Opinion of the european economic and social committee on the "Communication from the Commission on Developing an action plan for environmental technology" (COM(2003) 131 final)
Date: 2003-03-25
Institutions: European Economic and Social Committee
Subjects: ESC opinion, EU environmental policy, action programme, clean technology, sustainable development

5.2.2004

EN

Official Journal of the European Union

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Opinion of the european economic and social committee on the ‘Communication from the
Commission on Developing an action plan for environmental technology’

(COM(2003) 131 final)

(2004/C 32/07)

On 25 March 2003 the Commission decided to consult the European Economic and Social Committee,
under Article 262 of the Treaty establishing the European Community, on the above-mentioned
communication.

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 14 October 2003. The rapporteur
was Mr Nilsson.

At its 403rd plenary session on 29 and 30 October 2003 (meeting of 29 October), the European
Economic and Social Committee adopted the following opinion by 116 votes to 3, with 5 abstentions.

1.

Introduction

1.1.
The Lisbon European Council meeting in March 2000
established what is now known as the Lisbon Strategy: to
develop ‘the most competitive and dynamic knowledge-based
economy in the world’. The Stockholm Council meeting
in March 2001 called for an investigation into how the
environmental technology sector might contribute to growth
and employment. The June 2001 Council meeting in Gothen-
burg set out the ‘strategy for sustainable development’. All the
above underpin the Commission’s ongoing efforts to frame a
strategy and action plan for environmental technology.

1.2.
The Commission’s work is divided into three stages.
The first was a report presented in March 2002 on Environ-
mental Technology for Sustainable Development (1). The
second is the present communication on Developing an action
plan for environmental technology. The third stage is the
action plan that the Commission intends to present by the end
of 2003. This procedure includes an interactive phase in which
all interest groups are able to submit proposals and ideas for
the final draft.

1.3.
Environmental technology must be seen as a continu-
ous process that brings together research and development,
expertise and practical application. While the market is able to
develop the sector on a purely commercial basis, there may be
a need for various forms of support to enable it to push ahead
with development. The EESC wishes to be a strong player in
this respect.

(1) COM(2002) 122 final.

1.4.
The strategy and action plan can also be seen in relation
to other Commission initiatives in which environmental
technology can provide an important tool, e.g.

— The Commission Communication on Integrated Product
impact of

Policy, which addresses the environmental
products from a life-cycle perspective (2).

— The Commission Communication On The Road to
to coordinate
Sustainable Production, which aims
measures to prevent and contain pollution, and where
‘best available technology’ ties in closely with a future
action plan for environmental technology (3).

— The Commission Communication Towards a Thematic
Strategy on the Prevention and Recycling of Waste (4).

1.5.
Another important piece of work in this area is the
own-initiative opinion currently being drawn up by the EESC.
Starting from the premise that there are special obstacles to
the implementation of environmental technologies in the new
member states, the Committee will address the question of
how appropriate small-scale environmental technologies can
be used, or their use promoted, in these countries. Particular
attention will be paid to an assessment of the EU’s aid
programmes under the pre-accession programmes and the
future use of Structural and Cohesion Fund resources (5).

(2) COM(2003) 302 final, EESC opinion under preparation.
(3) COM(2003) 354 final, EESC opinion under preparation.
(4) COM(2003) 301 final, EESC opinion under preparation.
(5) EESC own-initiative opinion on Prospects and realities for appro-
priate environmental technologies in the candidate countries
under preparation.

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2. Gist of the Commission communication

3. EESC comments on the Commission communication

In its March 2002 report, the Commission defines
2.1.
environmental technologies as ‘all technologies whose use
is less environmentally harmful than relevant alternatives’.
However, the Commission extends the definition from cover-
ing only technology that cleans emissions to include tech-
nology that prevents pollution during the production process,
such as new materials, energy- and resource-efficient pro-
duction, environmental science and new methodologies. The
extended definition thus includes technology and know-how.

3.1.
The EESC endorses the focus of the Commission’s
efforts to use various means to promote the development and
commercialisation of technologies that reduce environmental
impact or improve use of resources. Work is ongoing in a
number of Member States, but a European approach is needed
to achieve optimum success through wider dissemination of
best practice. The EESC welcomes the Commission’s approach
to the action plan, involving an open consultation process in
which the EESC, Member State experts and various organis-
ations are invited to take part.

2.2.
Environmental technology is a growing market both
within the EU and internationally. The EU’s eco-industries
directly provided around 1.6 million jobs in 1999 and supply
some EUR 183 billion of goods and services per year. Pollution
management and cleaner technologies account for around
EUR 127 billion and resource management (excluding renew-
able energy plants) around EUR 56 billion. In the candidate
countries, pollution management and cleaner technologies’
eco-industries supply around EUR 10.3 billion of goods and
services a year (equivalent
to 1.9 % of their GDP). The
Commission provides an important contribution to the devel-
opment of new environment-friendly technologies through
the Research Framework Programme.

2.3. Many barriers, such as red tape, higher costs and public
attitudes, continue to prevent the full development and use of
environmental technologies. In particular, economic barriers
are consistently a problem unless true environmental costs are
taken into account. Poor access to finance coupled with long
investment cycles as well as poor dissemination of new
technologies are also issues. Technical barriers show the
need for targeted and more effective research efforts. Also,
technology entry into the market is slowed down by organis-
ational barriers, and a lack of awareness and skills.

The Commission has decided to focus on four environ-
2.4.
mental
issues: climate change, sustainable production and
consumption, water and soil protection. The work is carried
out by four different ‘Issue Groups’, each dealing with its own
specific area. These issues are also linked to the priority areas
identified in the 6th Environmental Action Programme. This
work will form the basis of the future action plan.

2.5.
The Communication is meant to kick off a wide
stakeholders’ consultation on the barriers holding back the
take-up of environmental technologies. All stakeholders have
been asked to provide input for the drafting stage, and their
responses will help prepare an action plan by the end of the
year.

The EESC believes it

3.2.
is important and extremely
positive that the Commission gives a broader definition of
environmental technology instead of confining it to ‘cleaning’
technology. The economic statistics provided by the Com-
mission refer only to the ‘eco-industry’. These 1999 figures —
which, moreover, need updating — only provide a partial
picture of environmental technology’s economic potential.
The challenge for the environmental technology sector is to
gradually improve all production and goods in terms of
environmental performance and resources. It is also important
to appreciate that a significant number of the rolling improve-
ments and efficiency gains that the industry continues to make
have yielded major environmental benefits without the term
‘new environmental technology’ ever being used. Given that
we are striving to achieve sustainable growth, it is important
to define environmental technology if we are to be able to
support it. The broader definition, in which environmental
technology also involves know-how, research and new pro-
duction methods, thus becomes a necessity.

3.3.
The EESC also sees environmental technology as a
strategically important business sector for European firms,
which can eventually enhance European corporate competi-
tiveness, contribute to economic growth and boost employ-
ment. The overall strategy for promoting environmental
technology should be to make it profitable for firms and
provide value added for consumers.

Environmental technology promotion measures pro-
3.4.
vide a back-up instrument that dovetails with other instru-
ments. Other environmental
instruments such as tax and
regulations often increase costs for businesses and can impair
their international competitiveness in the short term. European
corporate competitiveness must be improved if the Lisbon
strategy objectives are to be achieved. Consequently, pro-
motion of environmental technology is a positive step, since it
will enable us to secure environmental gains whilst maintaining
or even improving competitiveness.

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The four issue groups would seem to be a relevant
3.5.
choice since they represent the three basic elements of air,
water and earth, and the societal activity of production and
consumption. The EESC does not believe, however, that ‘air’
should be restricted to climate change, as all air emissions pose
a considerable environmental problem and major environmen-
tal technology development and business opportunities are
most certainly to be found in other air-related environmental
issues. It is also important to realise that these areas impact on
other areas and that solutions and innovations must also be
able to cope with the horizontal perspective. The Committee
also calls for the contribution of environmental technologies
to noise prevention to be included in the work as soon as
possible.

the Commission Communication on Integrated Product Policy,
legislation on public procurement provides ample opportunity
to include an environmental perspective in calls for tender,
and the real challenge is for the purchaser to exploit existing
opportunities. The EESC believes that both the Commission
and the Member States should be at the forefront in meeting
this challenge.

3.9.
The efforts of the Commission, aided by the issue
groups, to identify the various barriers to continued develop-
ment, are important. Stakeholders are best placed to describe
the obstacles they experience.

In a scenario in which environmental technology is
3.6.
being developed and commercialised in the Community, it is
important to manage exports from earlier (and from an
environmental standpoint, worse) production processes. For
example, there might be legislation that makes a certain
product profitable in the EU, but for which older technology
is more profitable in third countries, and therefore the most
widely used. This reduces environmental gains and restricts
opportunities for exporting the new technology. Consequently,
international cooperation on the environment should also
continue to push for optimum harmonisation for environmen-
tal development, whilst third countries and, more especially,
developing countries must be provided with expertise and real
opportunities to harness the technology.

The development and commercialisation of environ-
3.7.
mental technology should be bolstered through various forms
of support. In a scenario in which environmental technology
is pushed through by means of robust economic or legislative
instruments, there is a risk of it leading to reduced export
potential, and to production being transferred beyond Euro-
pean borders where restrictions are less severe. In practice, this
would lead to fewer overall environmental gains and to Europe
exporting its environmental problems to other countries. The
EESC feels this is morally dubious. Moreover, it would reduce
growth potential.

3.8.
Public procurement is a major player and can be
readily used to develop environmental technology and exploit
it commercially. It should be made clear that it is possible
and desirable for tender documentation to include explicit
environmental requirements. The environmental impact of a
product should be assessed from a lifecycle perspective that
includes all
It must be
possible to ensure that new environmental technologies really
do offer an improvement over existing technology. The
Member States should also be able to arrange specific tech-
nology tenders to encourage firms to develop their products,
in exchange for the ‘winning’ concept securing more orders, as
has been done successfully in some countries. According to

impacting factors, e.g.

transport.

3.10.
The EESC would like to see the action plan suggest
how the European and national level can continue to identify
barriers and get
In many
to work on removing them.
large scale technical research is needed to achieve
cases,
environmental gains, e.g. development of fuel cells for vehicles.
However, work is also needed on problem areas for smaller
firms and for small-scale environmental technology break-
throughs. Providing SMEs with support for environmental
investment could be a suitable way of encouraging develop-
ment.

3.11.
As the Commission has pointed out, there are legal
and administrative obstacles to developing environmental
technology. The European Ombudsman is investigating com-
plaints about administrative shortcomings within the EU’s
institutions and bodies. An administrative shortcoming occurs
when a Community institution omits to act in accordance
with binding Community legislation. Whilst legal obstacles to
developing environmental technology can hardly be con-
sidered a matter for the European Ombudsman, the EESC
would like the Commission to suggest where or to whom
individual firms (large or small) might turn if they feel that
either a piece of legislation or action on the part of the
authorities is impacting negatively on the environment. This
‘environmental ombudsman’ should not only ascertain wheth-
er the authorities have complied with legal requirements, but
also identify any shortcomings in existing regulations. The
EESC suggests that the Commission should investigate the case
for establishing an ombudsman in this area.

3.12.
The Commission communication gives an update of
current research. The EESC would stress the importance of
research, and the need for it to take place in close cooperation
with stakeholders. Companies and their organisations must be
involved when research funds are being earmarked for their
field. Corporate research efforts are crucial for product devel-
opment and innovation, but EU research programmes also
highlight the difficulties that small and medium-sized enter-
prises come up against in this area. The action plan should

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place great importance on developing models for corporate
applications of environmental research.

Production and consumption

3.13.
The EESC notes that the Commission focuses on
waste-management issues in production and consumption.
The Committee feels, however, that there is more to this area
than waste issues. If the latter are to be addressed, the policy
focus must be on reducing the amount of waste produced,
more recycling for any remaining waste, and recovery of
materials and energy. Experience from countries such as
France has shown that transport and, consequently, energy
requirements rise if unsuitable waste-sorting systems are put
in place. Product development should therefore be encouraged
to use materials in a resource-friendly manner. Similarly, waste
issues must be addressed from a local/regional perspective in
which solutions are assessed in terms of overall environmental
benefit.

3.14.
If environmental technology is to be a successful
factor in achieving better, cheaper processes, treatment and
know-how, that impact less negatively on the environment,
then new methodologies and techniques will have to be looked
at from a lifecycle perspective. A lifecycle analysis for goods
and products provides a good understanding of how and
where environmental damage occurs in the production chain.
New technology must use a comprehensive approach to show
that products and methodologies really can provide across-the-
board environmental gains. Consequently, the Commission
should include such an approach in its future work on an
action plan for environmental technology.

On the other hand, a product-labelling system
3.16.1.
could be developed to give consumers the information they
need to make an informed decision on environmental perform-
ance, including criteria such as taste, colour, size, image, price,
accessibility and function. A common labelling system already
exists for white goods. These labels tend to focus on energy
efficiency, although they also include criteria such as noise
levels, wash efficiency and water consumption. For office
equipment, there is a labelling system for energy consumption.

3.16.2.
In the section on climate change, the Commission
writes that public-awareness campaigns are an important
factor in cutting emissions. In order to enhance the effective-
ness of such campaigns, the consumer needs to be able to use
this new information constructively when making different
types of purchase. The EESC therefore suggests that the action
plan should state how existing product-labelling systems might
be extended to partially include other groups of product.

A wealth of experience also shows that market
3.16.3.
developments can drive through rapid, major change just as
successfully as regulation and legislation. For this to happen,
consumers and purchasers must be informed and critically
aware. Consumer organisations should be given a bigger role
in disseminating knowledge and information. The Commission
refers to an example of good practice in which industry has
replaced chlorine bleach in paper production with other more
environmentally-friendly methods that do not use chlorine.
This is, however, more an example of a demand- and
market-driven shift towards more environmentally-friendly
production. Industry had long argued that it was difficult or
impossible to change the production process, but as the
market required paper manufacturing to be chlorine free, these
new processes and methods began to take shape, with
the result that chlorine bleach is no longer used in paper
production.

The EESC notes the fact that the Commission has
3.15.
produced a Communication on Integrated Product Policy
(IPP) (1) which can play an important role in developing
environmental technology. For other EESC comments on the
IPP communication, the Committee would refer to its opinion
on the subject.

Water

3.16.
The Commission mentions ongoing research to per-
suade the public to adopt a more resource-based approach and
to focus on quality rather than quantity. This is the correct
approach and would have an immediate, major impact if
individuals could see the significance of their own behaviour
in a wider context. The EESC would also underline here, the
problems in deciding what the consumer should understand
as quality. It is not up to society to interfere and decide what
should be understood as ‘quality’, or when quantity becomes
negative.

3.17.
Turning to the ‘water’ issue group, the focus is on
waste and sewage-sludge treatment. The Commission points
out some key research areas that are relevant but wide-ranging.
Two very important strands of research should also be
mentioned:

— the impact of materials in contact with water, bearing in
mind that tests recognised by all Member States would be
helpful, as would a single EU standard for conformity of
materials;

(1) COM(2003) 302 final.

— real-time analysis, which would permit almost instant

reaction to incidents.

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3.18. With regard to the obstacles, the Commission laments
the somewhat conservative approach to technology of public
and private actors in the water sector. This is doubtless due to
the way the contract documents are drawn up, often with very
specific requirements and leaving little scope for innovative or
recourse to consultants, who tend to recommend tried and
tested technology. More widespread use of performance
tenders would doubtless lead to greater use of more innovative
technology.

Under the proposed directive to give Member
3.20.2.
States the option to make biofuel exempt from duty (3), the
exemption must only apply six years at a time. This means
that investment in biofuel plant is less certain, as write-off time
is considerably greater than six years. Longer term financial
certainty would make investment a more attractive prospect
and encourage environmental technology. The EESC calls on
the European Parliament and the Council to bear this in mind
in the current deliberations.

3.19.
The EESC notes that considerable investments remain
to be made for the installation of new sewage plants and new
networks capable of implementing the objectives of the Waste
Water Directive. Therefore, the EESC supports the focus on
waste water and sewage-sludge treatment. The EESC also
believes that the basic question should be whether the systems
currently in use — whereby we use clean water as a means of
transport, and mix household and industrial pollution together
— are the right ones, or whether we should seek new systems
for the sake of long-term sustainability. In the short term,
however, environmental technology can help achieve lower
material flows and cleaner emissions, but there is also a risk of
maintaining structures that are less than environmentally
friendly.

Climate change

3.20.
One way of complying with the Kyoto Protocol is to
step up use of biofuel, and the Commission communication
refers to previous proposals to encourage the development of
such fuels. The EESC would point to two examples that are of
considerable practical
importance to the development of
biofuel, yet which the proposal sees as hindering it.

In its proposal for a new agricultural policy (1), the
3.20.1.
Commission suggested that it should no longer be possible to
use set-aside land to grow crops for biofuel use, for example.
This would have led to a drastic reduction in biofuel pro-
duction. The EESC argued against this in its opinion (2) on the
subject. The Council followed the EESC’s suggestion at its
meeting in June 2003, so it will continue to be possible to
grow biofuel crops on set-aside land. In addition, a carbon-
dioxide premium for growing biofuel crops will also be
possible under the common agricultural policy. The agricul-
tural sector is also developing more precise methods and
systems that make more accurate use environmental tech-
nology in order to reduce chemical use and make more
efficient use of nutrients.

3.20.3.
Large amounts of carbon dioxide are continuously
seeping into and accumulating in the ground. The balance
between accumulation and breakdown of organic material
determines whether there will be carbon-dioxide emissions or
net absorption.
In order to shore up efforts to reduce
greenhouse-gas emissions, we need to study the potential for
sequestering carbon dioxide in organic carbon sinks, and
the action plan should mention ways of exploiting this
commercially in agriculture and forestry.

Soil protection

3.21.
The Commission communication’s treatment of soil
protection is limited. The EESC hopes that the somewhat
delayed thematic treatment of soil protection will result in
concrete proposals for environmental technology. We can also
see how closely related the soil and air issues are when, for
example, air-borne acid emissions pollute the ground. There is
also a strong connection with climate change, since one of the
greatest threats to the planet is the loss of organic materials,
which also leads to emissions of carbon dioxide — a green-
house gas. The EESC would therefore stress once again the
importance of development in this area, and the need for all
issue groups to be included in a horizontal strategy.

4. Conclusions

— The EESC endorses the Commission’s plans for a Euro-
pean initiative to develop and support environmental
technology, and its choice of four thematic areas: climate
change, sustainable production and consumption, water
and soil protection.

— The EESC endorses the broader definition of environmen-
tal technology as encompassing knowledge, research and
production techniques.

— Environmental technology can be developed into a
strategically important business sector if European cor-
porate competitiveness is enhanced in line with the
Lisbon Strategy.

(1) COM(2003) 23 final — CNS 2003/0006.
(2) EESC opinion 591/2003, OJ C 208, 3.9.2003; pp. 64-71

(3) COM(2001) 547 final, OJ C 103, 30.4.2002.

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— Development and commercialisation of environmental
technology should be enhanced through various forms
of support, rather than through economic and legislative
requirements that might hinder exports and lead to
production being moved to third countries.

— Public procurement can already be exploited to encourage
demand for products and services with an environmental
technology slant.

— Support can also be provided in areas that create
problems for smaller firms, and for small-scale environ-
mental technology successes, perhaps through invest-
ment support.

— The EESC suggests the Commission should indicate to
whom or where individual firms can turn in order to draw
attention to any obstacles posed by legal frameworks or
authorities that lead to environmental deterioration.

— Waste issues must be addressed from a global perspective
in which solutions are also assessed from the local and
regional standpoint.

— Life-cycle analyses must be used to assess whether a new
environmental technology is likely to yield environmental
gains.

— The EESC would stress the difficulty in establishing what
consumers consider to be quality or otherwise, and that
it is not up to society to decide what constitutes ‘quality’,
or when quantity should be considered a negative factor.
A product-labelling system is preferable.

— The EESC believes that market-driven development often
leads to change just as quickly as when change is a result
of regulation and legislation. Consumer organisations can
play a significant role here.

— In the main, clean water must owe its existence to a
lack of pollution in the first place. In the short term,
environmental technology can help to achieve cleaner
emissions.

— The EESC notes that there are still obstacles to ensuring

long-term stability for biofuel production.

Brussels, 29 October 2003.

The President

of the European Economic and Social Committee

Roger BRIESCH