Opinion of the Economic and Social Committe on: - the 'Proposal for a European Parliament and Council Directive on national emission ceilings for certain atmospheric pollutants,' and - the 'Proposal for a European Parliament and Council Directive relating to ozone in ambient air'
Date: 1999-12-08
Institutions: European Economic and Social Committee
Subjects: atmospheric pollutant, energy policy, environmental policy, prevention of pollution, stratospheric pollution

23.2.2000

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Official Journal of the European Communities

C 51/11

Opinion of the Economic and Social Committee on:

— the ‘Proposal for a European Parliament and Council Directive on national emission ceilings

for certain atmospheric pollutants’, and

— the ‘Proposal for a European Parliament and Council Directive relating to ozone in ambient

air’

(2000/C 51/03)

On 13 October 1999, the Council decided to consult the Economic and Social Committee, under
Article 175(1) of the Treaty establishing the European Community, on the above-mentioned proposals.

The Section for Agriculture, Rural Development and the Environment, which was responsible for
preparing the Committee’s work on the subject, adopted its opinion on 15 November 1999. The
rapporteur was Mr Chiriaco.

At its 368th plenary session (meeting of 8 December 1999), the Economic and Social Committee adopted
the following opinion by 96 votes to two, with three abstentions.

1.

Introduction

consulted extensively with Member States, industry, NGOs and
other parties (1). Regrettably the agricultural organisations were
not consulted, although they will have a role to play in
implementing the proposed measures.

1.1. Acidification, tropospheric ozone and soil eutrophication

1.1.1.
Acidification, tropospheric (‘ground-level’) ozone and
soil eutrophication are inter-related, transboundary environ-
mental problems caused by emissions of sulphur dioxide (SO2),
nitrogen oxides (NOx), volatile organic compounds (VOC) and
ammonia (NH3), and their by-products. Acidification — the
deposition of acidifying pollutants (SO2, NOx, NH3) onto veg-
etation, surface waters, soils and buildings — affects biological
populations and forests, leads to acid groundwater damaging
water supply systems and is harmful to buildings and monu-
ments. Tropospheric ozone — a secondary pollutant formed by
the reaction of precursors such as nitrogen oxides (NOx) and
VOC under the influence of sunlight — is harmful to human
health as it can damage all parts of the respiratory tract. In
addition, it also affects individual crop and tree species, degrades
materials and contributes to climate change. Eutrophication,
which is caused by the deposition of nitrogen compounds (NOx
and NH3), leads to changes in terrestrial ecosystems, such as
changes in plant community composition and biodiversity, and
is a factor alongside acidification and tropospheric ozone in
forest decline.

1.2. The two Commission proposals

1.2.2.
Taking account of previously established long and
medium-term environmental objectives, the NEC proposal sets
national emission ceilings for SO2, NH3, NOx and VOC, to be
achieved by 2010. The ceilings per Member State have been
allocated on the basis of cost-effectiveness considerations: due
to different environmental conditions (e.g. source-receptor
relations) and abatement potential, as well as varying
implementation costs, the required emission reductions differ
per country (‘differentiation versus a flat rate approach’). In
implementing the Directive, Member States will need to assess
what action is appropriate in their particular circumstances,
and introduce measures accordingly (subsidiarity). The NEC
proposal, which is closely related to existing EU environmental
policy and legislation (such as the Acidification strategy
adopted by the Commission in March 1997 and the Auto Oil
I package), should be seen against the background of the
planned multi-pollutant protocol to the United Nations Econ-
omic Commission for Europe (UNECE) Convention on Long
Range Transboundary Air Pollution (CLRTAP) which will also
set national emission ceilings for most UNECE countries
including the EU Member States.

1.2.1.
The two proposed Directives on national emission
ceilings for certain atmospheric pollutants (the ‘NEC’ Directive)
and on ozone in ambient air (the ‘ozone’ Directive) aim at
addressing these environmental problems jointly in order to
exploit synergies and to ensure a coherent and cost-effective
approach. When preparing its proposals the Commission

(1) See for more background information, including a comprehensive
report containing the positions of the experts involved in the
the following
preliminary consultations by the Commission,
website address:
http://europe.eu.int/comm/dg11/docum/99125sm.htm.

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1.2.3. Whereas the NEC Directive deals with emissions, the
proposal for an ozone Directive, which is to become the third
daughter Directive under the Air Quality Framework Directive
adopted in September 1996 (1), concerns environmental qual-
ity standards. Underpinned by the ozone related emission
reductions (NOx and VOC) envisaged under the NEC Directive,
the proposal aims at introducing (locally relevant) target values
for tropospheric ozone in order to protect human health
and vegetation, along with requirements to monitor ozone
concentrations in ambient air and to report to the public on
the findings of that monitoring.

1.2.4.
By no later than 31 December 2004, the Commission
will report to the Council and the European Parliament on the
implementation of the proposed Directives. This report will
then allow for a review of provisions in the Directives, taking
account of new factors arising from research, the development
of new technology, newly available data and new initiatives,
and with the benefit of more comprehensive statistical refer-
ences for areas such as natural and farm-generated emissions.

2. General comments

2.1. Overall appreciation

The Committee welcomes the Commission’s initiative of
presenting proposals which offer the Member States a frame-
work for reference, monitoring and exchange of information
with a view to further measures to protect human health
and the environment,
in accordance with the objective of
sustainable development. It notes that the proposal for a NEC
Directive is in line with the level of ambition indicated by
the Member States at the outset of the negotiations on a
multi-pollutant protocol at UN-ECE level (the so-called ‘guiding
scenario’) as well as with the European Parliament’s resolution
on the Community’s acidification strategy (2). The Committee
regrets that, although they constitute a step in the right
direction, the emission reductions to be agreed for the EU
Member States under this protocol are likely to fall far short of
the level of ambition associated with the national emission
ceilings proposed by the Commission.

2.2. The proposed objectives

Before examining the more specific elements of the two
proposals, it would appear necessary to look into the objectives
upon which they are founded. Whilst the proposed qualitative

(1) OJ L 296, 21.11.1996.
(2) OJ C 167, 1.6.1998, p. 133.

long-term objectives are virtually undisputed, their translation
into quantitative objectives for the long term and, in particular,
for the interim period is a more controversial question. This
involves a number of political decisions which are partly
guided by the expected costs and benefits of different policy
options. In turn, the results of the underlying cost-effectiveness
and cost-benefit analyses, though they are calculated in figures,
are also partly determined by assumptions of a political nature.
It should also be stressed that the methodology for quantifying
benefits in human health and environment terms and for
internalising the costs of damage to health and the environ-
ment is constantly being refined and calls for more attention
and resources. On the other hand, it is clear that a calculation
based solely on economic considerations would be inadequate
for assessing the effects of the proposed measures.

2.2.1. T h e p r o p o s e d l o n g - t e r m o b j e c t i v e s

2.2.1.1.
The proposals’ long-term objectives — for which
no deadline is proposed at this stage — are to avoid exceeding
critical loads (for acidification and eutrophication) and critical
levels (for ozone) (3) as well as the effective protection of all
people against recognised health risks from air pollution. This
qualitative ‘no adverse effects’ objective — which is a measure
of sustainable development — is in accordance with the
commitments laid down in the 5th Environmental Action
Programme of 1993 (4), which were recently confirmed by the
Council and the European Parliament (5). The ESC agrees with
this objective and has repeatedly supported it in its opinions.

2.2.1.2.
The translation of this qualitative long-term objec-
tive into quantitative terms is undoubtedly one of the pro-
posals’ most crucial elements. As to the operational definition
of critical acidification and eutrophication loads, it should be
noted that these have been established per eco-system/Member
State in accordance with an internationally agreed method-
ology (6). Thus, quantitative long-term objectives for acidifi-
cation and eutrophication are founded on a sound and
internationally recognised scientific basis.

(3) A critical load means a quantitative estimate of an exposure to
one or more pollutants below which significant adverse effects on
specified sensitive elements of the environment do not occur,
according to present knowledge. A critical
level means the
concentration of pollutants in the atmosphere above which direct
adverse effects on receptors, such as human beings, plants,
ecosystems or materials, may occur, according to present know-
ledge.

(4) See Chapter 5.2. This chapter, whilst establishing the objective of
not exceeding critical loads for acidification, does not explicitly
refer to eutrophication.

(5) See Article 11(2) of their Decision of 24 September 1998 on the

review of the 5th EAP — OJ L 275, 10.10.1998.

(6) The critical loads are taken to be those compiled by the CLRTAP

Co-ordination Centre for Effects.

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2.2.1.3.
Defining critical ozone levels for human health and
vegetation is more complicated owing to the lack of a clear
‘no adverse effects’ level as far as human health protection is
concerned. However, the Commission is of the opinion that
the relevant WHO ‘human health’ guideline of 1999 (120
µg/m3 mean over an 8-hour period) can be treated as the
critical
level, despite the fact that this guideline is based
upon acceptance of a certain amount of risk to the general
population. The Committee would mention that this decision
is in line with the fifth environment programme’s provision
that the European Union should apply the WHO guidelines. In
contrast to the area of human health, the WHO has set critical
levels relating to vegetation, which the Commission thus
proposes as long-term objectives. The Committee endorses
these proposed long-term objectives for human health and
vegetation, taking into account, among other things, that they
have been endorsed by the Scientific Committee on Toxicity,
Ecotoxicity and the Environment (CSTEE) as well as by all
Member States and environmental NGOs (1).

2.2.2. T h e p r o p o s e d i n t e r i m o b j e c t i v e s

2.2.2.1.
As it is generally acknowledged that it will be
technically and economically very difficult to reach the ‘no
adverse effects’ objectives in the near future, the Commission
proposes a number of interim objectives for the year 2010. It
is obvious that the choice of these interim objectives will
crucially determine the extent of
the required emission
reductions, the associated costs and the environmental benefits.

2.2.2.2.
The Committee notes that the exercise of setting
interim objectives involves both a ‘economic-technical’ dimen-
sion based on cost considerations and a number of ‘political’
decisions. Without going into detail, it can be stated that —
taking a ‘Maximum Feasible Reduction’ scenario as the upper
limit — the interim objectives have been established at such
levels as to avoid unreasonable marginal and total emission
control costs. (2) These costs are calculated using the so-called
RAINS model, developed in the context of the CLRTAP and
generally approved by the Member States, as is also shown by

(1) See points 5.3a and 5.9 of the explanatory memorandum.
(2) Thus, in principle, the estimated (marginal and total) benefits have
not been taken into account when setting the interim objectives.
In other words, these objectives have not been fixed on the basis
of a ‘maximisation of total benefits’ approach, which would imply
that emissions would be reduced until the point where marginal
costs equal marginal benefits. A more detailed description of the
general modelling approach and the objective setting principles
can be found in the Interim Reports Cost-effective Control of
Acidification and Ground-level Ozone prepared by the Inter-
national Institute for Applied Systems Analysis (IIASA). All these
reports are available on the Internet under:
http://www.iiasa.ac.at/ rains.

the fact that it has been recently used in the context of the
negotiations on the multi-pollutant protocol. This model has
is constantly being
already been in use for eight years,
improved and will continue to be refined, especially with a
view to the possible review of the directive in 2004 and 2008.

2.2.2.3.
As regards this model, the ESC notes, however,
that RAINS is very likely to overestimate the necessary
abatement costs, among other things because it is based on
‘pre-Kyoto’ energy consumption scenarios and because it only
considers technical (end-of-pipe) abatement measures without
taking account of the potential of structural changes such as
increased energy efficiency or use of alternative energy sources.
In this connection, the ESC takes note of the announced
‘Action plan’ to implement the Kyoto agreements (3) and takes
the view that a series of measures adopted in this context will
contribute to better implementation of these proposals.

2.2.2.4.
Also against this background, the ESC supports the
interim objectives proposed by the Commission. As far as the
120µ/m3 ozone target value is concerned , it should be noted
that a number of countries have adopted or are planning
similar and even more ambitious standards. For instance, the
UK national ozone objective is 100µ/m3 (8 hours), that of
Switzerland is 120µ/m3 (8 hours) and the (planned) Canadian
one is 130µ/m3. The recently adopted US standard is 160µ/m3.
Prima facie this more lenient US standard may raise competi-
tiveness problems (no ‘level playing field’). It is noted, however,
that as current (average) ozone concentrations in the US are
the required
substantially higher than those in the EU,
(proportional) emission reduction efforts are of the same order
of magnitude.

2.2.2.5.
Regarding the use of economic models such as
RAINS, the Committee would add that although such models
can play a useful role in guiding policy-makers in making
informed environmental policy decisions, they cannot act as a
substitute for such decisions. In the past, the ESC has repeatedly
expressed the view that it is impossible to expect 100 %
certainty in the technical justification for decisions on environ-
ment policy and that in cases of doubt, the environment policy
principles enshrined in article 174 (2) of the EC Treaty,
especially the ‘high level of protection’, the ‘polluter pays’ and
the ‘precautionary’ principles should be applied (4).

(3) Commissioner Wallström’s speech to the EP, Strasbourg session

of October 1999.

(4) See the ESC opinions on the 4th and the 5th Environmental
Action Programme (C 180, 8.7.1987 and C 287, 4.11.1992) as
well as its opinion on the first air quality daughter Directive (C
214, 10.7.1998).

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At

2.2.2.6.
this stage no separate interim objective is
proposed for soil eutrophication, although the Commission
does suggest considering such an objective as part of the
planned review in 2004. The proposal is rather vague about
the reasons for this delay. The Commission claims that as a
result of the proposed national emission ceilings, the Com-
munity area affected by soil eutrophication will be reduced by
ca. 30 % compared to 1990. The Committee regrets that such
a separate objective has not been proposed by the Commission.
In this connection,
it should be recalled that the planned
multi-pollutant/multi-effect protocol does pursue such an
objective.

2.3. The means to achieve the objectives

2.3.1.
The analysis carried out by the Commission shows
that in order to achieve the identified interim objectives, it is
necessary to achieve emission reductions beyond the so-called
‘reference’ or ‘business as usual’ scenario, which incorporates
most of
the relevant existing and already proposed EC
legislation as well as relevant national legislation and policy
plans.

2.3.2.
The necessary additional emission reductions will be
pursued in the framework of the proposed national emission
ceilings. These national ceilings, which also encompass the
emission reductions resulting from the legislation and policy
plans included in the reference scenario, have been allocated
on the basis of a comprehensive analysis of a cost-effective
distribution of emission reductions between the Member
States, again using the results of the RAINS model. The ESC
welcomes this differentiated approach to achieving the interim
objectives, which involves significantly lower costs than an
approach based on flat rate percentage reductions. It should
be kept in mind that the national ceilings approach gives the
Member States the required degree of flexibility to determine
— taking account of their specific national situation — which
measures are best suited to comply with the emission ceilings
allocated to them. However, the Committee takes the view
that the Commission should play an active coordinating role
in connection to the preparation and updating by the Member
States of the planned national programmes (Art. 6) and
emission inventories and projections (Art. 7) in order to ensure
the optimal mix of emission reduction measures, to ascertain
the stage reached in their implementation and to take the
necessary corrective action.

2.3.3.
The NEC Directive will be the main tool for ensuring
that the interim objectives for acidification and ground-level
ozone are met. For ozone, however, it will be complemented
by a Directive on concentrations of ozone in ambient air. In
submitting a proposal for this (third) air quality daughter
Directive, the Commission fulfils the obligation laid down in
the 1996 Air Quality Framework Directive. In line with the
provisions of this framework Directive, the proposed ozone
daughter Directive sets ‘target values’ for (local) human health
and vegetation related ozone concentrations to be achieved in

2010. These target values have been derived from the interim
objectives established for ozone (see 2.2.2 above). This implies
the proposed national emission ceilings will ensure
that
compliance with the target values at regional level; to ensure
attainment of these values at local level — i.e. to reduce locally
generated excess levels — Member States may have to take
further action.

2.3.4.
The Committee notes that the Commission con-
sidered two options for expressing the target value for human
health (1) and that it concluded that it was preferable to base it
on the long-term objective for ozone, i.e. the WHO guideline.
Taking into account the reasons outlined in point 5.3 of the
explanatory memorandum and the fact that the great majority
of experts including the CSTEE endorsed the Commission’s
decision, the ESC regards the proposed objective as a valid
one, especially in terms of benefits for human health.

3. Specific remarks

3.1.
As far as the identification and implementation of
specific emission reduction measures by the Member States is
concerned (cf. Article 6 of the NEC proposal on the national
programmes to be drawn up), it is necessary to draw the
logical conclusion from the options suggested by the modelling
(see point 2.5 of the explanatory memorandum). This ensures
the most appropriate combination of measures at national
level and forms of synergy which can be achieved among
sectors. The necessary measures involve redirecting invest-
ments and technological
innovations towards ‘sustainable
growth’. They should increasingly be of a preventive kind,
rather than corrective (‘end-of-pipe’) measures, and should be
combined with existing efforts to achieve energy saving, use of
alternative energy sources, a sustainable transport and mobility
policy, and encouragement for ‘clean’ production methods and
products.

3.2.
As to the tools to be used to implement such measures,
the Committee underlines the potential of financial instru-
ments. If well designed, levies and charges, which comply with
existing legislation and with the competition requirements of
a globalised market, can be very effective tools to achieve
environmental objectives. (2) Such levies and charges, estab-
lished at national
level,, should perhaps be coordinated at
European or international level. By the same token, the use of
incentives related to levies and charges to redirect investments

(1) See point 5.3 of the explanatory memorandum.
(2) See, for instance, the recent report The use of Economic Instru-
ments in Nordic Environmental Policy 1997-1998 published by
the Nordic Council of Ministers (Copenhagen, 1999).

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In addition,

innovations (see 3.1
and the promotion of technological
above) should also be considered.
incentives
should be identified and gradually developed for companies
who take steps to find substitutes for unsustainable activities
(e.g. those causing acidification, ozone formation and eutro-
phication). Finally, the Committee also calls on the Member
States to examine the scope for (voluntary) environmental
agreements.

3.3.
The planned multi-pollutant protocol, that involves
the accession countries, can be considered a starting point for
further emission reductions by these countries in the future as
they join the European Union. This could eventually take the
form of their own NECs, setting out transitional stages. As
action in these countries beyond the protocol requirements is
likely to be very cost-effective, the question could therefore be
asked whether, between now and the time of their accession,
measures in addition to those provided for by the protocol
could not be encouraged.

3.6.
The Committee would finally underline the importance
of effective enforcement of the proposed Directives. In this
respect it notes that the Commission proposals (Art. 12 of the
NEC Directive and Art. 13 of the ozone Directive) require
Member States to lay down the rules on penalties applicable
to infringements of the national provisions adopted pursuant
to the Directive in question. It goes without saying that should
Member States themselves not live up to the Directives, such
national penalties have to be complemented by action by the
Commission in accordance with its role as the guardian of EC
legislation.

3.7.
The Committee welcomes the review mechanism pro-
vided for under Article 9 of the NEC Directive, to be based on
periodical reports. These will enable the Commission to
propose changes in the national emissions ceilings listed in
Annex 1, taking into account the factors listed under Article
9(1) (including international commitments made in relation to
climate change). In this respect, special attention should be
given to the future improvement of the RAINS model.

3.4.
Regarding the proposed ‘ozone’ Directive, the Com-
mittee welcomes the dissemination of up-to-date information
on ozone concentrations to the public (see Art. 6). However,
it considers that the ‘information threshold’, which is aimed
primarily at
the population,
should be divided proportionately among the Member States,
depending on their climate and geography and the frequency
with which maximum levels are exceeded, where appropriate
even descending below the 180µg/m3 (1 hour average) pro-
posed by the Commission. (1)

informing sensitive parts of

3.5.
The Committee also suggests public education and
training campaigns to inculcate awareness and good practice
in the area of health protection - an aspect to be included in
all policies, especially in relation to urban pollution problems.
Initiatives such as the ‘network of sustainable cities’ or the
‘car-free days’ organised in a number of European cities help
to raise awareness and improve understanding of the measures
to limit pollution, in terms of their benefits for health.

(1) See the 1998 and summer 1999 annual reports on tropospheric
ozone pollution in the EU. Last summer, the population infor-
mation threshold was passed in nearly all EU countries. The most
critical situations were found in Italy, Greece, France and Spain
where the public was informed of high ozone pollution for
between 68 and 40 days running.

4. Suggested measures and programmes for individual
Member States to reduce emissions of the pollutants
in question

4.1.
Bearing in mind the comments made in 2.3.2 regarding
the need for national programmes to be actively coordinated,
the Committee recommends a number of measures to be
implemented and monitored in the various national, regional
and local situations. The potential for synergy is obvious and
some of the measures dovetail with those relating to climate
change. The Committee proposes to look into this matter in
further detail as part of its future activities.

1. Reducing energy consumption in the transport sector

Working on the assumption that national and local transport
sector programmes, financed under State and regional laws,
must generally be aimed at increasing energy efficiency, the
Committee recommends the following measures:

— maximum joint financing of measures to promote sus-
tainable mobility in urban areas and areas designated by
the regions (areas at risk from atmospheric pollution).
Such measures could include:

a) preparing and updating urban traffic plans, paying
special attention to their efficiency in terms of the
reduction of ozone;

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b)

in urban areas and areas with over 500 000 inhabi-
tants, implementing intelligent transport systems (ITS),
schemes,
and improving park-and-ride
building
increasing public transport capacity using hybrid elec-
tric or gas-powered vehicles, reorganising goods distri-
bution using incentives to encourage companies to use
hybrid electric or gas-powered vehicles;

— joint

financing of

the additional cost of using high-

efficiency fuels in public transport and vehicle fleets;

— joint financing of the purchase of electric/hybrid/low-
emission vehicles for public and public service fleets on
small islands;

— joint financing of production and purchase of two-wheeled
electric vehicles for government bodies and public services.

2. Generating energy from renewable sources

Working on the assumption that the generation of energy
from renewable sources is also promoted by other legislation,
the Committee recommends the following measures:

— joint financing of the construction of biomass power
plants, preferably integrated with district heating networks;

such programmes could include:

a.

energy audits,

b. measures targeting housing and related buildings,

c. urban regeneration and sustainable development,

d. promotion and dissemination of high-efficiency electri-
cal components and, heating and air-conditioning
systems in the housing sector, in offices and in public
buildings,

e. use of high-efficiency electrical parts in industry;

— joint financing of the additional cost of programmes for
the use of innovative fuels with a low environmental
impact and for the efficient use of fuels in industry.

4. Reducing emissions in non-energy sectors

The following measures are recommended:

— joint financing of programmes to reduce ammonia emis-

sions from livestock farms.

— joint financing of the construction of solar thermal power

5. National information campaign on climate change

plants;

— joint financing of the construction of photovoltaic power

plants;

— joint financing of the construction of plants on small
islands to generate power from the wind, urban solid waste
fuel, and biogas.

3. Reducing energy consumption in the industrial, household and

services sectors

Working on the assumption that reducing energy consumption
is an objective of many programmes for public, residential and
industrial buildings, the Committee recommends:

— joint financing of programmes for the efficient use of
electricity and the reduction of consumption in private
homes, offices, public buildings and industry and of the
reduction of the overall cost of programmes, joint finan-
cing of measures on the additional cost of products, and
on extra costs generally;

— joint

financing of public information campaigns and
promotion of better techniques and practice which increase
energy efficiency and reduce emissions;

— joint financing of public information campaigns, drawn
up by public and goods transport service providers, to
promote high-efficiency, low-emission transport systems;

— joint financing of public information campaigns, drawn
up by managers of biomass power plants, to promote
district heating.

6. National research programme on climate change

— a ‘basic project’ to assess and certify progress made in
the emission reduction programme, as required by the
Convention on Climate Change, the Kyoto Protocol and
European Union decisions. This would involve updating
emissions data, national data banks, numerical climate
simulations and generation of the related climate scenarios;

— joint financing of applied research projects to develop
technologies that are highly energy-efficient and low in

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pollutant emissions for combined cycle plants, industrial
and public cogeneration plants and in emulsion and
residue gasification plants;

— joint financing of applied research projects for the develop-
ment of low-emission transport technologies and systems.

Brussels, 8 December 1999.

The President

of the Economic and Social Committee

Beatrice RANGONI MACHIAVELLI

Opinion of the Economic and Social Committee on ‘The development of outlets for food and
non-food packaging waste’

(2000/C 51/04)

On 29 April 1999 the Economic and Social Committee, acting under the third paragraph of Rule 23 of
its Rules of Procedure, decided to draw up an own-initiative Opinion on ‘The development of outlets for
food and non-food packaging waste’.

The Section for Agriculture, Rural Development and the Environment, which was responsible for
preparing the Committee’s work on the subject, adopted its opinion on 16 November 1999. The
rapporteur was Mr Verhaeghe.

At its 368th plenary session (meeting of 8 December 1999), the Economic and Social Committee adopted
the following opinion by 112 votes with 1 abstention.

1.

Introduction

1.1.
In presenting this own-initiative opinion, the Economic
and Social Committee is seeking to contribute to the discussion
currently under way on a number of fronts within the EU on
the recycling of waste, and packaging waste in particular. The
key element of this discussion is the forthcoming revision of
Directive 94/62/EC on packaging and packaging waste. This
directive is essentially concerned with targets for the recycling
of packaging waste, which are currently fixed at 25% as a
minimum and 45% as a maximum by weight of the packaging
placed on the market. Five years after its introduction, this
directive has improved levels of non-recovered packaging
waste and the management of household waste. This achieve-
in its present form (1), the directive is
ment shows that,
undoubtedly a first step in the right direction. The present
opinion must also be viewed in the light of the debate within
the Recycling Forum set up at the start of the year (this forum

(1) We also refer to the ESC Opinion of 24 March 1993 on the
Proposal for a Council Directive on packaging and packaging
waste which gave the broadest endorsement to the directive in its
present form.

intends to submit a number of recommendations to the
Commission by the end of 1999 on ways of tackling the
difficulties faced by the EU recycling industry), as well as the
Commission’s future follow-up to these recommendations (in
the form of a communication to the Council and the European
Parliament).

1.2.
The intention is not, of course, to repeat the substantial
work carried out by the Recycling Forum, which deals mainly
with the economic, technological and legal aspects of waste
recycling, or to issue an opinion on the proposed revision of
look at another
Directive 94/62/EC, which the ESC will
time. The present own-initiative opinion asserts the ESC’s
determination to deal with the basic issues underlying the
results — the achievements as well as the shortcomings — of
the recycling sector. The depletion of natural resources and
the importance of conserving our environment make it
essential to retain an approach to recycling which is proactive,
forward-looking and geared to the need to develop outlets.
However, the Committee also feels it is essential to address the
economic considerations connected with packaging waste
recycling. Indeed, the idea of sustainable development meshes
both environmental and economic factors.