Standardisation), CENELEC (European Committee for Electrotechnical Standardisation) and ETSI (European Telecommunication Standardisation Institute). Directive 98/34/EC [2] recognises these bodies for the development of European standards. It also gives a definition of a European standard. The principles of relationship and cooperation between CEN, CENELEC, ETSI and the European Commission and the European Free Trade Association are laid down in general guidelines. A revised version of these guidelines was adopted on 28 March 2003 (OJ C 91 of 16.4.2003).

[1] http://www.cenorm.be; http:// www.cenelec.org; http://www.etsi.org

[2] Directive 98/34/ EC of the European Parliament and of the Council laying down a procedure for the provision of information in the field of technical standards and regulations

Standards contribute to economic and social development. Because they may define how a product is made, used, maintained and treated at the end of its life, or because they help to sample, test and analyse products or materials in relation to their environmental behaviour or conditions, standards can have a substantial influence on the way products and services impact on the environment. While requirements set out in technical regulations are mandatory, there are many thousands of technical standards that are developed voluntarily by companies, by ad hoc structures like forums and consortia, or under the umbrella of formal standardisation bodies. The stakeholders involved in these processes have already invested and will continue to invest significant resources in terms of experts' time, technical know-how and meeting expenses. Standards, as voluntary tools, are crucial and it is vital that all the stakeholders involved in their development maximise their potential and thus enhance their role in protecting the environment.

2. AIM AND SCOPE

Sustainable development is a priority for the EU, and it strives to achieve a balance between economic, social and environmental considerations [3]. European standards often deal with aspects of trade, quality, health and the safety of products, processes or services. By additionally considering environmental aspects, European standardisation could make a positive contribution to sustainable development and the relevant implementing policies, such as the Integrated Product Policy (IPP) adopted by the European Commission [4]. There are also a growing number of European standards for test and measurement methods, which contribute to the implementation of environmental policies.

[3] COM(2001)264 final. Communication from the Commission - 'A sustainable Europe for a better world: A European strategy for Sustainable Development'

[4] COM(2003)302 final. Communication from the Commission to the Council and the European Parliament - Integrated Product Policy - Building on Environmental Life-Cycle Thinking.

Standardisation stakeholders should take the further steps needed to systematically integrate the relevant environmental aspects into European standards making. Therefore, those conditions needed for European standardisation to make a positive contribution to the protection of the environment merit closer attention.

During the different stages of the development of this document, several consultation exercises took place [5]. A multi-stakeholder meeting was held on the 17th July 2002, a further meeting was held on 16 July 2003. An internet consultation then ran from 25 July to the 15 September 2003. These initiatives were aimed at all stakeholders in the standardisation system and contributions were received from business and industry, NGOs, public authorities and standards organisations themselves. The feedback obtained helped to focus in on the key issues of the subject and assess if a Communication was an appropriate policy instrument to achieve progress.

[5] http://www.europa.eu.int/comm/enterprise/ standards_policy/environment_standardisation/ stakeholder_meeting/2003/consultation_stakeholders.htm

The results showed that nearly all stakeholders felt that a Communication would be a useful contribution which would help them in their work. Furthermore, a number of common themes emerged which showed a consensus on where progress was most likely to be made. In particular, four key issues were identified, so these are specifically dealt with in this Communication:

- raising awareness and environmental thinking;

- setting priorities;

- enhancing stakeholder participation;

- using tools and offering incentives.

The European standardisation system and its stakeholders are invited to reflect and act on these issues with a view to advancing the standardisation system and to making it more responsive to the environmental dimension while still respecting all other dimensions of sustainable development. The stakeholders addressed in this communication are:

- European standardisation organisations and their national members;

- national public authorities;

- industry and business associations, including representatives of small and medium-sized enterprises (SMEs);

- non-governmental organisations (NGOs), and

- scientific organisations.

The Commission invites the European Parliament and the Council to endorse the key issues and objectives set out in this Communication.

3. POLICY FRAMEWORK FOR THE INTEGRATION OF ENVIRONMENTAL ASPECTS INTO EUROPEAN STANDARDISATION

3.1 European Policy Framework

The EC Treaty aims at a harmonious, balanced and sustainable development of economic activities and a high level of protection and improvement of the quality of the environment [6]. It reinforces the principle of the integration of environmental requirements into other policies, recognising that it is one of the keys to sustainable development [7]. The Community seeks a coherent approach to the pursuit of its objectives in relation to the Single Market and the environment, whilst also honouring its international obligations.

[6] Article 2 of the consolidated version of the Treaty establishing the European Community

[7] Article 6 thereof

European Standardisation is a tool that has been used frequently in the implementation of Community policies [8]. Consequently, there has been an increasing focus on the role it can play in protecting the environment and supporting sustainable development.

[8] For an overview of sectors using European standards to implement policy see COM (2001) 527 final or visit the website: http://europa.eu.int/comm/enterprise/ standards_policy/index.htm

In many policy documents the Council and the European Parliament have pointed out the wish and need to consider environmental aspects in standardisation [9]. This has been taken up in the aforementioned IPP Communication where standardisation was considered to be a potential tool for reducing the environmental impacts of products and services, from the mining of raw materials to production, distribution, use and waste management. One way that IPP is being put into practice is through the recently adopted proposal [10] for setting Eco-design requirements for Energy-Using Products. European standards could be very helpful in establishing methods for measuring or, in some cases, better describing environmental parameters relevant for those products.

[9] e.g. European Union Strategy for Sustainable Development: follow-up to the environment-related aspects of the European Council of Gothenburg - Council Conclusions, document 15280/01

[10] COM(2003)453 final. Proposal for a Directive of the European Parliament and of the Council On establishing a framework for the setting of Eco-design requirements for Energy-Using Products and amending Council Directive 92/42/EEC

The Commission specifically proposed the promotion of the integration of environmental protection requirements in standardisation activities in the Sixth Community Environment Action Programme [11] adopted by the Council and the European Parliament in 2002.

[11] Decision No 1600/2002/EC of the European Parliament and of the Council of 22 July 2002 laying down the Sixth Community Environment Action Programme, OJ L 242, 10.9.2002, p. 1 - 15

In the same year, the Commission announced the development of a paper (i.e. this Communication) on standardisation and the protection of the environment [12]. The Council welcomed this intention in 2002 [13].

[12] COM(2001) 527 final report from the Commission to the Council and European Parliament on actions taken following the resolutions on European Standardisation adopted by the Council and the European Parliament in 1999

[13] Council Conclusions on standardisation of 1 March 2002, OJ C 66, 15.3.2002

3.2 European standardisation, European legislation: distinct roles

European standards are voluntary documents developed under open and transparent procedures which are managed by the European or international standards organisations. Standardisation work is carried out by and for the relevant stakeholders themselves, on the basis of the consensus principle. This principle also applies to the environmental aspects that are discussed in the process of standards development.

Furthermore, there are areas and aspects where legislation is the best way to ensure that public objectives such as the protection of health, safety or the environment are achieved in a transparent and enforceable manner, involving the institutions invested with democratic legitimacy.

Standardisation and legislation are two different tools, which can offer, in some cases, two options to address environmental issues. They can also be complementary processes as standardisation can support the regulatory approach. Standards can provide solutions to complex technical problems and therefore offer advantages. Stable legal framework conditions can be created if legislation is kept performance-oriented and technical details are dealt with by voluntary standards. This means that a predictable framework for standardisation to deliver the expected results is needed. Nevertheless, in order to maximise the benefits of this complementary relationship, it is essential, when developing legislation, to follow rules for better regulation and to carry out an impact assessment. This kind of impact assessment could also expand on the potential role of standards in relation to the planned legislation. If standards are developed in a way that makes an effective contribution to environmental protection, this will have to be taken into account when developing regulations or when considering de-regulation and appropriate voluntary tools.

3.3 International Dimension

Trade has been a main driver for standardisation since ancient times. From a global perspective, more and more issues require global technical solutions and, in particular, internationally traded goods need international standards whenever possible. The multilateral trading system established under the WTO, and in particular its Agreement on Technical Barriers to Trade (TBT) stipulates the use of voluntary international standards as a basis for mandatory technical regulations for goods. The WTO rules respect the sovereign right of each member to define the level of protection deemed appropriate to meet legitimate objectives such as the protection of health and the environment, subject to not applying them in an arbitrary or discriminatory manner. Hence, WTO members do not need to use international standards if they are ineffective or inappropriate for the fulfilment of legitimate objectives. This rationale builds on the paradigm that essential protection requirements (legitimate objectives) should be defined by legitimate public authorities whilst recognising that technical solutions for the fulfilment of such objectives should preferably be developed by the private stakeholders themselves in international standards.

Due to associated benefits in terms of trade, market access and dissemination of technologies, European standardisation is closely linked to international standardisation. Consequently, European standards are based on international standards if international standards are available and if they meet European needs [14]. A significant part of CEN standards are taken over from the International Standardisation Organisation (ISO) and the majority of the output of CENELEC is developed in the International Electrotechnical Commission (IEC). Via the agreements concluded between the European and international standardisation organisations, there is also the possibility that European standards may be offered to the international standardisation organisations for adoption as international standards. Consequently, European leadership in dealing with the environment, or in integrating environmental aspects into existing standards, can result in relevant international standards.

[14] SEC (2001) 1296 European policy principles on international standardisation

4. DEVELOPMENTS IN EUROPEAN STANDARDISATION

European standardisation has undergone several developments that have helped to increase its potential to be a useful tool to protect the environment.

4.1 Growing number of European standards

Firstly, the growth in the number of European standards has been considerable. At the time of writing, CEN offers some 7 000 European standards, in a vast range of sectors. In the electro-technical field, there are some 3 300 European standards from CENELEC, most of which are based on the international standards of the International Electrotechnical Committee (IEC). In the telecommunications area, ETSI offers about 3 200 standardisation documents (ENs and ETSs) to its users. Some 1 200 European Standards (ENs) are published every year by these organisations. In 2003, approximately 13 500 European standards existed.

4.2 Growing range of sectors using European standards

The scope of issues dealt with by European standardisation has also increased in importance. Standards developers currently touch upon issues that are environmentally sensitive, such as product design, energy efficiency, solutions for end-of-life stages of parts and components, and technical / management processes. On top of that, there is a growing demand for environmental test and measurement methods.

4.3 Growing take-up in European legislation

In support of the EC's New Approach [15] directives for certain product areas, 2 165 harmonised standards have become voluntary solutions to demonstrate compliance with the legal requirements. The incentive to define voluntary solutions for compliance with the law requires European Standardisation Organisations to respect certain principles of accountability, such as national enquiry and voting and the representation of stakeholders in the standardisation process. New Approach directives could also be used to develop environmental policies, which has not really been the case so far.

[15] Council Resolution of 7 May 1985 on a new approach to technical harmonisation and standards (OJ C136 of 04.06.1985) - see http://europa.eu.int/comm/enterprise/ newapproach/legislation/guide/legislation.htm

4.4 Standards and the environment

Standards are tools for the dissemination of technical knowledge. Today, there are already many European standards that either directly deal with the environment or that take environmental aspects into account. Their use should be encouraged.

4.4.1 Environmental dimension of product standards

Product standards (i.e. those defining requirements for products) form a major part of the 13 500 European standards that exist today. These standards can set important criteria for products, such as their integral safety and dimensions to help ensure correct interfacing with other components. Waste and incompatibility of components is avoided and the resulting cost benefits can be passed on to consumers. Standards which appropriately take the environmental aspects of a product into account can help to minimise any negative environmental impacts of those products.

Increasingly, product standards which deal with key parts of product life cycles are emerging. Some standardisation documents [16] focus on integrating environmental aspects into product design and development and aim to help companies understand the reasoning and practicalities of eco-design. Also, there are a growing number of standards which help to deal with the end-of-life phase of products.

[16] e.g. ISO TR 14062: Environmental management - Integrating environmental aspects into product design and development

These types of dedicated environmental standards (or guides and reports etc) for products can deal solely with the environmental aspects and/or performance of a product if necessary. Their use might prove increasingly important for the future. They have the benefit of being produced by standardisers with specialized knowledge on environmental issues, thus avoiding prioritising certain environmental aspects to the detriment of others.

4.4.2 Test methods for environmental purposes

The implementation of Community directives and regulations sometimes requires the development of standardised test methods, for example, for pollution measurement, pollution control and water analysis. Such standards enable the consistent implementation and enforcement of legislation throughout the European Union. Without standardised methods of measurement there would be no compatibility/comparability between environmental quality data gathered throughout the EU.

Box 2: Test method for sludges

The Commission has given a mandate to CEN for the development of horizontal standards for sludge, biowaste and soil needed to implement existing and upcoming EU Directives. The aim is to have only a few standards which can be used within the framework of several directives. For example, a horizontal standard to test for potassium content could be used to test potassium levels in sludge or soil or biowaste.

4.4.3 Environmental technologies

In the process of creating the action plan for environmental technologies [17] the Commission has found that standards may increase their take-up. The level of performance specified in the standard can have a great impact on the market for environmental technologies.

[17] These are defined as all technologies whose use is less environmentally harmful than relevant alternatives. COM(2004)38 final. Communication from the Commission. Stimulating Technologies for Sustainable Development: An Environmental Technologies Action Plan for the European Union

Energy use, for instance, is an area where European standards are helping to provide environmental benefits. For example, there are European standards projects dealing with the energy efficiency of electrical and gas appliances. In order to benefit the consumer, standards are developed which help to measure the performance of appliances. The relevant information on a device's energy use is displayed on a so-called energy label. This enables European consumers to make informed choices.

Some standards have environmental benefits which are not immediately obvious. A good example of this is the standard for measuring the mesh sizes of fishing nets [18]. These will allow different countries to enforce international regulations and protect fish stocks. It is also argued that standards which are developed to support initiatives such as Intelligent Transport Systems will have environmental benefits as they will potentially contribute to the reduction of traffic and its negative environmental impacts.

[18] EN ISO 16663 Fishing nets - Method of test for the determination of mesh size.

Box 3: Combined Heat and Power or Micro-cogeneration

Micro-cogeneration is the simultaneous development of heat and electricity that can be done on site in buildings that need it. Once available, the European standards will help this technology further into the market.

4.4.4. Environmental management standards

Environmental management is another example of a domain in which standards are needed for the sake of the environment. An Environmental Management System enables an organisation to assess, organise and continuously improve the impact of its activities, products or services on the environment. Consideration of the environment within organisations needs to be done in the same systematic way as quality assurance, and therefore environmental management system standards, such as EMAS [19] and EN/ISO 14001, are useful tools.

[19] Regulation (EC) No 761/2001 of the European Parliament and of the Council of 19 March 2001 allowing voluntary participation by organisations in a Community eco management and audit scheme (EMAS); OJ L 114, 24.4.2001, p. 1. For more info see http://www.europa.eu.int/comm/environment/ emas

ISO 14000 is an internationally recognised series of standards for environmental management. The environmental management system standard ISO 14001 has also been adopted as a European standard (EN ISO 14001). Other parts of the ISO 14000 series deal with issues such as life cycle assessment (ISO 14040), environmental performance evaluation (ISO 14030), and environmental labels and declarations (ISO 14020). The standards of the 14000 series are management standards that do not apply to a specific sector or business type, but offer guidance on the fundamentals of environmental management, such as definition, goal and scope setting.

EMAS incorporates EN ISO 14001: 1996 as its basic management system but also goes beyond it. Some of the major differences are that EMAS requires legal compliance, a continuous improvement of environmental performance, an involvement of employees and the publication of an environmental statement (including information about the company and its environmental impacts). Moreover, it is a public system under the control of the Member States

5. KEY ISSUES

5.1 Environmental thinking

Care for the environment, optimal use of resources and efficient energy consumption have grown in importance amongst economic operators, customers and public authorities. Standardisation as a vehicle to implement business activities should be receptive to the need for environmental thinking, even though it is never the standards themselves that have an impact on the environment, but rather the products, processes and services covered by those standards. Depending on the way a standard is written, the provisions included and those omitted, the environmental impact of the issue to be standardised is to a large extent determined. Consequently, the experts writing or revising the standards need to be aware of environmental considerations and possible environmental impacts. A lot will depend on the environmental expertise available in the standards development process, and the willingness to take environmental issues systematically into account. The aim of this Communication is to promote awareness-raising activities and an exchange of expert knowledge and good practice, so that standards can contribute to a better environment and hence to sustainable development. Efforts at European level will need to be complemented at national level.

5.1.1 Commitment to taking the environment into account

Taking the environment into account must become a commitment for all stakeholders and technical experts involved in the process of creating standards. Raising environmental awareness is often a slow and difficult process because of the sheer number of stakeholders involved, as well as the rapid rate of change in environmental know-how. Continuous efforts are needed from all stakeholders, including European and national standards organisations, public authorities, industry and business. In particular, stakeholders representing big business can play a vital role in the production and use of environmental standards due to their relationships with their suppliers and business partners. Also, environmental awareness is an issue they are likely to consider in the context of their corporate social responsibility or their shareholder relations. They should also ensure that any statements they make in favour of the environment or publish in environmental declarations are reflected in the work carried out by their own experts in their standardisation activities. Many organisations, especially NGOs, are already active in raising awareness among their members of the environmental aspects of standardisation. However, this kind of commitment varies enormously across the EU and the acceding countries.

5.1.2 Consideration of possible environmental impacts from the beginning

There is no single or simple answer to the question of how to proceed in order to take the environment into account in European standardisation. The first step, naturally, should be to find out how the standard may impact on the environment. Consideration of the possible environmental impact of standards does not necessarily trigger complicated and time-consuming research or study activity, nor does it mean that a life-cycle assessment needs to be carried out to come to a satisfactory assessment. Obviously, it is better to take the environmental dimension into account from the very first stage than to revise a standard later on. Therefore, what matters is a systematic approach to increase environmental thinking at all stages of the standardisation process, which should then lead to concrete improvements.

Aspects such as energy and material consumption, emissions to air and water and soil are examples of environmental impacts that should be taken into account in standards development. Equally, measurable and objective issues like the release of hazardous substances, risks to the environment from accidents or misuse, waste, and noise creation should be considered if relevant. Also, standards for measuring eco-efficiency or emissions of pollutants have a crucial role to play in strengthening the environmental dimension of product standards. The results of an early appraisal of environmental impacts of this kind could be useful to standards users. This is why relevant material on which environmental aspects have been considered and at which stage (during the development of a European standard) should be made available in an appropriate format.

5.1.3 Consideration of possible environmental impacts at the revision stage

Adverse environmental impacts might be significantly reduced by the application of new knowledge. Because the rate of innovation, not least of environmental innovation, is high, the reviewing of standards on a regular basis is essential. Standards are generally reviewed every five years. The regular review process is an appropriate trigger to start looking into the environmental aspects of already existing standards. During such revision procedures, environmental aspects should be considered systematically, just as at the start of the development of new standards programmes or projects, and made accessible in an appropriate format.

5.1.4 Training

Two types of training could potentially facilitate the integration of environmental aspects into the European standardisation process.

Firstly, knowledge about the potential environmental impacts of certain materials, processes or functions needs to be accessible to all technical experts participating in the European standardisation process. Secondly, although the standardisation process is open and transparent, it can be seen as over-complex to an uninitiated audience - even one with sound and appropriate environmental knowledge. Training for such stakeholders could help them to find out how to have their voice heard at national and European level. Access to standardisation-relevant environmental information can be of benefit for all stakeholders and has the potential to strengthen the quality of standards by improving the dissemination of technical know-how. Training on the functioning of the standardisation process can help to promote mutual understanding between stakeholders with different interests.

Future training activities at European and national level should be developed jointly with all the relevant stakeholders and should be based on the experience gained so far.

5.2 Setting priorities

Considering the substantial number of ongoing standardisation projects, the high costs of taking part in the standardisation work and the often scarce resources of stakeholders, there is a need for prioritisation. Stakeholders could draw on many different elements to set their priorities, these ranging from stakeholder needs (industry and public) to the implementation of European legislation and policies (for example, those coming from the ratification of international agreements such as the Kyoto Protocol). The 6th Environment Action Programme and the annual Commission's legislative work programme present the main priority issues and can provide tools to anticipate and prioritise standardisation activities and environmental considerations.

5.2.1 Priority setting by the European Standardisation Organisations: work programmes

A simple methodology is needed to identify standards programmes or projects which could affect the environment. It would allow stakeholders to efficiently allocate their resources to standards projects of real interest and potential benefit to them. Such a system could also be used to attract technical comments, support and expertise. For instance, work programmes and business plans of technical committees and working groups operated by the European Standards Organisations could provide an indication of how their work relates to environmental aspects.

5.2.2 Priority setting by the Commission: mandates

One instrument that the Commission can use to flag priorities for European standardisation work is the European standardisation mandate. Mandates are used to initiate European standardisation activities in relation to policy goals, particularly in regard to New Approach directives which can deal with the free circulation of goods and services in the internal market. They can also be issued in areas requiring specific environmental standards or in support of EU environmental policy.

The Commission has been stressing for some years that where mandates are given, it is important to integrate essential issues, such as the protection of safety, health and the environment [20]. Accordingly, the Commission needs to ensure that standardisation mandates invite a proper consideration of environmental aspects in standards development whilst still respecting other policy areas such as the free circulation of goods in the internal market. In the preparation of a mandate, if appropriate, a preliminary assessment of different environmental, health and safety issues could add value. Finally, the mandate should also set out environmental requirements in such a way as to allow for an assessment on whether the required environmental consideration has been successfully carried out or not.

[20] COM(1998)291 final, p.11. Report from the Commission to the Council and the European Parliament - Efficiency and accountability in European standardisation under the new approach.

Specific mandates in support of EU environmental policy are also useful. A specific instrument the Commission uses to invite for the setting of priorities in European standardisation work is the so-called programming mandate. For example, the Commission has issued a programming mandate in support of the future directive on the eco-design of energy-using products.

5.3 Stakeholder participation

The acceptability of standards depends to a large extent on the involvement of all stakeholders. The participation of civil society (e.g. stakeholders representing consumer, health, safety and environmental interests) in standardisation reinforces the quality of consensus and makes the standards more representative and thus acceptable for use by the stakeholders themselves, and, if appropriate, by the authorities. The scientific community should also be involved in order to make sure the standards take latest scientific developments into account. At the political level, the Council has stressed the importance of involving all interested parties by inviting them to participate actively in the development of European standards and to contribute to the management of the standardisation process [21]. Of course, contributions to the programming of European standardisation require a legitimate capacity by representing a constituency nationally and at European level.

[21] Council Resolution of 28 October 1999 on the role of standardisation in Europe; and Council Conclusions on standardisation of 1 March 2002

Virtually all standards organisations (national and European) have declared their openness to the involvement of new stakeholders in the standardisation process. In practice, however, effective participation in the standards development process largely depends on the capacity of any interested party to provide technical input and to earmark resources for such work.

5.3.1 The national dimension

The participation of environmental stakeholders in standardisation is very important, particularly at national level. The national delegation principle offers stakeholders the possibility of both participating in standardisation activities without extensive travel and to express technical comments in their own language. Achieving consensus between stakeholders at national level followed by the establishment of consensus between national positions generally results in standards that are regionally or internationally accepted.

Some stakeholder groups experience practical difficulties in participating in standardisation. These groups include environmental NGOs, consumer representatives, representatives for occupational health and safety matters, and SMEs. A lack of financial resources and technical expertise may hamper their participation. However, as they constitute a public interest dimension in standard-making and because they can improve the acceptance of standards by their users, their participation should be subject to public support.

Likewise, national public authorities should participate more actively in the standardisation process. A dialogue between the various (national and local) authorities involved may facilitate the integration of environmental aspects with health and safety and economic considerations.

It is also important that the consensus achieved between all the stakeholders at national level is documented and presented as a single, consensual position at European level. Exchanges of experience and best practice between Member States should be organised. They should highlight the representation of environmental interests at national standardisation level, the support granted to the relevant stakeholders and the involvement of national authorities in standardisation. Working on the basis of national activity reports, the Commission, together with the Member States, could then review the progress made.

5.3.2 The European dimension

The European standardisation process in CEN and CENELEC is based on national delegations and it is important that the national delegations take forward positions that comprise the views of all stakeholders participating at national level. Since the current participation of environmental stakeholders was deemed as unsatisfactory, the Commission has awarded a service contract [22] to ECOS (European Environmental Citizens Organisation for Standardisation), a consortium of environmental organisations. ECOS aims to express environmental interests in the European standardisation process and to ensure that these are considered. At European level, ECOS will have an important role to play by:

[22] 'Service contract for the integration of environmental requirements in the European standardisation process' OJ 2002/S 173-137828

- attracting new members among NGOs participating in standardisation at national level;

- establishing a network of experts and working procedures that achieve co-ordination with, and transparency amongst, the ECOS members, thus better influencing the decision-making process at national level;

- establishing a technical work programme and identifying the technical committees where they want to participate in standardisation activities;

- training experts and appropriate staff on standardisation principles and procedures;

- ensuring participation of their experts in the technical committees and working groups identified in their work programme.

ECOS started work in November 2002. Applications for associate membership with CEN and for social and economic partner status in CENELEC are under way. After an initial phase, the Commission expects ECOS to play a significant role in the integration of environmental issues into standardisation and intends to support it further in its activities.

The European Commission attaches great importance to the full involvement of all stakeholders in the European standardisation process and has already ensured representation of consumers (ANEC), workers (TUTB) and small and medium-sized enterprises (NORMAPME). These groups have attained associate membership or equivalent status within the European Standardisation Organisations.

6. TOOLS AND INCENTIVES

The European Standardisation Organisations have already developed a number of useful tools which can directly help with the integration of environmental aspects into standardisation. Their further development and systematic use are promising and should be encouraged. To enhance the market relevance of standards, it is also important that standards users such as manufacturers, procurers and consumers indicate which environmental aspects they want.

6.1 Existing tools

Working groups dedicated to the environment

Some European standardisation organisations have established special groups for the environment. They tend to function as environment-oriented discussion platforms for experts, where recommendations can be drawn up for strategy development. The CEN Strategic Advisory Board for the Environment (SABE) [23] and the CENELEC Working Group of the Technical Board "Environmental Standardisation" (BTWG 85-3) [24] are good examples of this.

[23] http://www.cenorm.be/cenorm/workarea/ advisory+bodies/strategic+advisory+board+for +the+environment/index.asp

[24] http://www.cenelec.org/Cenelec/ About+CENELEC/Our+strategy/Environmental+strategy/default.htm

The CEN Environmental Helpdesk

CEN has established a service function for environmental issues, the CEN Environmental Help Desk (CEN EHD) [25] , which gives technical advice to standards writers through networks of environmental experts. The CEN EHD is financially supported by the Commission.

[25] http://www.cenorm.be/cenorm/workarea/ advisory+bodies/environmental+helpdesk/index.asp

Environmental database

An environmental database could be used to enhance transparency and to disseminate information about environmental considerations. The use of databases can help to collect relevant information on potential environmental aspects for materials, products or processes (for example technical information needed to calculate emissions of pollutants or energy consumption). Easy access to such information helps to facilitate the uptake of environmental knowledge and can help to avoid duplication of costs. Of course, such databases take time and resources to create and maintain. In particular, the information they hold needs to be agreed upon and validated.

CENELEC has recently developed an Environmental Database that will pool all environmental aspects dealt with by CENELEC and will help to give access to environmental knowledge.

Guides and checklists

There are also a number of environmental guides and checklists which can help to show how environmental considerations can be integrated into standards. These are either general or specific to individual sectors; the latter are particularly useful because they are written by experts from the sector involved for experts from the sector involved.

Box 4 : Environmental checklists and guides

CEN Guide 4 - Guide for the inclusion of environmental aspects in product standards

CEN Guidance - Consideration of environmental aspects in standards, includes a matrix checklist to help perform an initial environmental assessment

ISO Guide 64 - Guide for the inclusion of environmental aspects in product standards

IEC Guide 109 - Environmental aspects - Inclusion in electro-technical product standards

IEC Guide 113 - Materials declaration questionnaires - Basic guidelines

ISO TR 14062 - Environmental management - Integrating environmental aspects into product design and development

6.2 Incentives for the systematic application of tools for the integration of environmental aspects

In standardisation, stakeholders give their time and expertise voluntarily. If they are to spend resources on the integration of environmental aspects, they will need the motivation to do so. This Communication therefore provides political acknowledgement of stakeholders' efforts towards more systematic integration of environmental aspects. There are many existing tools which can aid the integration of the environment into European standardisation. The real task ahead is to promote their systematic use. The Commission intends to disseminate best practice and to support tools that have already proved their effectiveness in the integration of environmental aspects. It issues an open invitation to stakeholders to present their ideas for incentives and to begin a dialogue on good practices and achieved results. Also, with an increasing number of European standards containing environmental aspects, their use for policy purposes by the Commission is likely to increase.

7. CONCLUSIONS AND THE WAY FORWARD

The Commission intends this Communication to raise awareness for the need to integrate environmental aspects into European standardisation, a voluntary, stakeholder-driven process.

The Commission hereby acknowledges that environmental aspects need to be integrated into European standards. However, it also stresses the importance of addressing environmental aspects in a balanced and appropriate manner and of properly taking into account the other reasons for which standards are written.

The Commission will now initiate ongoing discussions with stakeholders from the standardisation community in order to develop concrete actions. Indeed, two workshops are planned for 2004 and these will aim to gather ideas and establish projects to achieve progress in the following four areas:

- Awareness for the consideration of environmental aspects in European standardisation needs to be promoted among all stakeholders, in particular in the Acceding Countries. The exchange of expert knowledge and good practice can ensure that environmental aspects in standardisation are identified at an early stage of the development of new standards, or when existing standards are revised every five years. Training has been identified as a key issue to ensure that environmental stakeholders can effectively voice their views in the European standardisation process. Equally, the relevant environmental information needs to be gathered and disseminated to all technical experts participating in the process. For the way forward, the Commission invites ideas and proposals from stakeholders to engage them further in awareness raising and training activities. The Commission is prepared to earmark support for the European standards organisations, if appropriate proposals are presented. Member States are invited to envisage similar activities for the national standards organisations. The situation will be monitored in view of the relevant activities deployed and stakeholders will be invited to exchange experience with a view to identifying good practice. Because of resource constraints, priorities for the work on environmental issues in European standardisation need to be set. Due to the voluntary nature of the process, standardisation stakeholders should remain in control of their work priorities. However, public interest areas and issues relevant to European policy should also be taken into account. For the way forward, the Commission will consider, where appropriate, environmental aspects in the development of European standardisation mandates as well as specific mandates in support of environmental issues and for standards dedicated to the environmental aspects of products. The Commission will duly consult stakeholders when developing mandates. All stakeholders are invited to develop indicators so that standards that have satisfactorily integrated environmental requirements can be identified.

- The participation of stakeholders is crucial for the acceptability and relevance of standards. All stakeholders should be in a position to effectively participate in the development of European standards that are relevant to them. As the European standardisation process is based on national positions, it is important that Member States facilitate the participation of all stakeholders in the formulation of a national position. This then needs to be taken forward on the basis of a consensus at European level. At European level, stakeholder groups who can co-ordinate and develop public interest positions, such as in the environmental field, play an important role in effectively underpinning the national positions. For the way forward, the Commission invites Member States and Acceding Countries to help all stakeholders, particularly those representing societal concerns and public interests related to environmental matters, including public authorities, to participate in the standardisation process and to formulate consensual positions to be presented at European level as part of the standardisation process. The Commission invites the Member States and the Acceding Countries to regularly report on the different means of support granted. This is expected to promote the exchange of experience and good practice. At European standardisation level, the Commission will continue to offer support for European stakeholder groups that can play a role in the identification and co-ordination of environmental standardisation issues dealt with by the European Standardisation Organisations.

- The systematic use of tools for the integration of environmental aspects into standardisation needs to be put into practice. Stakeholders are encouraged to use the tools that have been developed for dealing with environmental considerations in standardisation. Increased use of such tools will enhance experience and it will increase the number of standards with an environmental dimension. This in turn will further increase the attractiveness of European standards for the purposes of policy support and legislation, including in the environmental field. For the way forward, the Commission invites stakeholders to report on how they have used the different tools they have to hand. Regular meetings to exchange experience and to agree on indicators for assessing progress can help to build up a growing number of European standards with an environmental dimension.

The Commission will continually assess the integration of environmental aspects into European standardisation in the light of progress made in the above four areas. For this purpose, regular stakeholder meetings and workshops will be organised at least once a year.

COMMISSION STAFF WORKING PAPER - Communication of the Commission on the Integration of Environmental Aspects into European Standardisation - Extended Impact Assessment {COM(2004)130 final}

TABLE OF CONTENTS

1. Problem identification

2. Main objective of the Communication

3. Policy options

4. Social, environmental and economic impacts of each policy option

5. Monitoring of results

6. Stakeholder consultation

7. Commission draft Communication and justification

ANNEX to the Extended Impact Assessment: Report on the Public Consultation

1. Problem identification

Standardisation is a voluntary process carried out by and for the stakeholders within the structures and rules of standards organisations. The resulting technical specifications are voluntary consensus documents that may define, for example, how a product is manufactured used or disposed of.

In recent years, the number of European standards has grown significantly - the total number of European Standards is estimated at 13,500. The interest in European standards and this increase in numbers can be explained by the fact that standards play a positive role in the economy as they reduce transaction costs, facilitate trade, increase competition, and channel innovation. Moreover, European standards help to avoid technical barriers in the internal market, they are consistent with the international trade framework deemed to facilitate global trade and in some instances, they are used to implement European legislation.

There are three European Standardisation Organisations (ESOs), CEN, CENELEC and ETSI. They are recognised under Community law (Directive 98/34). Jointly adopted guidelines exist for the co-operation between the Commission (and EFTA) and the European Standards Organisations (OJ C 91 of 16.4.2003).

The growing number of standardised products, processes and services poses questions about their effects on the environment. There are many standards and many ways in which standardised products can interact with the environment. Virtually all standardised goods and processes impact on the environment, although this impact may or may not be significant. Four major types of relationships between standards and the environment have been identified: the environmental dimension of products, the standardised tests methods for environmental purposes, the environmental technologies included in standards and the environmental management standards.

However, the extent to which the environmental dimension is taken into account varies among national and European standardisation organisations. There are many tools already developed, yet their use is not systematic. One of the main obstacles identified during the consultation phase was a lack of environmental knowledge among experts sitting on technical committees.

Practices regarding stakeholder participation also differ. Standardisation is a business-driven process, even though it must ensure openness to the representation of all interested parties, in particular if standards are to be widely recognised and used in the market. There are various groups of stakeholders that have particular difficulties in taking an active part in standardisation: small and medium sized enterprises, environmental and consumer non-governmental organisations and representatives of the workforce. They often lack knowledge about the standardisation process itself, and even if this is not the case, they may still experience shortcomings in terms of financial and human resources.

The large number of standards adopted every year, the ever-widening scope of products and processes that they cover, along with the voluntary character of this process, means that it is not possible for the European Commission to assess the environmental dimension in individual standards. It is more appropriate for the Commission to focus on the European standardisation process as a whole (tools and methods applied) and its institutional framework (participating stakeholders) in order to stimulate the production of European standards that positively contribute to the environment and to sustainable development in view of their economic and social importance. The Commission is tackling the issue of integration of environmental aspects into standardisation for the very first time at this level. In order to send a strong signal to all stakeholders involved in the standardisation process (industry, standardisation organisations, NGOs and public authorities), and bearing in mind the voluntary nature of standards and their consensus-based elaboration, it is therefore crucial to have a sufficient level of visibility and of commitment from the Commission services. A Communication was deemed to be the best way to start the process even though this Communication has to be seen as a stocktaking exercise presenting the state of the art and highlighting areas which deserve more attention in the future to meet our objectives.

No policy change scenario

A 'no change' scenario means that even though the number of European standards continues to grow - mainly due to technological, but also to legislative developments - the integration of environmental, aspects would remain un-systematic, becoming more a consequence of a personal commitment by a few experts rather than being based on a consistent analysis of potential impacts. Consequently, an opportunity for sustainable development in Europe would be missed. In other words, the environmental pillar may be neglected and standards would not contribute to the development of more sustainable production and consumption patterns.

There is also the risk that if European standards fail to take into account relevant environmental aspects, they would become less attractive and relevant for both the market and public authorities.

2. Main objective of the Communication

The aim is to promote the effective integration of environmental aspects into the European standardisation process.

3. Policy options

There are three major policy options available:

- Do nothing (business as usual);

- Encourage stakeholders to make further voluntary efforts;

- Use of legislative and financial instruments.

3.1 Do nothing (business as usual)

This option assumes continuing limited support from the Community budget for the participation of environmental NGOs such as ECOS (European Environmental Citizens Organisation for Standardisation). Indeed the European Commission has already shown the great value it attaches to the full involvement of all stakeholders in the European standardisation process. To that effect, it has already ensured representation of both consumers and workers for several years. With this new contract to ECOS, launched in November 2003, the voice for the environment is now secured.

Under this option the Commission will continue drafting standardisation mandates for environmental issues, concentrated mostly on measurement and performance standards.

The European standardisation organisations will continue to use some existing tools for the consideration of environmental aspects in standardisation, but not systematically and without any extra incentives from the Commission or national authorities.

3.2 Encourage stakeholders to make further voluntary efforts

The second option goes further and assumes that the stakeholders themselves could increase their efforts to systematically improve the integration of environmental aspects into European standardisation. Although the standardisation process is voluntary and based on consensus, all stakeholders involved are sensitive to strong political messages that can be sent out from the Commission. They would also react positively to incentives and accept appropriate support offered to them. This option assumes the development of incentives and targeted support for the stakeholders and the system. Identification of these measures has been the key objective of stakeholder meetings and consultations organised in 2002/2003 and the Communication aims to present the outcome of these previous phases. In a nutshell, 4 key issues have been identified to encourage stakeholders to make further voluntary efforts:

- raising awareness and environmental thinking

- setting priorities

- enhancing wider stakeholder participation

- using tools and offering incentives.

3.3 Use of legislative instruments

The third option assumes that legislative instruments would be used in lieu of voluntary standards if the stakeholders were not willing to deal with environmental aspects in standards making. As a consequence, public authorities would then need to lay down detailed rules for technical issues that could have been dealt with by the standardisation process. The authorities would need to assess, lay down and revise in the light of technical progress, the technical, economic and environmental specifications needed by the stakeholders. The associated cost would need to be covered entirely by public funding.

4. Social, environmental and economic impacts of each policy option

4.1 Do nothing (business as usual)

Environmental: There are many European standards that could have impacts on the environment in one way or another. Doing nothing may be a lost opportunity as these standards could make a positive contribution to safeguarding or even improving the environment. This impact is difficult to assess in quantitative terms due to the wide scope of products and goods covered by standards. The environmental pollution resulting from using goods made to standards that do not take the environmental dimension on board is very diverse. As far as products are concerned one should also take into account the different phases when environmental impacts can occur: design, production, use, re-use and disposal.

Social: Existing European standards support a number of directives for workers' health and safety and for consumer protection. Also, standardisation stakeholders, including industry and business, have an interest in developing standards for safe products and processes. If business as usual is continued, limited stakeholder participation from consumer organisations, unions or environmental NGOs will risk to make the standardisation process less democratic and user-oriented. On the other hand, users such as consumers or public authorities may prefer to purchase products which have a better environmental performance or at least to have information on this issue. Standards which take the environment into account are more likely to lead to products which give these elements to users.

Economic: There is little if any economic impact in the business as usual option because the drivers for standardisation are industry and business who want to find technical agreements for the purposes of compatibility and trade. The majority of the existing European standards have been created by the wish to enable trade and to effectively implement the single market. Only in the long term could a worsening of the state of the environment potentially exercise pressure on the standardisation stakeholders to systematically deal with environmental aspects.

4.2 Encourage stakeholders to make further voluntary efforts

Environmental: Further voluntary initiatives in this area would lead to a positive impact on the environmental pillar of sustainable development. Taking into account the wide coverage of standards, integration of environmental aspects will help to reduce the negative impacts of certain goods and processes. However there are three factors that will delay the potential positive effects. Firstly, taking into account the large number of stakeholders there is some time needed to raise their environmental awareness and to provide them with efficient tools to effectively deal with environmental consideration in the standardisation process. Secondly, the time span needed for development or revision of a standard varies from 3 to 5 years. Lastly, due to the large number of standards and the limited capacities of the standardisation bodies and their stakeholders, it would be unrealistic to expect immediate integration of the environmental dimension into all standards.

Social: This option may have an ultimately positive impact for consumers who buy products and services produced in accordance with standards which consider environmental aspects. Also, purchasers along the production chain and public authorities may have more choices between products and services with certain environmentally relevant functionalities and characteristics. Another positive aspect is the potential contribution to the state of the environment that in the long term leads to improvement of health, including health and safety at the workplace. A negative impact of this option may be that the efforts of standardisation stakeholders are steered away from the existing work on health and safety and consumer protection.

Economic: When environmental aspects are integrated appropriately, there could be economic benefits to the standards users - an obvious positive impact. However, a negative impact of this option may be that the existing standardisation work which supports economic activities such as free trade and the single market risks to be hampered. Moreover, the involvement of more stakeholders who have previously not taken part in standardisation activities, may delay the delivery of the new standards beyond what is acceptable to the market. This in turn may hamper innovation in the European economy. However, one should recognise that the standardisation process is already too lengthy in some instances and that efficiency improvements are under way. Therefore there are different potential delay-factors that should be addressed. Encouragement of stakeholders to make further efforts implies increased financial support for the environmental stakeholders so that they can effectively participate and apply the appropriate tools to integrate environmental aspects into European standards. This can be considered as an economic impact as such.

4.3 Use of legislative instruments

Environmental: This option may lead to the quickest results with the legislator developing and reviewing standards from their environmental point of view. This could be considered as a positive impact on the environmental pillar. However, it would change the well defined relationship between the legislator and the standardisation system and put the existing achievements at risk. In addition, it could create negative perceptions of the environmental debate - no other policy area has needed special legislation to become considered in standardisation.

Social and economic: This option may be perceived as heavy-handed interference. This may lead stakeholders to leave the system altogether so the current work being done for the social and economic aspects in standardisation could suffer. On the other hand, the public authorities would have to assess, lay down and revise in the light of technical progress, the technical, economic and environmental specifications needed by the stakeholders. The associated cost would need to be covered entirely by public funding. Overregulation and a regulatory process that is overburdened with technical detail would negatively impact on Europe's economy and competitiveness.

5. Monitoring of results

Due to the financial assistance given by the EU to European standardisation (5-6% of the total estimated cost of European standardisation), there is a need for the European standards organisations to be accountable and to regularly report on a number of issues. Also, due to the principle of national representation in the European standardisation system, there is a need for cooperation between the Commission and the Member States. For the integration of environmental aspects, progress reports from the different stakeholders such as the European standardisation organisations, the Member States or the private stakeholders from business and NGO side are foreseen. These should make some benchmarking possible and, if the focus is on continuous improvement, will be enable progress to be tracked. The Commission can regularly assess the situation, give further support, or propose new or alternative measures as and when it feels necessary. Main activities to be followed are:

Environmental thinking

Care for the environment, optimal use of resources and efficient energy consumption have grown in importance amongst economic operators, customers and public authorities. Standards should participate to this trend.

Experts involved in the development of standards have this power in their hands to influence the provisions written in the standard. The Commission is aware of the voluntary and consensus driven nature of standards. The Communication therefore aims to promote awareness-raising activities and an exchange of expert knowledge and good practice. This is a qualitative approach which is needed to trigger off the process and measurable aspects will come only in the long run. As regards quantitative aspects, ideas such as the provision of training are options which were highly supported by the stakeholders during the consultations. The Commission, in cooperation with stakeholders, therefore intends to explore the possibilities in these areas, identify what already exists at European or national level, work with stakeholders to better define their needs and present concrete actions in the coming months.

Setting priorities

Priorities can be set by the European Standardisation Organisations via their work programmes or by the Commission via the mandates. At this stage, these options were deemed to be interesting enough to be included in the Communication although it is clear that further dialogue and research is needed on how to put these measures into practice. This is particularly important for the mandates which observe specific rules, under specific conditions (a political or legislative framework for instance).

Stakeholder participation

The acceptability of standards depends to a large extent on the involvement of all stakeholders. The participation of civil society (e.g. stakeholders representing consumer, health, safety and environmental interests) in standardisation reinforces the quality of consensus and makes the standards more representative and thus acceptable for use by the stakeholders themselves, and, if appropriate, by the authorities. The monitoring of these participation (at national and European level) and information regarding names of participants, funding, areas of expertise, etc. could be easily coordinated by European standardisation organisations and passed on to the Commission.

Systematic and better use of tools

The national and/or European Standardisation Organisations have already developed a number of useful tools which can directly help with the integration of environmental aspects into standardisation. Their further development and systematic use should be encouraged. Environmental databases for example already exist in some specific areas. An assessment of these databases could be carried out to see under which conditions they could be further developed to cover other areas of activities.

Generally speaking, three sets of criteria could be considered together with stakeholders:

- When designing concrete awareness raising and/or training activities in the future, one should define indicators to monitor the participation at national and European level.

- Likewise, if databases containing relevant environmental information are established, indicators could be for example, the number of entries into the database and the number of queries made, etc.

- It is also important to monitor progress regarding the integration of environmental requirements. To that effect, stakeholders should be invited to develop appropriate indicators.

- It is important to bear in mind the Communication aims at presenting ideas that have been validated by the stakeholders. The process started two years ago and a lot of ideas were suggested but rejected for one reason or another (see also annex to the extended impact assessment). As stated in the Communication, all these ideas deserve further attention with relevant stakeholders. However their support for them needs to be built up and a commitment obtained.

6. Stakeholder consultation

Two stakeholder meetings took place in July 2002 and in July 2003. In addition, DG Environment and DG Enterprise held an internet consultation which ran from mid July until mid-September 2003 and invited all stakeholders to deliver their comments on a working document setting out the elements aiming at the encouragement of stakeholders.

A questionnaire was also developed to help gather comments and feedback for the alternative policy options. The extended impact assessment has been refined in accordance with the results of the stakeholder consultations. The detailed results of the consultation can be found in the Annex.

Overall, the consultation highlighted that:

- the aim and scope of the Communication targeted at the stakeholders is relevant and appropriate;

- all key issues have been identified;

- there are enough tools to address environmental issues in standardisation, but they require time, expertise and resources to be used systematically and all stakeholders must address this challenge;

- the Commission and Member States should jointly play a role in facilitating the effective participation of all interested stakeholders in the standardisation process;

- the progress made with the integration of environmental issues into European standardisation should be reviewed every five years.

7. Commission draft communication and justification

From the policy options available, the encouragement of stakeholders to make further voluntary efforts has been identified as a proportionate and balanced approach in view of the nature of the subject and the goals pursued. The results of the stakeholder consultation provide reassurances for this approach.

Two instrument options were considered: a working paper from the Commission services and a Communication from the Commission.

7.1 Instrument option: Working Paper from the Commission services

This paper would focus on the role of the Commission services, for instance, in the development of standardisation mandates or of legislation that sets out specific requirements for corresponding standards. The stakeholders who need to be convinced most may take little notice of this instrument.

7.2 Instrument option: Communication from the Commission

A Communication is considered a realistic option considering the nature of standardisation: a voluntary and stakeholder driven process. In view of its political significance and the contributions European standardisation has made and should make to EU policies, a Communication is a good way to meet the objectives of visibility and encouragement for stakeholders. The Communication also invites political feedback from the Council, the European Parliament and the Economic and Social Committee.

ANNEX to the Extended Impact Assessment

Report on the Public Consultation

The Integration of Environmental Aspects into European standardisation

25 July 2003 - 15 September 2003

This is a joint report by the Enterprise and the Environment Directorate General of the European Commission.

The aims for this report are:

- to describe the steps taken by the Commission to ensure the full consultation of stakeholders during the formation of a policy on the integration of environmental aspects into European standardisation

- to analyse the views collected during the public consultation.

The public consultation of stakeholders is part of the Commission's extended impact assessment process.

Consultation websites:

Background

Between 25 July 2003 and 15 September 2003, the Enterprise and Environment DG of the European Commission held a public internet consultation on the integration of environmental aspects into European standardisation. The consultation followed the Commission's consultation standards [26] and was aimed at stakeholders in the European standardisation system: businesses and industry, NGOs, public authorities and standards organisations. The stakeholders were asked to give their views on a working document for a Commission Communication on the integration of environmental aspects into European standardisation. In order to take advantage of the principle of Interactive Policy Making (IPM), a set of questions, designed by the responsible Commission services, was also posed.

[26] COM (2002) 704 final, 11.12.2002

At the start of the internet consultation period a multi-stakeholder meeting was held. It took place on 16 July 2003 in Brussels. This helped to raise attention for the internet consultation, clarify the objectives and check the initial contents of the planned Communication. The multi-stakeholder meeting was, in fact, the second of its kind since the responsible Commission services started to look into the opportunities and challenges linked with the integration of environmental aspects into standardisation in 2002 and held a first stakeholder meeting on 17 July 2002.

The feedback obtained from the meeting(s) and the responses now received from the internet consultation will feed into the extended impact assessment which is already underway for the Communication. The responses will help to further analyse the subject and examine the appropriateness of the policy instrument chosen. They will also help to finalise the text of the Communication itself and to make sure that it will cover the main issues in a balanced and appropriate manner.

Main findings

The general conclusion of the multi-stakeholder meeting of July 2003 was that the working document was a good basis for a Communication from the Commission.

The answers to the set of questions posed in the subsequent public internet consultation show that the presented text is broadly satisfactory to the range of different stakeholders at which it is aimed. There was a strong conclusion that the Communication will help stakeholders in their work and will help them achieve their aims in standardisation. Importantly, there is general agreement that a Communication from the Commission is the appropriate policy instrument for what the Commission is trying to achieve at this point in time.

The written contributions were often accompanied by general statements laying out the environmental policies of the respondents. These were often much wider than the contents of the Communication and indeed were wider than the subject of standardisation itself. Nevertheless, no stakeholders indicated opposition to the working document and the specific comments mainly related to the strengthening or clarifying of certain chapters.

To summarise, the main findings were:

- aim and scope of the future Communication are relevant and appropriate;

- all key issues have been identified, and it is important to clarify the relation between voluntary standards and mandatory legislation;

- there are enough tools to address environmental issues in standardisation. However these require time, expertise and resources if they are to be used systematically. All stakeholders must address this challenge;

- the Commission and Member States should jointly play a role in the financing for an effective participation of all interested stakeholders in the standardisation process;

- priorities should be set, primarily for efficiency purposes, on where to start with the integration of environmental aspects into standardisation; whilst the Commission could flag interest areas by way of mandate it should be left to the standardisation stakeholders to decide whether and how to deal with them;

- training of experts and the use of databases with relevant environmental information were considered the most instrumental incentives to incorporate environmental aspects into standards whereas the idea of awards was not supported;

- the international framework for standards and technical regulations must be respected to avoid unnecessary trade barriers, but the European standardisation system should take a certain leadership role in the development of specific environmental standards;

- the progress made with the integration of environmental issues into European standardisation should be reviewed every five years.

Annex 1: Multi-stakeholder meeting of 16 July 2003

1. Findings

Nearly all those attending expressed a positive opinion on the presented working document for a Communication. Some new ideas were introduced and these were taken on board in the text that was placed on the internet. e NGO, however, did not feel that satisfactory solutions to protect the environment could be achieved by voluntary standardisation and indicated a general preference for mandatory requirements in standardisation or legislative approaches in favour of the environment.

1.1 General Statistics

Over 50 participants attended the meeting. The represented stakeholders came from business and industry, NGOs, and the standardisation bodies from both the Member States and candidate countries. The European standards organisations CEN (European Committee for Standardisation), CENELEC (European Committee for Electrotechnical Standardisation) and ETSI (European Telecommunication Standardisation Institute) were also represented.

Below is a detailed list of organisations represented during the meeting:

* ACEA

* AENOR

* ANEC

* ANIE - Electronic Industry Italy

* BEAMA Ltd

* BE-Federal Department of the Environment - Product Policy Division

* British Standards Institution

* BUND KNU

* CECED

* CEN - European Committee for Standardization

* CENELEC

* CENELEC BTWG 85-3 "Environmental Standardisation"

* Council of European Producers of Construction Materials (CEPME)

* Czech Office for Standards, Metrology and Testing

* Danish Standards Association

* DIN - Deutsches Institut für Normung e.V.

* ECOS

* EFTA

* Estonian Centre for Standardisation

* ETSI

* EUCAR

* EUROFER

* Federal Ministry for Economic Affairs and Labour

* FIEC (Fédération de l'Industrie Européenne de la Construction)

* Finnish Ministry of Trade and Industry

* Finish Standards Association SFS

* FME ORGALIME

* FNE - France Nature Environnement

* IEC/ACEA

* Malta Standards Authority

* Ministère de l'Economie, des Finances et de l'Industrie

* Ministry for Foreign Affairs, Sweden

* Ministry of Agriculture, Forest, Water and Environment (Romania)

* Ministry of the Environment

* Mission of Norway to the EU

* NEN

* NORMAPME

* ORGALIME

* Spanish Electric Manufacturers Association

* Spanish Permament Representation to the EU

* Svenska Elektriska Kommissionen

* Swedish Ministry of Environment

* Swedish National Board of Trade

* Swedish Standards Institute

* TUTB - European Trade Union Technical Bureau for Health and Safety

* UK Department of Trade and Industry

* UMI

Annex 2: Internet consultation

1. Findings

The analysis of replies received in the internet consultation are reproduced according to the structure of the working document and the questions of the survey.

1.1 Aim and Scope

Q1 Do you agree with the aim and scope?

Supporting comments

Most of the respondents agreed with the aim and scope presented in the working document. It was confirmed that the international framework and the effective participation of certain groups of stakeholders, like small and medium sized enterprises (SMEs) should be taken into account.

Concerns

Some stakeholders expressed concern as to whether voluntary standardisation was a valid tool to contribute to a high level of environmental protection and indicated a preference for mandatory solutions. Others pointed out issues like a potential cost increase or negative impact on competitiveness.

Q2 Have we identified all the key issues?

Supporting comments

The majority of stakeholders confirmed that the working document identified the main issues. Some respondents pointed out that the consumer dimension was insufficiently addressed, and if there is no consumer demand, it will be difficult to maximise profit through economies of scale. Moreover, the relation between legislation (mandatory) and standards (voluntary) should be explored. Experience already gained, for instance with the Environmental Help Desk of CEN, should also be added.

Concerns

Some respondents said that the inclusion of environmental aspects into standardisation does not guarantee a higher level of environmental protection, as standards are voluntary. Complexity of the standardisation process would generally make it difficult for some stakeholders, including SMEs, to get involved. This includes the fact that standards are regularly revised and that not every laboratory could test against every standard if tests were required.

1.2 Environmental Thinking

Q3 Should another policy option (e.g. legislation, guidelines) have been chosen by the Commission? If so, which and why?

Supporting comments

The main feeling was that a Communication was the appropriate tool. This respects the voluntary nature of standardisation best while progressing the matter forward. Most respondents said that specific legislation was not appropriate for bringing environmental aspects into standards

Concerns

A few respondents said that the debate on environmental aspects in standardisation needed a general legal framework, such as the European Directive on General Product Safety without this, stakeholders would be unlikely to include environmental aspects into standards.

Q4 How frequently should the progress be assessed regarding the integration of environmental aspects into standardisation (e.g. every 2, 5 or 10 years)

Supporting comments

Five years was seen as a satisfactory period by the majority of the respondents.

Q5 Do you feel that you or your organisation contributes to the promotion of environmental thinking in standardisation? If yes, please describe the nature of your contribution.

Supporting comments

Many respondents indicated that they were contributing to the promotion of environmental thinking in standardisation in one way or another. The dissemination of state-of-the-art knowledge and offers for training and educational material were mentioned. Also, some respondents undertook lobbying activities aimed at regulators. Companies and their associations mentioned the use of environmental management standards and environmental declarations, their involvement on the development of certain test and measurement methods, and for the environmentally conscious design of products. NGOs engaged in raising awareness for standardisation amongst their stakeholders or made active contributions to standardisation work and the development of the internal procedures of standards organisations.

Q6 What are your expectations with regard to possible positive and negative impacts of the ideas implemented in the text?

Supporting comments

Respondents felt that the promotion of environmental thinking in standardisation can have a positive effect regarding the state-of-the-art environmental performance of products. This includes issues such as the use of recycled materials in industrial activities. Also, the use of uniform measures (European standards) throughout the EU and EEA was mentioned. Business stressed the need to integrate environmental aspects without damaging the achievements of the existing standardisation process such as its facilitation of trade

Concerns

Some scepticism was expressed about the situation that standards would become prescriptive and not performance oriented. It was mentioned that unwanted delays and increased cost in the standardisation process could occur due to awareness raising and educational activities. NGOs had the concern that business would limit environmental considerations to requirements imposed by the law. One organisation went as far as indicating that they do not believe in achieving results by awareness raising and recommended, instead, an obligatory environmental statement produced for each standard.

1.3 Tools and Standards for the Environment

Q7,8,9 Do you feel that there are sufficient tools to deal with environmental aspects in standardisation?If not, what new kinds of tools could improve the situation? Do you have any examples/experience of these tools being used?

Supporting comments

The general feeling was that there are sufficient and adequate tools and that these should be open to review and improvement as necessary. Most respondents felt that more encouragement was needed to ensure the use of these tools. Some said that the use of the tools could be systematic and monitored. There were no real concrete ideas for new tools (as defined as directly helping to integrate the environmental aspects - the use of databases is dealt with separately). Some considered Guides for product disassembly, use, disposal options and sustainable production as useful tools. Life cycle assessment (LCA) and educational tools were suggested. Many respondents said that they had used the existing tools and had positive experiences with them. However, no specific examples were given. A comment made several times was that the expertise to use these tools was needed. It was suggested that in the cases where comments from CEN's EHD were not taken into account, a justification should be provided.

Concerns

Some respondents felt that the CEN Environmental Help Desk (EHD) needed stable resources for staff from different backgrounds and countries. These respondents wished that CEN changed its internal rules and procedures regarding the role of the EHD.

Q10 Does the text correctly describe the existing tools? Have we forgotten some instruments used which are already being used in standardisation?

Supporting comments

Several additional existing tools were suggested including the following: ISO 14062, 14040, 14020, IEC Guide 109, 112 and 113, the EHD, CLC Database, CEN Memorandum 4, CEN Checklist and ENIS team (implements Guide 64). It was also mentioned that a leaflet describing all these tools may be useful.

Q11, 12 Are the categories for the existing standards for the environment correct and are the examples given useful? Please give other examples of types of standards that when applied, have a particular positive or negative impact on the environment.

Supporting comments

On the whole, this section of the working document was found to be useful, some simplification and clarification could lead to improvement. e categories of different standards for the environment should be changed to include product standards: product standards take environmentally friendly design into account and product standards are where the main thrust of effort is needed. relation to this, it was said several times that safety took precedence over the environment or that at least the environment must be assessed with the other aspects covered in product standards. Alternative headings were suggested: product standards, measurement standards, systems management standards, standards for dealing with products and technologies, other useful management standards, supply chain, procurement, design management. Many respondents noted that for the section on ISO EN 14000 management standards it should be stressed that the benefit came from applying it, not from the 3rd party certification to it. Several poor and one good example were presented.

1.4 Priority Setting

Q13, Q14 Should the Commission set priorities (at all)? Can you think of any positive or negative consequence of setting priorities?

Supporting comments

The views as to whether the priorities should be set by the stakeholders in the standardisation process or by public authorities like the Commission differed widely among the respondents. From the reactions obtained one could conclude that the European policy makers should flag public interest areas, but that it should be left to the discretion of the standardisation stakeholders to decide - on a case by case basis and agreed by consensus - whether and how to deal with them. Prioritisation as such was acknowledged as important and positive for better efficiency in standards making.

Concerns

Concerns were raised that low priority standards would be unlikely to see completion and ill chosen priorities would result in market distortion.

Q15 Do you have suggestions as to how priorities could be set?

Supporting comments

Respondents suggested different ways to set priorities for the integration of environmental aspects in standards. Proposals included a prioritisation according to industrial/product sectors, according to the links with EU legislation and policy, according to the relevance for public procurement, or according to key environmental problems tackled by international commitments such as the Kyoto Protocol.

Q16 Do you think that the Commission should use mandates in order to prioritise issues?

Supporting comments

Many respondents perceived mandates as tools for priority setting in standardisation. They acknowledged the potential for public authorities to express their priorities by means of standardisation mandates. However, some NGOs wanted to link mandates strictly to legislation and it was suggested that, on a general basis, an assessment of compliance could help to decide whether voluntary standards or mandatory regulations are the better solution. Some respondents wished to see mandates from the Commission regarding low carbon technologies to support Kyoto Protocol measures or regarding reverse logistics to facilitate the return of products from the market place at the end of their useful lives.

Concerns

Certain respondents had concerns as to the possibility of political decisions being transferred to standards organisations. It was suggested that in preparation of a mandate, the Commission evaluates different environmental, health or safety costs from a sustainability perspective; that stakeholders should be consulted in the preparation of mandates; that environmental requirements are well defined to allow for assessment on whether a mandate has been fulfilled or not; and that national public authorities be encouraged to participate in mandated standardisation work.

1.5 Stakeholder Participation in the Standardisation Process

Q17 Should the emphasis of the efforts to improve the integration of environmental aspects be placed at the European or national level?

Supporting comments

Many respondents felt that standardisation should take place at the European level. It was more cost effective and avoided duplication of work at different levels. The national and international dimension, they said, were nevertheless important. The national, because this would be the level at which standards were implemented; and international, because of the growing importance of the global market.

Concerns

Some stakeholders, in particular NGOs, expressed concern that in their countries there was no mechanism guaranteeing that consensus achieved at the national level would be transferred to the European standardisation process. This raised the issue of how important it was that NGOs are sufficiently represented at the European standardisation level to complement any representation in the national standardisation committee.

Q18 Do you have practical suggestions for ensuring the effective participation of groups of stakeholders that have important input but that are difficult to reach?

Supporting comments

It was clearly demonstrated that stakeholder participation in standardisation varied from country to country. Suggestions were made as to improve the effective participation of the relevant stakeholders:

- by making publicly available the work programmes of the standardisation organisations;

- by increased financial support for some stakeholders;

- by limiting their participation to technical committees or working groups that are relevant from the point of view of environmental protection;

- by encouraging representatives from national public authorities to participate in the relevant standardisation work;

- by providing easier access to relevant data; and

- by providing appropriate training.

Concerns

Many respondents stated that the relevant stakeholders already participate in the standardisation process. Standards organisations were generally open to participation and opinions from all interested parties. Hence, the current system would not require any changes- those who are truly interested ould already participate in it

Q19 How will more involvement of different stakeholders affect / change the standardisation process?

Supporting comments

Opinions concerning the participation of a wider group of stakeholders were mixed. One potential positive consequence would be that standardisation would be made more transparent, so that the interests of all affected parties could be represented. It would be particularly important for SMEs to ensure that standards reflected their needs and not just those of big companies.

Concerns

Some opinions noted that wider participation may slow down the process of adoption / revision of standards, which was already too slow. In particular, a further slowdown may occur in the initial phase when new stakeholders join the technical committees and working groups as they may not be familiar with all the procedures. Moreover, standardisation is a consensual process and some of the newcomers may have difficulties in accepting the need for compromise.

1.6 An international framework for greener standards

Q20 What implications does the international framework have for European policies in your view?

Supporting comments

Some respondents pointed out that national, island solutions risked becoming barriers to international trade and the integration of the Single Market called for the WTO Agreement on technical barriers to trade to be respected. Others stated that Europe could take a leading role and intellectual leadership in the development of certain environmental standards; and that for global transfer and use of European standards, comments from stakeholders outside Europe should be enabled. Close co-operation between international and European standards development via the principle of national mirror committees was considered important.

Concerns

A third country administration pointed out that developing countries may require special and differential treatment, as they will have difficulties in implementing international standards with specific environmental requirements.

1.7 Possible Incentives to further integrate environmental aspects in standards

Q21 Would it encourage standardisers to develop standards with an environmental dimension if there was the possibility to show compliance with environmental legislation?

Supporting comments

To demonstrate compliance with environmental legislation by using voluntary standards tends to be perceived as an incentive by industry, mostly against the background of the New Approach directives. But clearly, this is only seen as positive in instances where regulation is absolutely needed and legal incentives should not be introduced as a rationale for new, unnecessary legislation. Some respondents suggested that New Approach type legislation should be used for new areas such as energy using products or that existing directives for products should cover environmental requirements in the future.

Concerns

Some NGOs stressed that standardisation cannot and should not replace legislation. Other respondents asked for an advanced warning of new legislation, which would avoid wasting resources on standards in areas that are likely to be regulated in the foreseeable future. Many respondents felt a need for a clear distinction between voluntary standards and mandatory laws. The discrepancy between product related legislation affecting all competitors equally and EU environmental legislation, differing from member state to member state was mentioned.

Q22 Are you familiar with the information made available under the eco-labelling schemes? If so, is it of use for the production of European standards?

Supporting comments

Most of the respondents were familiar with eco-labelling schemes. However, the views on whether eco-labelling could be used in standardisation were mixed. Some stakeholders perceive eco-labels as a good reference point, clearly identifying most important areas of concern. Standards, however, should be less ambitious in establishing environmental performance, as they are to be accepted by all the stakeholders. Some of the eco-label criteria, such as water or energy use, could be easily adapted for standardisation needs. Certainly, data gathered during assessment of products for eco-labels should be used in the standardisation process.

Concerns

Concerns for using eco-label criteria in standardisation were mostly related to market relevance. Eco-label criteria are developed by a relatively limited number of market players and therefore should not be extended to the whole market. Eco-labels should remain as goals for front-runners only. Some respondents pointed out that environmental standards should be rather process than product orientated as this is the case with eco-labels. Also, the eco-label is more perceived as a marketing tool for a limited group of market players.

Q23 Would you use standards or purchase standardised products, processes and services that cover environmentally important performance?

Supporting comments

Many of the stakeholders said that this was already the case. Other factors, such as price and quality, however, must also be taken into account.

Concerns

Stakeholders expressing doubts pointed out that the impact on the environment is only one among many factors taken into account when purchasing products or contracting services.

Q24 Would awards provide an incentive to integrate environmental issues into standardisation?

Concerns

The majority of respondents were sceptical as to possible use of awards. If at all, awards needed to be accepted by the market rather than being introduced by a top-down approach. The effects of awards were considered limited as they tend to attract the participation of only the highly committed organisations, and therefore could have a divisive effect. However, the need to communicate achievements was noted.

Q25 Would you consider using databases? How would you use them? uld the availability of databases ease the integration of environmental aspects into standardisation?

Supporting comments

The overwhelming response was yes that databases were useful. However the format, usability, content, access rights and procedures to use them needed to be very carefully thought through. Otherwise it would just be additional to an already confusing amount of information and innovation could be stifled by old data. The data would be the main thing to think about. In particular its validation was important - especially when conflicting views were put forward. It was noted that if databases needed to be created they should be an aid to standardisers but not mandatory in their use. Resources and costs would also needed to be considered. The text of the working document needed