Opinion of the Economic and Social Committee on the "Green Paper on Integrated Product Policy"
Date: 2001-07-11
Institutions: European Economic and Social Committee
Subjects: EU programme, consumer information, eco-label, environmental protection, labelling, research and development

17.9.2001

EN

Official Journal of the European Communities

C 260/35

3.5.
Given the numerous and evolving techniques for
producing alcohol from agricultural products, and from prod-
ucts that are themselves produced from agricultural products,
it will be difficult to establish satisfactory definitions for the
various types and even more difficult to police them, especially
for products from third countries.

4. Conclusions

4.1.

The Committee:

— supports the value of better market information and of

— supports the need for a legal framework to provide these;

— suggests that the requirements could be provided in a

number of ways;

— has yet to be convinced of the added value of a CMO

regime for alcohol of agricultural origin;

— insists that any CMO that does not include arrangements
to cover the complete alcohol market will be fatally
flawed;

— considers that if a CMO is established it will need a

dedicated Management Committee;

an established forum to discuss problems in the sector;

— points to the need to harmonise definitions.

Brussels, 11 July 2001.

The President

of the Economic and Social Committee

Göke FRERICHS

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

(2001/C 260/06)

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

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

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

1.

Introduction

1.1.
The Committee is examining the Green Paper in
connection with the Environmental Action Programme’s (1)
new approach which highlights, in tandem with implemen-
tation of
the main-
the existing legislative instruments,
streaming of environmental considerations in EU policies,
involvement of the various stakeholders and the voluntary
dimension. Further, the Committee regards this Green Paper

as an auxiliary instrument for the ‘sustainable development’
strategy, also from the economic and social angle (2). It would
refer to the comments made in its opinions on related subjects,
pointing out that this instrument can only be implemented
satisfactorily in this broader context.

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

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

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

2. Role of stakeholders and local initiatives

1.3.
The proposed approach is based on a wide mix of
instruments but does not go into the details of the link-up
between the new IPP paradigm and existing environmental
policies organised along sectoral and vertical
lines. IPP is
instead defined as being ‘complementary’ to existing legislative
instruments; further study is needed of the interaction between
vertical regulation and voluntary instruments or agreements
so as to ascertain whether the latter could be deployed in the
absence of relevant legislative instruments and be geared to
more ambitious ‘green’ solutions than the current rules and
standards. The Committee would point out that it has in the
past made suggestions to this effect with a view to improving
the environmental performance of products and services,
notably in its opinions on the ‘eco-label’, the ‘Community eco-
management and audit scheme’ (EMAS) and, most recently,
the directive on ‘waste electrical and electronic equipment’ (1).
Point 2.3 of this last opinion pointed out that the eco-label
and EMAS could serve a useful purpose in encouraging more
advanced solutions than those envisaged in the directive.

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

1.5.
Further, the examples given all relate to the industrial
sector whereas the mainstreaming exercise could perhaps be
extended to other sectors, especially as the scope of the
EMAS (2) regulation on environmental certification has already
been enlarged and the services, tourism and agri-food sectors
are now fully involved in a drive to update environmental
standards and to define sustainability indicators.

(1) OJ C 296, 29.9.1997, p. 77; OJ C 209, 22.7.1999, pp. 43-44; OJ

C 116, 20.4.2001, pp. 38-43.
(2) OJ L 114, 24.4.2001, pp. 1-29.

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

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

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

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

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

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

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

3. Strategy to implement the IPP approach

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

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

fuel

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

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

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

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

4. Green consumer demand

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

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

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

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

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In this connection, it should be remembered that the
4.5.
in its opinion on the new eco-label Regulation (1),
ESC,
expressed its opposition to the ‘proliferation’ of green labels
because they could generate confusion in consumers and
prove misleading.

environmental impact of products. The European Environment
Agency (EEA) and national environment agencies will play a
these
leading role in the compilation and circulation of
databases, taking care to ensure that all links in the production
chain, in particular the workforce, are asked to contribute.

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

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

5.

Information on product life cycles

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

Life Cycle Analyses (LCAs) are the main instrument in
5.2.
developing IPP. The Commission recognises the complexity of
such assessments and the relatively high costs of adoption. It
therefore recommends the setting up of publicly available
databases to collect the fullest possible information on product
lifecycles which can be of use to designers, manufacturers,
retailers and consumers for the purposes of evaluating the

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

Brussels, 11 July 2001.

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

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

The adoption of guidelines for eco-design is also
factor in gradually moving towards more

5.5.
an important
environmentally friendly production.

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

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

The President

of the Economic and Social Committee

Göke FRERICHS