Green paper on integrated product policy
Date: 2001-02-07
Institutions: European Commission
Subjects: environmental protection, fixing of prices, manufactured goods, polluter pays principle, pollution control measures

COMMISSION OF THE EUROPEAN COMMUNITIES

Brussels, 07.02.2001
COM(2001) 68 final

GREEN PAPER ON INTEGRATED PRODUCT POLICY

(presented by the Commission)

TABLE OF CONTENTS

1.

2.

3.

4.

4.1.

4.2.

Introduction.............................................................................................................. 3

The Integrated Product Policy Approach .................................................................. 5

The Role of Stakeholders and Local Initiatives ......................................................... 7

Strategy to Implement the IPP Approach .................................................................. 9

The price mechanism.............................................................................................. 10

Tools and incentives for greener consumption ........................................................ 12

4.2.1. Green consumer demand ........................................................................................ 12

4.2.2.

Public procurement................................................................................................. 15

4.3.

Tools and incentives to strengthen business leadership in greener production ......... 16

4.3.1. Generation of product information.......................................................................... 17

4.3.2. Guidelines for product design ................................................................................. 19

4.3.3.

Standardisation and the New Approach .................................................................. 20

4.3.4.

Product panels ........................................................................................................ 22

4.4.

Other supportive instruments.................................................................................. 23

4.4.1.

Environmental management and audit systems ....................................................... 23

4.4.2. Research, development and innovation ................................................................... 24

4.4.3.

LIFE ................................................................................................................... 25

4.4.4. Accounting and reporting for the environment........................................................ 25

5.

Next steps............................................................................................................... 27

2

1.

INTRODUCTION

Products are fundamental to the wealth of our society and the quality of life we all
enjoy. Rising consumption of products is however, directly or indirectly, also at the
origin of most of the pollution and depletion of resources our society causes. The
challenge we face is to achieve an equitable development for all human beings,
including future generations, while preserving the integrity of
the global
environment, as called for in the 1992 Rio Declaration on Environment and
Development. One way to do so is to aim at a new growth paradigm and a higher
quality of life through wealth creation and competitiveness on the basis of
greener products. Products of the future shall use less resources, have lower
impacts and risks to the environment and prevent waste generation already at the
conception stage.

This Green Paper proposes a strategy to strengthen and refocus product-related
environmental policies to promote the development of a market for greener
products. The ideas put forward are intended to stimulate public discussion on the
proposed strategy and its elements, the prospects opened up for stakeholders and
government in the greening of products, and on the practical means for implementing
and promoting it.

The strategy is based on the Integrated Product Policy approach and intends to
complement existing environmental policies by using so far untapped potential to
improve a broad range of products and services throughout their life cycle from
the mining of raw materials to production, distribution, use, and waste management.
Its central element is the question how the development of greener products and their
uptake by consumers can be achieved most efficiently. Hence, there is no single
preferred instrument of IPP. Rather, there will be a mix of instruments which needs
to be carefully used and fine-tuned to ensure a maximum effect.

The challenges of making products more environmentally friendly have to be taken
up first and foremost by businesses and consumers as the main decisions on the
environmental impacts of products are taken at the design table and in the shops.
Once a product is put on the market, there is relatively little than can be done to
improve its environmental characteristics. Equally, all design efforts will be in vain if
consumers do not buy greener products or use them in an environmentally friendly
way. Therefore, the Integrated Product Policy approach will primarily focus on eco-
design of products and the creation of information and incentives for an efficient
take-up and use of greener products.

The Integrated Product Policy approach and its focus on the life cycle of products
combined with a strong stakeholder co-operation to identify eco-efficient solutions
both for the environment and business development will be a major innovative
element of the 6th Environment Action Programme. Through using the synergies
of environmental improvement and business development it can also contribute to
the goals of the Sustainable Development Strategy currently being prepared by the
European Commission for the Gothenburg Summit.

3

Why a Community IPP approach?

Most products are traded on a global or regional scale and circulate freely within
the Internal Market. Therefore,
it makes sense to develop a product-related
environmental policy not only on a small scale for locally established companies but
for all businesses operating and trading within the Community. A Community IPP
can only be successful if it takes up and integrates the experience gained from local
and national
initiatives and extends this to general business and government
practice.

A Community Integrated Product Policy will therefore be both a framework for
Member States, local authorities, businesses and NGOs to develop their ideas and
spread positive experiences on the greening of products and a driving force through
specific Community policy initiatives where such initiatives are most promising.
This will require that the different levels of action, the Community, national, regional
and local levels as well as government and business-led initiatives work hand in hand
to ensure that a maximum effect of initiatives can be achieved.

Box 1: The steps towards a Community IPP so far.

In 1997, the Commission undertook a study on the development of the IPP approach in Member
States and the use of the product life cycle concept by industry and consumers. A stakeholder
workshop was organised at end-1998. An updating study on developments in Member States was
done in 2000. (Details in Annex I).

in Europe,

in Weimar. In Presidency conclusions1, ‘it was agreed that,

Under the German Presidency, in May 1999, Environment Ministers discussed IPP at the Informal
in seeking to achieve
Council
increasing importance attaches to the impacts on the
sustainable development
environment associated with the pre production process, manufacture, distribution, use and
disposal of products. [...] Environmental policy [...] must concentrate more on developing and
implementing an integrated approach that deals with the entire lifecycle of products. [...] It was
emphasised that efforts to develop environmentally friendly products and improve the conditions
for the success of such products on the European market would also help to strengthen the
competitiveness of European industries. From this perspective, and in view of the necessity of
harmonising as far as possible the standards demanded of products and services within a single
European market and a common currency area, the view was taken that a [...] environmental
product policy was justified at Community level. [...] It was made clear that this new innovative
policy approach does not necessarily lead to additional regulatory measures but is meant to be an
intelligent integration of instruments and measures taking into account existing provisions. [...] The
Ministers therefore welcomed the Commission's intention of submitting [...] a Green Paper
containing proposals for the development of an integrated environmental product policy [...]’.

1

The President’s conclusions on the results of the Informal Meeting of EU Environment Ministers in
Weimar, May 7-9, 1999

4

2.

THE INTEGRATED PRODUCT POLICY APPROACH

impacts of products from the mining of

Integrated Product Policy is an approach which seeks to reduce the life cycle
raw materials to
environmental
production, distribution, use, and waste management. The driving idea is that
integration of environmental impacts at each stage of the life cycle of the product is
essential and should be reflected in decisions of stakeholders.

IPP focuses on those decision points which strongly influence the life cycle
environmental impacts of products and which offer potential for improvement,
the polluter pays
notably eco-design of products,
principle in product prices. It also promotes instruments and tools which target the
whole life cycle of products.

informed consumer choice,

Integrated…

This refers to consideration of the whole life cycle of products covering all stages
from the mining of raw materials to the production, distribution, use, recycling
and/or recovery and final disposal (compare box 2) as well as to a broad approach
integrating various instruments to achieve the goal of greening of products on the
basis of co-operation with stakeholders.

From a stakeholder perspective, if their decisions influence the environmental impact
of products somewhere else in the product life cycle, upstream or downstream, they
must be aware of and take responsibility for the consequences of their actions. From
a policy perspective, policy initiatives focusing on particular life cycle stages must
not merely shift environmental burdens to another stage. Life cycle thinking needs to
be promoted throughout the economy, as part of all decisions on products along with
other criteria such as functionality, health and safety.

…Product…

In principle, all products and services are included in the scope of this policy which
is aimed at achieving an overall improvement of the environmental impacts of
products. In practice, action might address all or only certain products, selected on
the basis of discussions with stakeholders because of their importance and their
scope for improvement. In so far as the IPP approach can usefully be applied to
improve the environmental impact of services, this should not be excluded although
services are not the primary focus of IPP. Nevertheless, services may play an
important role in partly or entirely replacing products (e.g. car sharing; voice mail
instead of answering machines; dematerialisation potential of the “new economy”).

…Policy

The role of public authorities within the IPP approach shall be in most cases one of
facilitation rather than direct intervention. The general idea is that policy should
focus on setting the main objectives and providing the different stakeholders with the
means and incentives to achieve these objectives. Depending on the context, the IPP
approach may also be useful in finding business-oriented solutions of environmental
problems in discussion and co-operation with stakeholders and/or the preparation of
legislation.

5

Although legislation is not the primary focus of IPP, it should be part of a mix of
instruments to be used, if appropriate. This may concern e.g. the legal framework for
voluntary action such as eco-label; New Approach legislation;
legislation if
voluntary approaches do not deliver the envisaged results and legal security is
needed to avoid distortion of competition; and the integration of a more holistic and
life-cycle oriented approach into other types of legislation.

Box 2: Schematic life cycle of a product

Resources

M ater ial + E nergy
proc ess ing

Marketin g

Transport

Recycling

Product
concept
and de sign

Product

Distribu tio n

Cons umption
Use

Final
co nsump tion

W aste

Reco very

Manu factu ring
proces s

Packaging

Supp ly chain

Maintenance,
Repair, Reuse

Disposal

Incin eratio n

En ergy

6

3.

THE ROLE OF STAKEHOLDERS AND LOCAL INITIATIVES

In order to be able to deal with the very broad scope of potential measures to support
the greening of products, the strategy relies on the strong involvement of all
stakeholders on all potential levels of action. An open dialogue and the creation of
incentives to apply a general life cycle thinking in relevant decisions are the main
fundaments upon which an Integrated Product Policy approach should build.

Consumers will benefit through more information and a higher transparency as
regards environmental characteristics of products. Better and more reliable
information in an easier understandable form will allow consumers to make informed
choices in favour of environmentally friendly products. Greener products and
services should offer a higher quality, a longer life and - if environmental impacts are
correctly reflected in product prices - a lower overall cost to the consumer.

Non-governmental organisations will be given the opportunity to contribute as a
partner to the identification of issues and the development of practical solutions
towards reducing environmental impacts of products.

For industry and retailers, Integrated Product Policy offers the opportunity to bring
in their experience to promote a business-oriented approach towards greener markets
on the basis of innovation and economic growth. Businesses will be required to take
an active role in bringing about solutions for the environment within companies and
industry sectors as well as in co-operation with public administration and non-
governmental organisations. Pro-active companies will both have the chance to lead
a market
their experience into market
opportunities. In particular for businesses operating across Member State borders and
non-European companies, a Community framework offers greater consistence of the
European market. Experiences gained on the European market may later be
transferred to the global level, including developing countries. SMEs will profit from
an easier access to information and tools how to reduce the environmental impacts of
products. There will also be a special focus on the product chain as a support for
SMEs to bring about environmental improvements.

transformation process and convert

As many examples show (compare box 3), environmental leadership and business
development go hand in hand. To quote business associations, "Eco-efficiency does
much more than lead a business to a point where environmental benefits balance
costs. It is a leadership practice. It serves those leaders who want to stay ahead of the
curve and look at the future needs of society, natural resource availability and public
perceptions."2 It is these practices which need systematically to be built upon and
broadened to a more general co-operation within industry and between companies,
non-governmental organisations and national and local authorities in order to make
this way of thinking the norm.

2

WBCSD/EPE Memorandum on EEEI to Prodi Group, May 2000

7

Box 3: Greening of products as a business practice3:

Electrolux, a major producer of household electrical appliances has developed a system of
Environmental Performance Indicators to monitor progress in eco-design of their products. Inter
alia, they identified a top group of products with respect to environmental characteristics which
they called “Green Range”. In 1996, sales in the Green Range accounted for 5% of total sales and
8% of gross margins. In 1998 these figures already reached 16% and 24% respectively.

The 3M Company adopted a Pollution Prevention Pays Programme which in the period 1975-96
920 million. During the same period, the
prevented 750 000 tons of pollutants and saved
company achieved an energy efficiency improvement of 58% per unit of production or per square
meter of office and warehouse space in its operations in the United States. In 1996, the company
announced a breakthrough in the process for making medical adhesive tapes that reduces energy
consumption by 77%, cuts solvent use by 1.1 million kg, lowers manufacturing costs and cuts
manufacturing cycle time by 25%.

€

Rank Xerox developed technology to make remanufactured copiers, for which demand now
outstrips supply by about 50%. Of the 80 000 copiers recovered per year, 75% are remanufactured
and the rest are taken apart for reuse or recycling. In 1995, asset recovery allowed Rank Xerox to
avoid

93 million of raw material and component purchases

€

Local initiatives will be a major building block of a Community policy as they allow
a practice-oriented bottom-up approach. These initiatives need to be linked among
each other to allow an efficient communication to build upon practical experiences.
Positive examples (compare box 4) that can be transferred to a larger scale shall be a
major inspiration for the future development of a Community strategy.

IPP will put the challenge to research and development to provide new solutions to
satisfy the needs of human beings with less resource use and environmental impacts.
This will also imply research funding, inter alia within the 5th Research Framework
Programme and beyond.

Box 4: Coup 21. An example for an existing IPP initiative in co-operation
between business and local government

The city of Nuremberg in Germany initiated a network of pro-active companies called “Coup 21”
which is supposed to develop steps to implement the goals of Agenda 21 on a local level4. This
network also comprises a working group on Integrated Product Policy which has set itself the
following objectives:

- Implementing pilot projects for selected industry sectors/companies
- Producing a sustainability guideline with a checklist on IPP focussing on retailing and consumers
- Developing marketing concepts for IPP products
- Collating policy proposals by companies.

3

4

http://www.wbcsd.ch/ee/EEMprofiles/index.htm;
(2000), “Green” Companies:
the OECD Directorate for Science,
Sustainable Development and Industry,
Technology and Industry, Paris: OECD; in: OECD, Background report for the business and industry
policy forum on environmental management: challenges for industry. DSTI/IND(2000)10.
For more information, see: http://www.coup21.de

report prepared for

JUSTUS, Debra

8

4.

5
STRATEGY TO IMPLEMENT THE IPP APPROACH

This chapter presents a strategy with the aim to promote a gradual increase in the
environmental quality of goods and services in a life cycle perspective. This strategy
has been put together with a view to a broad debate both on strategy itself and all its
elements which are in no way fixed and may be changed as a result of the public
debate. With a view to orient this debate, questions have been put at the end of each
section. Comments are however, not bound, to respect this structure and may address
any aspect with relevance to this Green Paper and the strategy to implement the IPP
approach.

In the context of the proposed strategy, promotion of environmental quality of goods
and services means using market forces to the largest possible extent. Indeed, given
the size of the challenge and the multitude of stakeholders involved, the goal can
only be envisaged and reached if the different actors recognise the potential in this
approach and are committed to achieving it.

The success of a product-oriented environment policy therefore depends on its
implementation strategy, on identifying and using the most relevant drivers and the
corresponding instruments to ensure a continuous improvement of the environmental
characteristics of products within the framework of the Internal Market.

As economic interests are a main driver, the instruments probably most effective are
those, like taxes and subsidies, that help to “get the prices right”, to internalise
external costs (Section 4.1). However, as long as this is not the case, supplementary
action to better inform consumers on the environmental characteristics of products
and to encourage producers to develop a better design of products is needed.

interest. Direct

is in their commercial

The most influential supplement in this respect should be “green demand” (Section
4.2). As far as firms are concerned, one can expect
them to improve their
environmental performance, including the environmental quality of their products,
the
when it
improvement of brand image, the perspective of new markets and higher market
shares – these, plus eventually anticipation of regulatory measures, might be listed as
main interests. Image and market share both stand for the influence the consumer can
exercise, whether the consumer is in the private (section 4.2.1) or the public sector
(section 4.2.2). Given the importance of the public sector, its purchasing activity is
one of the most influential factors, allowing for the development of a significant
“green market”. In order to “green” the demand side in general, information plays a
crucial role.

financial cost

savings,

The “greening” of demand, a change of consumer behaviour, can and must be
supplemented by supply side measures (section 4.3). These cover instruments that
encourage firms to apply a life cycle approach for their products. Standards and
product directives (section 4.3.3) and support for product design (section 4.3.2) fall
into this category, as does product information (section 4.3.1). Where a value added

5

An overview of the main actions envisaged in the strategy to implement the IPP approach can be found in
Annex III.

9

can be created by bringing together the different stakeholders to elaborate business-
oriented solutions towards specific problems such as environmental agreements,
product panels on the basis of a variable format adapted to specific issues are
proposed (section 4.3.4).

in particular

impacts of products,

In addition, in order to help this strategy to be implemented, certain new or improved
tools might be needed (section 4.4). It might be necessary, for example, to further
develop and disseminate easily usable life cycle tools that allow a fast check of the
environmental
for small and medium-sized
enterprises. Tools for the management of life cycle environmental information flow
along the product chain might also need further development. Other supportive
instruments for the strategy are environmental management and audit systems
(section 4.4.1) and accounting and reporting for the environment (section 4.4.4). This
new policy approach should also be supported by a well-focused research and
development policy which both supports innovation in the development of
environmentally friendly products and services and gives a better understanding of
the mechanisms which lead to the greening of products (sections 4.4.2 and 4.4.3).

4. What is the overall view of stakeholders on the strategy and its elements?

Does the Green Paper adequately describe the Integrated Product Policy
approach and the issues it is supposed to address?

Is the proposed overall strategy appropriate to effectively implement
the
Integrated Product Policy approach? What suggestions can be made to improve
and supplement the overall strategy?

What are stakeholders views on the various elements of the strategy and how can
they be improved?

4.1.

The price mechanism

The environmental performance of products can best be optimised by the market
once all prices reflect the true environmental costs of products during their life cycle.
However, this is not always the case and there are market failures (“external costs”),
in other words, products and their users may profit from a “free lunch” by causing
environmental
reduce the
environmental impacts of their products and consequently the environmental costs
society has to bear as a whole, it only seems fair that they should profit from a
preferential treatment as regards taxation, state aids etc.

impacts without paying for

If producers

them.

instrument

The most powerful
in favour of more
environmentally friendly products and services is to correct these market failures
according to the polluter pays principle6 by ensuring that the true environmental
cost during the life cycle of products is integrated into the product price.

to transform the market

6

Art. 174(2) of the Amsterdam Treaty

10

In order to provide an evaluation of these external costs, it is essential that objective
criteria are established to assess the environmental performance of products. On the
basis of these criteria, the Commission intends to investigate the main price elements
which are not in conformity with the polluter pays principle and which prevent that
the environmental efforts made by companies are properly rewarded in product
prices. The associated external costs shall be quantified as far as possible. These
investigations should assist
in identifying the main stages of the life cycle of
products, including transport, where external costs occur and in conceiving measures
to better take into account these external costs in the price of new products and/or
elements related to their use7.

Nevertheless, it will neither be straightforward to identify the true external costs of
products and their inputs nor always easy to design broadly accepted policy options
to implement the polluter pays principle. Therefore, it will be necessary to make
simplifications in order to achieve the broader goal of effective and simple measures
to correct market failures that can also be administrated. There are a number of
possible actions which may form a cornerstone of an Integrated Product Policy and
which are suggested as ideas for discussion: The main solution envisaged in this
framework is differentiated taxation according to the environmental performance of
products. A first step might e.g. be to apply reduced VAT rates on products carrying
the European eco-label. Possibilities to do so will be investigated in the framework
of the New VAT Strategy. This could be supplemented by the development and use
of other environmental taxes and charges, tradeable permits etc. on all levels of
government.8 Clearly, these instruments need further evaluation and elaboration and
may apply only in the medium to longer term. Care must be taken that such measures
properly reflect differences in external costs linked to products and that they do not
lead to artificial pricing structures that might hamper competition within the Internal
Market.

The concept of producer responsibility relates to the integration of costs occurring
once the product has been sold into the price of new products. This encourages
prevention at
the design stage and allows consumers to bring back end-of-life
products free of charge. It has recently been integrated into the Directive on End-of-
Life Vehicles9 and the Commission Proposal for a Directive on Waste Electrical and
Electronic Equipment10. This concept should be extended to further areas of
Community and Member State legislation whenever the integration of environmental
concerns into the product design can be usefully achieved in this way. Other ways of
giving incentives to consumers to return end-of-life products such as deposit-refund
systems could also be further investigated.

Within the framework of Community law, Member States should financially support
the development of environmentally friendly products through state aid. Subsidies
having the opposite effect should be reduced as far as possible. On 21 December
the Commission has adopted the new Guidelines on State Aid for
2000,

7 E.g. similar instruments could be used as it is the current practice for cars in the form of taxes on the purchase

8

9

10

of new vehicles, fuel taxes and road pricing.
Taxes and charges for environmental purposes have been discussed in the Commission Communication
on Environmental Taxes and Charges in the Single Market (COM(97)9 final). A further Communication
on the wider aspects of economic instruments in environmental policy is currently planned.
2000/53/EC
COM(2000)347 final

11

Environmental Protection. These Guidelines clarify the possibilities to use aid
measures for environmental purposes in compatibility with the Treaty. The planned
Directive on Environmental Liability should give a strong incentive to companies
to prevent damage for which they could be held liable later.

4.1. How can IPP contribute to getting “the prices right”?

What do stakeholders know about market
environmental impacts of products?

failures

in relation to the

How can product-related economic instruments contribute to correct
these
market failures and what other options could be proposed within an IPP
approach?

4.2.

Tools and incentives for greener consumption

Consumers can make the difference through buying greener products. Their
preference for environmentally friendly products is the major driving force for
companies to reflect upon ways to green their products and win market shares
through innovation and a better design. An important kick-off effect can also come
from public procurement. Public authorities need to take their responsibility and be
the first in creating demand for greener products. The stronger this demand will be,
the faster and more massive will be the shift
towards a more sustainable
consumption.

4.2.1. Green consumer demand

Demand for greener products will be a major driving force for industry to strengthen
their environmental efforts and improve the life cycle performance of their products
and services. Such demand needs to be created and reinforced through a mutual
education process between companies who should actively promote environmental
information and consumers who should challenge companies to improve the
environmental characteristics of their products. Such a process also needs to involve
children who are the consumers of tomorrow. They need to learn the practice of
making informed product choices
their environmental
taking into account
characteristics through their parents, kindergartens and schools.

The goal should be that the power of consumer choice stimulates the potential for
market-driven continuous environmental improvement of products. An example for
such a continuous improvement
triggered by information is the mandatory EU
energy label. It demonstrates that product information can be effective not only in
helping consumers find and choose those products with a better environmental record
but also in spurring manufacturers of white goods to market models with the highest
energy efficiency and to phase-out their worst-performing models.

Consumers must have easy access
to understandable, relevant, credible
readily
information either through labelling on the product or from another
accessible source (e.g. consumer and environmental NGOs, websites, public
authorities).

12

Information about product characteristics is available in different forms and from
information from
including claims made by the producer,
different sources,
consumer organisations, 3rd party verified eco-labels. For most consumer products,
relevant environmental information is not available on the product itself. In many
cases the consumer would need to look hard for the information and would have to
know where to find it. Currently, only the most motivated consumer would do this.

ISO11 has already developed a framework of distinct
types of environmental
labelling, differing in degree of life cycle thinking and methodology, inter alia12.
This is an important and useful base for systems, notably eco-labels. Clarity on label
types promotes comparability and may promote progression from one label type to
another.

Product information on the product through 3rd party verified product labels, (Type
I ISO), like the European eco-label13, is available for a range of product categories.
Eco-labels, whether at national or EU level, are a reference of environmental
excellence among products on the market while guaranteeing a minimal good quality
("fitness for use"). As such, they have an important role to play in sustainable
consumption as they define in a credible,
transparent way, a threshold for
distinguishing the more environmentally friendly products from less environmentally
friendly ones. They set a high standard for all products in a given category which
also other products are measured against. In this way, they have important secondary
effects in influencing the further development of the whole range of products. There
are cases where the eco-label standard later became a general product standard.
Therefore, their scope should be extended to cover as many products as possible,
targeting those product categories for which they are likely to be most effective.

However, these schemes are complex and have not yet used their full potential to
influence the market. Tests must be carried out, the application must be made and
approved, and fees must be paid. To boost the use of eco-label schemes at national
and EU level, these schemes should receive more public funding. This would not
only allow fees to be reduced but, more importantly, would make possible a much
greater marketing effort to promote the knowledge and use of these labels to both
manufacturers, retailers and consumers.

The general philosophy of increasing the amount of product information on the
market calls for flexible and cost-effective solutions. For example, the criteria of
environmental performance developed for product groups, based on a transparent
examination of life cycle considerations, could be more extensively used. This could
be done not only in the labels themselves but in any situation in which the market
needs to distinguish between greener and less green products (e.g. public
self-declarations,
procurement, benchmarking exercises, eco-funds,
essential
aspects of developing these
requirements). Procedures and other
possibilities for effective impact would have to be considered.

indicators,

The question of how relevant, understandable and credible environmental
information can be brought to the wider mass of consumer products in a way that
would help consumers choose those which have the lesser environmental impact is

11

12

13

ISO is International Organisation for Standardisation
ISO 14021:1999, 14024:1999, ISO Type III/TR 14025:2000.
Ecolabel, EUROPA site

13

still open. In this context, with a view to developing a wider labelling strategy, the
Commission intends to review its eco-labelling strategy.

Green claims and self-declarations, ISO Type II, are perhaps most likely for the
foreseeable future to be used on a broad scale. In practice, a lot of environmental
information on products is presented in the form of self-declarations.

The Commission is finalising guidelines for making and assessing environmental
self-declared claims by producers or distributors, based on the ISO 14021:1999
standard, with the objective of preventing misleading claims and encouraging good
ones. A reference to the transposed European standard and to the guidelines may be
made in the Directive on Misleading Advertising, currently under
revision.
Monitoring of claims by Member States and stakeholders is essential.

Product environmental declarations in line with ISO Type III14 are still scarce on
the market but are beginning to come into use, especially in business to business
communication. There may be a need for European co-operation in support of their
use.

information relates

An aspect of
to informed consumer practice. The
environmental impact during the use phase of a product can often be reduced if the
product
is used in conformity with the producer's or consumer organisation's
recommendations. For EU eco-label products, information on the correct use of
products to minimise their environmental impact is often a key requirement. Certain
industries and their associations have started public information campaigns about
this.

Communication technologies, including the Internet, open up ways of making
information more accessible. They offer also the possibility for two-way information
transfer, providing value to producers as well as consumers, in the current context of
highly-differentiated and user-oriented products. This could be the subject of an
exchange of best practice and evaluation.

4.2.1. How can consumer demand be “greened” most effectively?

How can consumer information on the environmental characteristics of
products be improved? How can it be ensured that consumer information
contributes to consumer “knowledge” and “awareness”?

How can the impact and cost-effectiveness of environmental labelling schemes
be increased?

How can consumer awareness and behaviour concerning an environmentally
optimal use of products be improved?

14

More accurately, ISO Type III/TR 14025:2000; consist of quantified environmental data on all significant
impacts based on procedures and results from a life cycle study with additional relevant information e.g.
on environmental management systems or social aspects, if appropriate.

14

4.2.2.

Public procurement

Public procurement represents 12 % of EU GDP on average, but can be as much as
19% in some Member States, for example France15. These numbers underline the
purchasing power of public authorities. Public authorities should take their
responsibility and act as leaders in the process of green management and in changes
of consumption towards greener products. If a substantial part of public authorities
increases their demand for green products this will have an enormous effect on the
market of environmentally friendly products and will get industry to increase their
production of green products substantially.

The EU public procurement rules are of an essentially economic nature but have also
to be seen in the light of the sustainability requirement of Art. 2 of the EC Treaty.
Above a certain threshold in terms of monetary value of the contract, European
Directives apply. They contain specific obligations and procedures, offering, on the
one hand, numerous possibilities to take into account environmental considerations
in public purchases, but, on the other hand, they could, in certain cases, limit the
differentiation in favour of more environmentally sound products or services16. The
Commission will also look at the feasibility of promoting green purchasing by
introducing an obligation to carry out, before purchasing, an assessment of the
environmental impact of the different alternatives available that meet the needs of the
contracting authorities. In this way, decisions will be taken with full awareness of the
environmental consequences. The entry into force of the Amsterdam Treaty and, to
some extent, new legislation could help in this respect. It should be noted that below
the thresholds, public procurement rules are not harmonised, which means that
purchasers are generally freer to prefer green products, although they are bound to
observe other applicable provisions of the Treaty, notably those regarding the free
movement of goods.

There is, however, an even more significant barrier to greening public procurement,
namely that public purchasers generally lack specific information as to what
environmental characteristics they should seek for a given product. This is important
because if the eco-criteria for products are clearly specified in the subject matter of
the contract,
the public sector can purchase environmental products without
constraints.

Systematic awareness raising initiatives of public procurement authorities are
needed. In this regard, the Commission will adopt an Interpretative Communication
on Public Procurement and Environment that addresses the question to what extent it
would be possible to require the use of a specific production process or to take into
consideration all costs incurred during the whole life cycle of a product. A handbook
and/or a communication on Green Public Procurement with examples on how to
draw up green calls for
tenders in conformity with EU law is also under
consideration.

15

16

OECD, 1999, "Greener Public Purchasing: issues and practical solutions", p. 11
see Interpretative document on Community public procurement legislation and the possibilities for taking
account of environmental considerations in public procurement
(Commission Communication in
preparation)

15

In order to facilitate the access to product criteria for the call for tenders a network
to exchange best practice of databases of eco-product criteria for public authorities
might be discussed, based on existing initiatives in Member States and on the
existing EU eco-label criteria. The Commission could co-ordinate and facilitate such
an information exchange, inter alia via internet.

The Commission intends to take the lead in greening its procurement activities, thus
stimulating the dissemination and development of environmentally friendly products.
the Commission will, within the framework of public
Wherever available,
procurement law, give preference to products which fulfil the requirements of the EU
ecolabel criteria. The Commission intends to register under the EMAS17 scheme and
encourages other public authorities also to follow this example. This process shall be
evaluated with a view to increase the number of purchased environmentally friendly
products gradually. An evaluation of this experience shall be published and made
available to Member States and local authorities.

4.2.2. How can “green” public procurement be promoted?

What should be the role of “green” public procurement within an IPP
approach?

What obstacles need to be overcome in order to “green” public procurement?
How can it be stimulated?

4.3.

Tools and incentives to strengthen business leadership in greener production

Successful businesses are ahead of future developments in taking up market
opportunities. Good environmental management and product design is a key to future
market shares in a sustainable economy. Thus, it is not surprising that the leading
companies in business development are also those who are most advanced in
greening their products. From December 1993 to August 2000, the companies that
are part of the Dow Jones Sustainability Group Index have outperformed the general
Dow Jones Global Index by 86.5%18. The challenge for an Integrated Product Policy
Approach is to reinforce and broaden this move towards sustainability to ensure a
faster change towards greener products. To do so, measures are envisaged to
encourage the development and availability of tools to improve the environmental
performance of products and to strengthen incentives for businesses to take the lead
in becoming sustainable companies.

17

18

Community Environmental Management and Audit System
The DJSGI is based on the economic performance of companies (products and services) which were
identified as sustainability leaders according to a number of criteria. These criteria may be debatable in
their detail but are globally one of the very few attempts to identify proactive companies and compare
their performance to the general stock market. The companies that are part of the DJSGI have increased
their share values from December 1993 to August 2000 by +240.6% while the general DJGI has risen by
+174.1%.

16

4.3.1. Generation of product information

in the market

For a sustained shift
towards taking environmental aspects into
account, it is important that stakeholders have and use information on the life cycle
environmental impacts of the products or components about which they are deciding.
In general, the availability, user-orientation and leverage in the market of accurate,
non-misleading information needs to increase.

– Manufacturers should know the environmental profile of the components they are

incorporating in their products.

– Designers should examine life cycle impacts of their choices and have easy access

to existing life cycle data and methodologies to do so.

– Producers should pass on information down the chain to consumers and buyers in

an easily accessible form.

– Retailers, consumers and buyers should recognise which are greener products.

In order to improve the life cycle performance of a product, it is necessary to
understand it. Therefore, a first step in spreading life cycle thinking throughout the
economy is the generation and collation of
information on the life cycle
environmental impacts of products.

Such information can be assembled in Life Cycle Inventories (LCIs) and interpreted
in Life Cycle Analyses19 (LCAs). LCIs and LCAs are neither simple nor cheap to put
together. Some elements are in the public domain, others not. Their value depends on
their quality and on their relevance to the user's needs and options. The Commission
considers the development and collation of easily available life cycle information a
priority. Ways to do so could be to harmonise and eventually link existing life cycle
information and, if appropriate, set up new databases that conform to agreed data
standards. The public availability through databases of existing standard life cycle
data will be encouraged in co-operation with consumer and industry organisations as
well as relevant agencies such as national environmental protection agencies and the
European Environment Agency. Links to other relevant
information (e.g. best
practices of life cycle performance among product groups, new technologies of
environmental interest) shall also be made more easily accessible.

Tools should be developed and made available which allow a fast check of the
environmental impacts of products, in particular for those actors such as small and
medium-sized enterprises who do not dispose of the expertise and resources to
conduct life cycle analyses themselves. Similar tools should address the management
of life cycle environmental information flow along the product chain. Benchmarks,
technological state of the art, key performance indicators, guidelines for design (see
Section 4.3.2), standards (see Section 4.3.3), should be developed to serve as
yardsticks against which producers and consumers could compare the environmental
characteristics of particular products.

19

Life Cycle Analysis (LCA) is a method for assessing the environmental aspects and potential impacts
associated with a product, by compiling an inventory of relevant inputs and outputs of the defined system,
evaluating the potential environmental impacts associated with these inputs and outputs, and interpreting
the results. In practice, LCAs may be deliberately simplified or their scope may be limited, but in
principle, they are comprehensive, systematic tools.

17

The Commission intends to host one or several expert workshops on practical
options and needs.

The goal of the IPP approach is not necessarily to require full life cycle analysis for
all relevant decisions. More important is the identification of key information and its
translation into a general life cycle thinking.

A possible instrument to increase the generation and availability of information is to
oblige and/or encourage producers to supply key data along the product chain and
and its
to consumers. The details of
implementation would have to be worked out and evaluated according to cost-
effectiveness criteria. Existing initiatives of producers and other stakeholders could
be used as a source of inspiration for such measures. Examples for such initiatives
are:

such an obligation/encouragement

• The Supply Chain Management initiative of EICTA (European Information and
the objective of
Communications Technology Industry Association) has
developing a common European supply chain management approach for the
electronics industry, simplifying data collection for both the requestor and the
supplier whilst driving environmental improvements in supplied items. This will
ensure a common list of reportable materials and a common template for
providing product information. It will allow comparisons on critical materials to
be made between suppliers.

• In the automotive sector, the End-of-Life Vehicles Directive has encouraged
automotive manufacturers to form a strategic alliance to develop a common IT
system to collect data on product materials, called the International Material Data
System (IMDS). This central database will allow each part of the supply chain to
input data on their products. As a hierarchical database, car manufacturers can
then collate information at various levels to be able to supply reports on the
composition of the vehicle itself, as the sum of its various components. Full
compositional data is disclosed tier by tier by direct interaction with the database.
Charging for access to reports pays for maintenance of the system. EICTA is
investigating whether to integrate their scheme into the IMDS system.

There are various options for the role of initiatives to be created and/or further
developed within an IPP framework. One option could be based on information on a
set of broadly-applicable criteria, guided by environmental policy objectives and
established design guidelines. Another could be to focus on information relatively
easily known to producers, understandable and verifiable by consumers themselves,
such as expected product lifetime, expected cost of disposal, guarantee of repairs,
expected running costs.

18

4.3.1. How can more reliable information be generated on the environmental
characteristics of products?

What role can the provision of
approach?

information play to implement

the IPP

What initiatives can be taken to promote the generation, flow, availability and
use of life cycle related information and should they be voluntary or mandatory?

How can IPP contribute to further develop and link these initiatives?

Can obligatory key data/information provide added value to voluntary schemes?

4.3.2. Guidelines for product design

One form of information which might be particularly effective in promoting life
cycle thinking among companies is eco-design guidelines. Work has been carried out
in various fora, including ISO/TC 207, on general and product group-specific design
guidelines.

The development of a generalised strategy for the integration of the environment into
the design process will need to take into account the complexity and the diversity of
products and the rapidly evolving knowledge and know-how in the design field.

Such a strategy should be geared to

– optimisation of the service provided by the product;

– conservation of resources;

– reduction of waste;

– reduction of pollution;

– reduction of hazards and risks.

Design concepts to pursue these goals include

– design for cleaner production and use; (examples: source reduction, leading to

reduced mass, less wastes; minimal energy consumption);

– design

for

reduction/substitution;

environmentally unfriendly materials,
consumption);

– design for use of renewable materials;

(of

hazardous,
in the product or

toxic

or

otherwise
in accompanying

– design for durability; (examples: reparability, maintainability);

– design for longevity; (examples: upgradability; classic design, accommodation of

future needs);

19

– design for extended function; (examples: multifunctionality, modularity);

– design for reuse and recycling; (examples: simple disassembly, reduced material
recovery

complexity, use of recyclable and recycled materials; component
through closed loop re-manufacturing and secondary applications);

– design for simplicity; (should lead to lower manufacturing costs, lower material
mass, greater durability, easier disassembly for maintenance or asset recovery).

to encourage the elaboration, dissemination and
The Commission intends
application of such guidelines. They shall also be integrated into the development of
Community initiatives, e.g. in the framework of the New Approach (Section 4.3.3),
specific product regulations and environmental labels (Section 4.2.1).

4.3.2. How can environmental aspects become a key feature of product design?

What activities on environmental design guidelines exist? How can the
Community contribute to the development, dissemination and application of
such guidelines?

How can eco-design guidelines be integrated in ongoing and future Community
initiatives

4.3.3.

Standardisation and the New Approach

Out of the five thousand or so European standards implemented today, many are
product standards. Some are applied without a legislative background, some are in
support of regulation, e.g.
the New Approach. Today product certification in
accordance with a specific European standard confirms "fitness for use" and "safety
for the user". It is highly desirable that in the near future the idea of "environmental
soundness“ is also associated systematically with products meeting a European
standard.

Standards20 are the result of a consensus-driven process which is open to all
interested parties. Although standards are generally non-binding, they set important
rules, which are in many cases applied throughout the market. Standards can be an
important element influencing the environmental impact of products.

standards,

alternative

Beyond formal
(e.g. Workshop
Agreements) have been developed by the standards organisations. These "New
Deliverables" do not undergo all procedural requirements of formal standards but can
rapidly be elaborated as consensual solutions to quickly evolving market needs or
less stable innovations.

forms of consensus

20

"By ensuring that all enterprises providing a product or service do so within a verifiable and measurable set of
technical or professional norms, standards can level the playing field in areas of collective concern ranging from
public health, safety, environment and products/process/service quality. In this way, a number of standards become
mandatory either as an expression of regulatory intention or more spontaneously, through the interplay of the market
technical regulations and "de facto" mandatory standards); OECD1998, "What do standards for
forces (i.e.
environmental management system offer?", p.17

20

Proposals to better use standardisation in the context of the IPP approach could
include:

• Developing standards or other consensus driven products of

relevance to

environmental protection.

• Incorporating environmental aspects

in the process of European product
standardisation, e.g. when developing new and reviewing existing product
standards.

• Developing and applying environmental guidelines for the formulation of new

product standards and reformulation of existing ones.

The Commission intends to co-operate with the standardisation bodies and relevant
stakeholders to develop mechanisms to integrate systematically environmental
characteristics into product standards. Ways need to be found to advance the
greening of standardisation through the participation of civil society actors.
Furthermore, discussions are currently under way how to improve and enlarge the
role of the environmental help desk of CEN.

Another prospective field of action closely related to standardisation is the potential
of New Approach legislation for promoting eco-design. New Approach directives
are total harmonisation measures that define binding essential
requirements.
Producers are free to choose the means by which they demonstrate that products
comply with the essential requirements. One way of doing so is by applying
“harmonised standards” developed by CEN, CENELEC and ETSI21 following a
mandate of the Commission. Compliance with these harmonised standards gives
presumption of conformity with the relevant legislation and allows the product to
circulate freely within the Internal Market.

The New Approach and standardisation have become a central and successful pillar
of Community legislation on health and safety aspects of product design. The so far
only experience of using the New Approach technique specifically for environmental
design of products is the Packaging and Packaging Waste Directive22 although there
are discussions on the completeness and appropriateness of the New Approach
elements of this directive. Similarly, the standards elaborated on this basis have
raised substantial debate. The mixed experience with the Packaging and Packaging
Waste Directive should be taken as a basis to launch a debate on how the New
Approach could be best applied in new initiatives such as the planned Directive on
Electrical and Electronic Equipment (EEE). The objective of this planned directive is
to ensure a continuous and sustained improvement in the overall environmental
impact and resource consumption of EEE by integrating a holistic approach to
environmental thinking into the product development process while assuring the free
circulation of goods in the internal market.

Some ideas on options to deal with the particularities of eco-design within the
framework of the New Approach are laid down in Annex II.

21

22

CEN, CENELEC, ETSI are, respectively, European Committee for Standardisation, European Committee
for Electrotechnical Standardisation, European Telecommunication Standards Institute
94/62/EC

21

4.3.3. How can IPP contribute to greening the standardisation process and to
use the potential of New Approach legislation optimally?

How can environmental characteristics become an integral part of
standardisation process?

the

How can the New Approach legislation contribute to the promotion of
environmental characteristics of products (compare also Annex II)?

4.3.4.

Product panels

Economic operators are in general ready to embrace environmental considerations
into product design and manufacturing as long as this does not substantially
compromise their competitive position. Equally, consumers will prefer greener
products as long as there is no disproportionate price difference. In many cases, it
will therefore be sufficient to create a momentum for environmental improvements
of products by launching a debate among stakeholders. This allows faster and more
business-oriented reactions and can resolve environmental problems before
legislation is needed.

the purpose of

One possible route towards this goal would be to set up stakeholder groups to work
on how environmental goals can be achieved or obstacles overcome in relation to
their particular product group. For
the IPP approach, such
stakeholder groups can be called product panels. Such panels can be set up in
various formats and need to be adapted to the issues considered. Such issues may
concern the overall environmental performance of specific products or product
groups but also specific issues for one or several product groups (e.g. the reduction
of hazardous substances in particular products or product groups). In some cases,
these panels may be largely self-organised, in other cases public authorities and the
European Commission may be more closely involved. There is also similarity to the
mechanism of workshop agreements used by the European standardisation bodies23.
Such workshop agreements may also be used for similar purposes, depending on the
context.

In order to ensure an efficient use of resources, it should however be made sure that
such panels are only set up in cases in which there is potential for substantial
progress towards EU environmental objectives. Other pre-conditions should be the
readiness of stakeholders to work together, acceptance of reasonable conditions of
transparency, participation,
information quality etc, and some indication that
stakeholders might be ready to act after the panel's work is completed. Examples of
similar initiatives are Auto-Oil and the various panels organised in Denmark.

An efficient discussion needs preparation. An initial analysis of the issues to be dealt
with should be prepared to allow the discussion to take place on a common
understanding. The tasks of the panels should be clearly and practically defined.
Time limits should be set to avoid the risk of protracted discussions without tangible
results. Finally, an appropriate evaluation of the results should be made. In case of

23

compare annex II

22

failure to produce the envisaged results, the work of these panels can be used to
prepare other instruments such as regulation.

4.3.4. How can the design process of products be influenced to better take into
account environmental factors?

Are product panels suitable solutions and how can they be organised in
practice?

Is there any experience available from similar initiatives?

4.4.

Other supportive instruments

There are a number of instruments which, although not primarily focused on
products, might stimulate operators to follow a life cycle approach. These
instruments include the environmental management and audit systems ISO 14001
and EMAS, environmental reporting,
the LIFE instrument and research and
development.

4.4.1. Environmental management and audit systems

Environmental management systems are designed to help companies to improve their
environmental performance including the life cycle performance of their products,
activities and services. They allow organisations to have a clear picture of their
environmental impacts, help them to target the significant ones and manage them
well. Environmental management systems also help to introduce a change in
management style by bringing environmental issues into the day to day management
of companies.

The European EMAS Regulation24 adopted on 29 June 1993 and the subsequent
international standard ISO 14001 are applied by a rising number of companies and
other organisations.

EMAS II will, in the same way as the ISO standard, cover not only the industry
sector but all sectors and will concern not
impacts of
economic activities, but also of their products and services.

the environmental

just

Such environmental management systems can therefore help to spread the IPP
approach throughout the European Union. Firstly, because they initiate management
change and secondly because they provide environmental information and ways to
manage this information which correspond well to the IPP approach.

The condition for this is that these voluntary instruments are applied on a broad basis
covering a high percentage of economic activities. For organisations, environmental
management means efficiency and environmental improvements as well as financial

24

Council Regulation (EEC) No 1836/93 allowing voluntary participation by companies in the industrial sector
in a Community eco-management and audit-scheme. The revision of the existing EMAS Regulation (EMAS
II), which will be adopted soon, takes over the international standard ISO 14001 as the environmental
management system component of EMAS, so that in future both systems are compatible.

23

In addition, EMAS should bring in future ‘regulatory benefits’

benefits and better image. For interested parties and the public, it signifies that
organisations are taking seriously their responsibility in relation to environmental
issues.
for
participating organisations. Member States are supposed to consider how EMAS
registration may be taken into account in the implementation and enforcement of
lead to environmental controls taking into
environmental
account the EMAS implementation through lightened frequency or bureaucracy;
more flexible reporting and permit procedures and, in certain cases, subsidies for the
implementation of the management system and registration fees.

legislation. This will

In order to allow public authorities to have a better overview of the potential
incentives for EMAS registration the Commission services intend to organise an
exchange of views amongst the Member States once the new EMAS Regulation has
been adopted. As indicated in section 4.2.2, the Commission also intends to register
itself under the EMAS scheme.

4.4.1. How can environmental management systems contribute to the greening
of products?

4.4.2. Research, development and innovation

The IPP approach is based on the idea that there can be a new dynamic in which
producers find incentives to include environmental aspects in their strategic thinking
and in their product design. This business-internal momentum for innovation should
be reinforced through assistance by research and development Programmes. Ongoing
Programmes include e.g. the Growth Programme within 5th Community Research
Framework Programme which, inter alia, supports research for more environmentally
friendly electrical and electronic products. Such research Programmes support
conceptual, organisational and technical innovations to meet future needs of society
with substantially less resource use and lower environmental impacts. The link
between Integrated Product Policy and such Programmes needs to be strengthened
and extended on all levels where research is funded and also with a view to making
the development of greener products and services a priority for the 6th Community
Research Framework Programme.

To better promote innovation, the drivers for environmental product design, changes
in the market, system-level changes, evolving societal needs, futures scenarios etc.
need to be better understood. Further efforts need to be made to develop, harmonise
and diffuse the Life Cycle Analysis methodology and to facilitate its easy
application, in particular by small and medium sized companies. In order to facilitate
life-cycle assessment in SMEs, research could include the development of more
simplified methodologies. In addition, research could contribute to identifying
product categories that have a considerable impact on the environment, and could
contribute to conducting detailed LCAs of such products.

The Community and other authorities should provide facilities to fund projects and
networks wherever research and development Programmes can have a substantial
impact in triggering innovations for new, more environmentally friendly products
and service systems.

24

From a policy perspective, evaluation of the effectiveness of instruments and
indicators of progress will be a continuing requirement. The broadly-based change in
products and consumption sought via the IPP approach presents challenges. Research
could help, in developing indicators, for example.

4.4.2. How can the Community Research and Development Programmes
contribute to IPP?

4.4.3.

LIFE

LIFE25 is the only instrument which specifically supports in financial terms the
development of Community environmental policy as described in the consecutive
Community action programmes. The new Life III Regulation was published in July
the
2000 and has brought
implementation of the IPP approach.

significant and very positive opportunities

for

LIFE III has widened the scope for innovative and demonstration projects designed
to promote sustainable development and for preparatory measures designed to
develop or revise Community policy.

The specific objective of LIFE-Environment is to contribute to the development of
innovative and integrated techniques and methods. The LIFE guidelines on
demonstration projects mention the IPP approach as one of five specific objectives,
along with land use development, water and waste management and impacts of
economic activities.

There is a particular focus on demonstration projects dealing with eco-design, eco-
efficiency and green financial products (investment funds, credit or insurance
facilities linked to environmental criteria) as well as eco-labelling.

4.4.3. How can the LIFE programme contribute to IPP?

4.4.4. Accounting and reporting for the environment

Accounting and reporting for the environment has become increasingly relevant to
enterprises. Moreover, how the environmental performance of an enterprise affects
its financial health is of growing interest and sometimes concern to investors,
creditors, governments, and the public at large. The Annual/Financial Report of a
company is the principal way in which stakeholders keep themselves informed of the
activities, progress and future plans of a company. However, currently there is no
standard way of presenting environmental information and no analytical standards
for their interpretation. This weakens the impact of financial reporting.

25

LIFE is a Community financial instrument for three major areas of action: Environment, Nature and Third
Countries.

25

The Commission has undertaken a study in order to identify disclosures that allow
for standardisation and comparability of environmental information being presented
in corporate Annual/Financial Reports. Guidelines on how to incorporate
environmental costs and benefits into a company’s annual account might follow.

4.4.4. How can financial reporting systems contribute to the “greening” of
products?

26

5.

NEXT STEPS

The purpose of this Green Paper is to initiate a public debate on the proposed
strategy and its elements as well as the prospects opened up for stakeholders,
governments and the environment in the greening of products and the IPP approach.
This debate shall both address the ways how an EU framework shall be set up and
the practical means for implementing such a framework26.

This will in particular involve discussion of this paper in the European Institutions,
in particular the Council and the European Parliament who will be closely associated
to the further development of the Integrated Product Policy approach and its
elements. The Commission also intends to use and support the informal European
IPP network of Member State experts as a forum for discussion and exchange of
experience on the subjects of the Green Paper and Integrated Product Policy in
general.

For all other stakeholders such as local governments, business and consumer
associations, non-governmental organisations and other interested actors who wish to
take part in this debate, the Commission will organise a number of stakeholder
consultation events, focused on major topics in this Green Paper. They will be
announced
http://www.europa.eu.int/comm/
environment/ipp/home.htm. The summaries of discussions and the main conclusions
will published on the same site. Requests27 to participate in such stakeholder events
can be addressed to the following e-mail address: env-ippstakeholder@cec.eu.int.

the Commission's website:

on

Written comments by stakeholders should be sent to the Commission at the latest
on 30 June 2001. Submissions should be addressed to Mrs. Marianne Klingbeil,
Head of the Unit on Industry, Internal Markets, Products, Voluntary Approaches
(DG Environment E.4), 200 rue de la Loi / Wetstraat 200, B-1049 Bruxelles/Brussel,
Belgium. Comments may alternatively be sent by e-mail to the following address:
env-ippstakeholder@cec.eu.int . The various language versions of the Green Paper as
well as related documents can be found at
the following internet address:
http://www.europa.eu.int/comm/environment/ipp/home.htm.

The outcome of the debate should provide an insight into how the IPP approach can
be best
integrated into environment policy. The debate will be the basis for a
Communication which is planned for the second half of 2001. This Communication
will contain a summary of the debate and set out the conclusions of the Commission
for the implementation of the IPP approach.

As the Integrated Product Policy approach is based to an extent on existing
initiatives, there will be ongoing work on these instruments in parallel. As indicated
in this paper, there is also the intention to set up a limited number of test cases, in
particular for product panels.

26

27

An overview of the main actions envisaged in the strategy to implement the IPP approach can be found in
Annex III
They should contain a description of the stakeholder and his/her particular interests on Integrated Product
Policy. Invitations will be sent out according to the number of available places. As a rule, only one
member per association will be accepted and no funding will be provided unless specific reasons can be
brought forward.

27

ANNEX I: IPP studies and stakeholder consultations

In 1997, the Commission contracted a study on integrated product policy (IPP)28,
characterising it as a comprehensive approach, addressing actions, actors and impacts
along the whole life cycle of products. The study looked at the development of IPP in
Member States and the use of the product
life cycle concept by industry and
consumers. The authors put forward a general analysis of IPP, constructed around
five "building blocks" of policy initiatives, on the themes of waste, innovation,
responsibility. They saw the role of an EU policy as
markets,
articulating a common vision of what IPP is trying to achieve, diffusion of best
practice,
in EU policies, and some specific EU IPP
measures.

integration of the concept

information,

involvement.

With this study as a basis, the Commission organised a stakeholder workshop at the
end of 1998. The topics raised were broad-ranging. General conclusions underlined
life cycle approach and the related
consensus around the interest of a product
stakeholder
Information along the product chain was seen as
fundamentally important. A number of instruments were recognised as relevant:
environmental management systems in industry, environmental labelling of products,
integration of environmental considerations into product standards, greening of
public procurement, environmental agreements. A need was expressed for more
clarity on the vision which IPP represents, its overall purpose and objectives.

A follow-up study on recent developments in IPP policies in Member States and
implications for EU policy29 confirmed that the majority of Member States do not yet
have an active policy. For those which do, despite there being reasonable consensus
there is considerable diversity as regards
on key principles underpinning IPP,
implementation. Most Member States seem to be keen for the Commission to take a
lead, to aid those which have not yet taken action or to define a framework which
will apply consistently across the Community.

28

29

Ernst & Young/SPRU for the European Commission 1998, Integrated Product Policy. The executive
summary of the study can be downloaded from the Commission IPP website (http://www.europa.eu.int/
comm/environment/ipp/home.htm).
Ernst & Young for the European Commission 2000, Developing the Foundation for Integrated Product
Policy in the EU. The
IPP website
(http://www.europa.eu.int/
comm/environment/ipp/home.htm).

study can be downloaded

from the Commission

28

ANNEX II: Options to deal with the particularities of eco-design within the
framework of the New Approach

The following options are intended as practical ideas for a debate on how the
difficulties encountered in the application of the New Approach in the Packaging
Directive could be avoided in future New Approach legislation on environmental
design of products.

1) Environmental management systems and/or eco-design guidelines coupled with
the use of
the enforcement system to raise ideas on possible life cycle
improvements.

As the experience of the Packaging Directive shows, it is difficult to define clear and
unequivocal essential requirements and standards, which can be used for yes/no
decisions on the conformity of products. An idea might therefore be to use criteria
related to the process of design decisions as essential requirements instead of
to control.
concrete requirements for the final product which may be difficult
Requirements related to the design process may be established e.g. on the basis of
environmental management systems such as ISO 14000/EMAS and/or eco-design
guidelines.

Instead of
immediate decisions on the conformity of products, enforcement
authorities could raise issues where the environmental characteristics of products
could be improved directly with producers. If appropriate, such issues could also be
put to a broader discussion within industry associations or be brought to the attention
of authorities who could then decide on the most appropriate follow-up.

2) The use of “New Deliverables” such as workshop agreements

The improvement of environmental characteristics of products should be a
it might be appropriate to update
continuous and ongoing process. Therefore,
environmental standards to technological developments more often than this is
possible under the procedural requirements for formal standards. Such a fast-track
approach could take the form of “New Deliverables”. “New Deliverables” could first
be developed as workshop agreements. When their usefulness has been established,
they could be upgraded to formal standards giving real proof of conformity. The
advantage of this process is that
it allows dissemination of such consensus
agreements. Similar approaches have been developed in other sectors with rapidly
developing sectors, e.g. information technology.

3) The use of eco-label criteria as giving presumption of conformity

their
Products bearing an eco-label are particularly advanced as
environmental characteristics. It is therefore only logical that such products should
profit
from an automatic presumption of conformity with legislation on
environmental design of products.

regards

29

4) The use of key performance indicators to define essential requirements

Two variations of this approach are possible: In one, clarity on what
the key
environmental performance indicators are for the products in question is sought
before essential requirements are defined and is directly reflected in the formulation
of the requirements. In the second, essential requirements are formulated in a rather
flexible way, consensus on the key performance indicators is developed by some
mechanism after, which in its turn could be an aid in any formulation and
implementation of standards. This approach requires the identification of valid
indicators that can be applied throughout the product groups in question.

5) Combining various elements

The above options along with the classical way of New Approach legislation need
not to be seen as incompatible. An option could be e.g. to define clear pass/fail
requirements for environmental characteristics of products in essential requirements,
standards and/or workshop agreements where this is possible. Eco-design guidelines
could then be used for other aspects of the same legislation. Moreover, it might be
appropriate to complement such New Approach legislation by classical legislation, in
particular for politically contentious issues which are difficult to be dealt with by
consensus-driven organisations such as standardisation bodies.

30

ANNEX III: Summary of the main instruments and actions

INSTRUMENT

PROPOSED ACTION

Economic
instruments

•

•

Identify price elements which prevent a more ready take up of
greener products in the market

Investigate options for differentiated taxation (e.g. reduced VAT rate
for eco-labelled products within New VAT Strategy) etc.

Producer
responsibility

• Extend the concept to further areas of Community legislation

• Encourage Member State initiatives

Eco-labels

• Extend to more products

• More public funding for marketing and fees

• Review the Community eco-labelling strategy

• Use eco-label criteria for other applications (e.g. procurement,

benchmarking, eco-funds, indicators, essential requirements)

• Prepare monitoring of the use of environmental self-declared claims

• Set up a framework to support declarations in line with ISO Type III

• Adopt an Interpretative Communication on Public Procurement and

the Environment

Environmental
declarations

Public
procurement

Product
Information

• Draw up a Handbook on Green Public Procurement

• Co-ordinate and facilitate an information exchange on GPP

• Green the Commission’s own public procurement

• Link existing information on life cycle impacts of products

• Support

the development and dissemination of easily applicable
tools to evaluate life cycle impacts of products (in particular for
SMEs) and to improve the information flow along the product chain

• Host workshops on the most-efficient ways to achieve these goals

•

Investigate the potential for schemes to oblige/encourage producers
to provide key information on environmental product characteristics

Eco-design
guidelines

• Encourage the elaboration, dissemination and application of such

guidelines

31

Standards

• Support the development of standards on the environmental design

• Find ways and means in co-operation with all stakeholders to
achieve that “environmental soundness” will be systematically
associated with all European standards

New Approach

• Review the potential of New Approach legislation to encourage

greener product design

• Ensure an optimal use of the New Approach in legislation such as

the planned Directive on Electrical and Electronic Equipment

Product panels

• Develop the framework for product panels

Supportive
Instruments

• Launch one or two pilot projects in 2001

• Make the link with EMAS

• Ensure that green product innovation is a key part of Community
Research and Development programmes (FP5, Growth Program;
FP6)

• Put a focus of the LIFE programme on the greening of products

•

Investigate the potential of environmental reporting

32