Communication from the Commission to the Council and the European Parliament - Integrated Product Policy - Building on Environmental Life-Cycle Thinking
Date: 2003-06-18
Institutions: European Commission
Subjects: consumption, environmental policy, environmental protection, goods and services, production

COMMISSION OF THE EUROPEAN COMMUNITIES

Brussels, 18.6.2003
COM(2003) 302 final

COMMUNICATION FROM THE COMMISSION TO THE COUNCIL
AND THE EUROPEAN PARLIAMENT

Integrated Product Policy
Building on Environmental Life-Cycle Thinking

1. 

INTRODUCTION

One  of  the  European  Union’s  fundamental  objectives  is  sustainable  development.
This means meeting the needs of the present generation without compromising those
of  future  generations.  This  objective  was  reinforced  at  the  Gothenburg  European
Council  in  2001,  where  an  environmental  dimension  was  added  to  the  Lisbon
process, in the form of a strategy for Sustainable Development.1

This  strategy  identified  several  actions  in  the  environmental  field,  following  the
priority  themes  in  the  6th  Environmental  Action  Programme.2  In  the  area  of
managing natural resources more responsibly the European Council agreed, “that the
EU Integrated Product Policy aimed at reducing resource use and the environmental
impact of waste should be implemented in co-operation with business”.

The  Commission  has  developed  the  EU  Integrated  Product  Policy  (IPP)  in  co-
operation with stakeholders and with the aid of studies.3 IPP was first discussed with
stakeholders at a conference in 1998. The following year, IPP was considered at the
Weimar  Informal  Meeting  of  Environment  Ministers.  The  Presidency  conclusions
from the meeting welcomed the Commission’s intention to adopt a Green Paper and
emphasised  that  improving  the  market  conditions  for  greener  products  on  the
European  market  would  also  help  to  strengthen  the  competitiveness  of  European
industries. The Commission adopted the Green Paper in February 2001 and launched
a  stakeholder  consultation  exercise  on  its  contents  (see  Annex  I  for  more
information).

These  consultations  showed  that  IPP  clearly  has  a  role  to  play  in  contributing  to
sustainable  development.  This  Communication  will  re-iterate  why  a  product
dimension  to  environmental  policy  is  needed.  In  section  2  it  will  explain  the  IPP
approach  before  setting  out,  in  section  3,  the  guiding  principles  of  the  EU’s  IPP
strategy. The remaining sections outline what the Commission will do to further the
uptake of the IPP approach.

2. 

WHY IS A PRODUCT DIMENSION TO ENVIRONMENTAL POLICY NEEDED?

During the last few years, the Commission has begun to rethink policies relating to
the  environmental  impacts  of  products.  All  products  and  services4  have  an
environmental impact5, whether  during  their  production,  use  or  disposal.  The  exact
nature of this impact is complex and difficult to quantify but the potential magnitude
of  the  problem  is  clear.6    At  the  same  time  continued  economic  growth  and

1

2

3

4

5

6

Presidency  Conclusions  of  Gothenburg  European  Council  15th  and  16th  June  2001,  paragraphs  19-32,
http://ue.eu.int/pressData/en/ec/00200-r1.en1.pdf
Decision  1600/2002/EC  of  the  European  Parliament  and  of  the  Council  laying  down  the  Sixth
Community Environment Action Programme, OJ L 242, 10.9.2002, p. 1-15
For example, http://europa.eu.int/comm/environment/ipp/ippsum.pdf
The  rest  of  this  Communication  will,  for  simplicity,  only  refer  to  products,  although  it  should  be
understood that services are included within the general scope too – see Section 4.
Environmental impacts should be taken to include those on human health.
For  example,  one  product,  the  car,  is  responsible  for  roughly  80 %  of  the  European  Union’s  CO2
emissions  from  the  transport  sector,  the  sector  from  which  emissions  have  been  rising  fastest.  At  the
same  time  the  number  of  cars  per  inhabitant  is  also  increasing  –  by  14 %  between  1990  and  1999  –

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prosperity  is  significantly  influenced  by  the  production  and  use  of  products.  The
challenge  is  to  combine  improving  life  styles  and  well-being  –  which  are  often
directly influenced by products - with environmental protection. In other words, win-
win  situations  need  to  be  found  where  environmental  improvements  and  better
product  performance  go  hand  in  hand  and  where  environmental  improvements
support long-term industrial competitiveness. This is what IPP seeks to achieve.

Up  to  now,  product-related  environmental  policies  have  tended  to  focus  on  large
point sources of pollution, such as industrial emissions or waste management issues.
Often  these  have  been  successful.      Now,  however,  it  is  becoming  clear  that  they
need  to  be  complemented  by  a  policy  that  looks  at  the  whole  of  a  product’s  life-
cycle,  including  the  use  phase.  This  should  ensure  that  environmental  impacts
throughout  the  life-cycle  are  addressed  in  an  integrated  way  –  and  so  are  not  just
shifted  from  one  part  of  the  life-cycle  to  another.  It  should  also  mean  that
environmental  impacts  are  addressed  at  the  point  in  the  life-cycle  where  they  will
best and most cost-effectively reduce the overall environmental impacts and resource
use. To be successful, the policy also has to take into account several characteristics
of products that make them diffuse objects for pollution reduction measures.

First,  their  overall  quantity  is  increasing.  Greater  disposable  income7  means  that
more products can be afforded. For example, where before a household would have
one, fixed-line, telephone, now it often has several extensions throughout the house.
The  average  household  size  is  also  decreasing,  which  may  often  lead  to  greater
duplication of certain household products8. This means that there are larger numbers
of the same products and that these are becoming more diffuse. Any product policy
should therefore aim to reduce the environmental impacts of increased quantities of
products.

Secondly, the variety of products and services is increasing. Basic products now
come in many different versions. For example, there are different types of television
screens – (cathodic, LCD or plasma). Any product policy has therefore to be flexible
in order to address many different product variations simultaneously.

Thirdly, innovation constantly creates new  types of products. For example, over
the last 20 years there has been a shift from record players to compact disc players
and now the advent of DVD players may well supplant them. Innovation cycles for
components  can  often  be  even  shorter.  The  rapid  development  of  more  powerful
computer processors is testament to this. A product policy has to use this creativity
for the benefit of the environment as well as the economy.

Fourthly, products are traded globally. Both the Single Market and the multilateral
reduction  of  trade  and  investment  barriers  have  contributed  to  a  more  global

using  up  more  resources  in  their  manufacture,  more  space  for  parking  and  roads,  and  creating  more
waste  disposal  problems.  All  this  is  despite  significant  reductions  in  the  emissions  per  car  and
considerable  efforts  by  the  industry  concerned,  such  as  the  voluntary  agreement  to  reduce  CO2
emissions  by  25 %  by  2008.    Moreover,  for  other  pollutants  there  have  been  extremely  significant
reductions over recent decades.
Between 1980 and 1997  consumer  spending  has  increased  by  46 %  in  real  terms,  shifting  from  basic
needs,  such  as  food  and  housing,  towards  more  discretionary  items,  such  as  transport,  fuel  and
recreation. (EEA Fact Sheet 2001 – YIR01HH04)
Between 1980 and 1995 the average household size in the EU fell from 2.82 people to 2.49. This trend
is likely to continue. EEA Fact Sheet 2001 – YIR01HH03

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economy in which goods from many countries are traded internationally. The diverse
origin of the products available in our shops has become significantly more diverse.
A  product  policy  has  to  take  account  of  the  global  nature  of  trade  and  be  in
compliance  with  relevant 
international  agreements,  such  as  World  Trade
Organisation rules.

Fifthly, products are becoming more complex. This means that product expertise is
increasingly concentrated in the hands of those who are responsible for their design.
It  is  very  difficult  for  regulators,  let  alone  the  general  public,  to  have  any  realistic
idea  of  what  technical  changes  are  achievable.  For  this  reason  any  product  policy
needs to ensure that producers and designers become more responsible for ensuring
that their products fulfil agreed criteria on health, safety and the environment.

Sixthly,  the  product  can  be  designed  perfectly,  but  inappropriate  use  and
disposal will cause significant environmental  impacts. Although products can be
designed to cause as little environmental impact as possible, consumers may still use
them in an environmentally unfriendly way. For example, the use  of energy-saving
light  bulbs  brings  considerable  environmental  benefits,  but  these  can  only  be  fully
realised if they are switched off when not in use. Similarly, if products are disposed
of  inadequately,  perhaps  by  fly  tipping,  then  product  design  can  not  be  considered
responsible for the ensuing environmental damage.

Lastly,  products  now  involve  a  greater  variety  of  actors  throughout  their  life-
cycle.  Their  increasing  complexity  and  the  processes  of  globalisation  mean  that
many different actors are involved with a product throughout its life-cycle. Product
policy  needs  to  be  capable  of  addressing  many  different  actors.  It  also  has  to  take
account of the  fact that a product may be assembled, marketed or used many miles
apart under different sets of societal values. It is therefore difficult for an actor at one
stage in the product’s life-cycle to have a clear idea of what potential problems there
are  in  others.  The  conditions  under  which  our  products  are  produced  may  be
unknown. Therefore policy should contribute to improving information flows along
the supply-chain.

All  of  these  factors  underline  the  need  to  introduce  a  product  dimension  to
environmental policy. It should look at products in a holistic way, involve as many
actors  as  possible  and  leave  to  them  the  responsibility  for  the  choices  they  make.
This should provide a powerful supplement to existing product-related measures. The
IPP  approach  seeks  to  address  this  challenge,  while  supporting  the  EU’s  wider
economic  and  social  objectives,  as  set  out  in  the  Lisbon  Strategy,  and  complying
with international treaty obligations. The IPP approach is explained in the following
section.

3. 

THE IPP APPROACH

The IPP approach, which has been developed gradually over the last decade, is now
generally  recognised  as  being  a  potentially  very  effective  way  to  address  the
environmental dimension of products. This approach is based on five key principles:

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–  Life-Cycle  Thinking9  –  it  considers  a  product’s  life-cycle  and  aims  for  a
reduction  of  its  cumulative  environmental  impacts  -  from  the  “cradle  to  the
grave”. In so doing it also aims to prevent individual parts of the life-cycle from
being  addressed  in  a  way  that  just  results  in  the  environmental  burden  being
shifted  to  another  part.  By  looking  at  the  whole  of  a  product’s  life-cycle  in  an
integrated  way,  IPP  also  promotes  policy  coherence.  It  encourages  measures  to
reduce environmental impacts at the point in the life-cycle where they are likely to
be most effective in reducing environmental impact and saving costs for business
and society.

–  Working  with  the  market  –  setting  incentives  so  that  the  market  moves  in  a
more  sustainable  direction  by  encouraging  the  supply  and  demand  of  greener
products. This will reward those companies that are innovative, forward-thinking
and committed to sustainable development.

–  Stakeholder Involvement – it aims to encourage all those who come into contact
with the product (i.e. industry, consumers and government) to act on their sphere
of  influence  and  to  encourage  co-operation  between  the  different  stakeholders.
Industry can look at how to better integrate environmental aspects in the design of
products  while  consumers  can  assess  how  they  can  purchase  greener  products10
and  how  they  can  better  use  and  dispose  of  them.  Governments  can  set  the
economic and legal framework conditions for entire national economies and also
act directly on markets, for instance by purchasing greener products.

–  Continuous  Improvement  –  improvements  can  often  be  made  to  decrease  a
product’s  environmental  impacts  across  its  life-cycle,  whether  in  design,
manufacture,  use  or  disposal,  taking  into  account  the  parameters  set  by  the
market.  IPP  aims  for  a  continuous  improvement  in  these  rather  than  setting  a
precise threshold to be attained11. As a result, companies can set  their own  pace
and can focus on the most cost efficient improvements.

–  A  Variety  of  Policy  Instruments  –  the  IPP  approach  requires  a  number  of
different  instruments  because  there  are  such  a  variety  of  products  available  and
different  stakeholders 
instruments  range  from  voluntary
initiatives to regulations and from the local to the international scale. Within IPP,
the  tendency  is  clearly  to  work  with  voluntary  approaches,  although  mandatory
measures  might  also  be  required.  The  determining  factor  is  the  effectiveness  of
the tool to achieve the desired result with regard to sustainable development.

involved.  These 

4. 

THE EU IPP STRATEGY

As  stated  in  section  1,  the  EU  IPP  is  an  integral  part  of  the  EU’s  Sustainable
Development Strategy. Its primary aim is to reduce the environmental impacts from

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10

11

As  opposed  to  Life  Cycle  Assessment  (LCA)  which  is  different  and  involves  the  quantification  and
assessment  of  the  environmental  impacts  of  a  product  throughout  its  life-cycle,  albeit,  for  practical
reasons, in narrowly defined boundaries.
Here,  and  throughout  this  text,  greener  products  are  defined  as  those  that  have  lower  environmental
impacts throughout their life-cycle when compared to similar products fulfilling the same function.
This is not to say that legislative thresholds can not be useful in stimulating continuous improvement.
They are just less flexible, which, in some cases, may well be desirable.

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products  throughout  their  life-cycle,  harnessing,  where  possible,  a  market  driven
approach,  within  which  competitiveness  concerns  are  integrated.  Indeed,  the
competitiveness of business will be enhanced by the increased policy coherence that
IPP  will  facilitate,  both  within  the  life-cycle  and  between  different  policy
instruments.  Experience  with  some  environmental  management  tools  shows,  that
rising  environmental  awareness  in  companies  can  go  hand  in  hand  with  cost
reductions.    Furthermore,  in  an  increasingly  competitive  world,  environmental
performance  can  also  be  a  factor  giving  companies  or  their  products  a  competitive
edge.  Indeed, some companies use their environmental performance as a marketing
instrument.  IPP will help these companies, not least by  giving some of them more
visibility.

At  the  present  time  methodologies  for  assessing  the  environmental  impacts  of  a
product across its life-cycle exist. The experiences gained through initially applying
IPP to the environmental aspects of products will be an invaluable  knowledge base
from which to build towards broader sustainability impacts.

Clearly,  IPP  will  be  further  developed  taking  other  policies  closely  into  account.
There  is  already  a  substantial  and  significant  body  of  legislation,  such  as  that
regulating the characteristics of and trade in products, for example in the framework
of  the  internal  market,  or  competition  policy.  In  principle,  IPP  will  complement
current legislation by triggering, on a voluntary basis, further improvements in those
products whose characteristics do not necessarily require legislation.

When putting the present Communication into operation, full account will be  taken
of  the  Community’s  obligations  under  international  law,  in  particular  as  regards
trade,  as  well  as  the  principles  governing  other  EC  policies.  In  addition,  any  new
legal proposals from the Commission will also be subject to the Commission’s rules
on  Impact  Assessment12.  This  will  ensure  that  they  represent  a  balanced  approach
towards  the  three  pillars  of  sustainable  development.  The  development  of  IPP  will
also  build on experiences  with existing  environmental tools,  such  as  environmental
management systems and environmental labelling.

To achieve its objective, the policy will perform three key roles.

Firstly  it  will  contribute  to  addressing  the  environmental  challenges  identified  in
both  the  Sustainable  Development  Strategy  and  the  Sixth  Environment  Action
Programme.  Without  a  product  dimension  the  chances  of  meeting  them  will  be
smaller.  IPP  will  also  be  a  key  part  of  the  implementing  measures  for  the
forthcoming  Thematic  Strategy  on  the  Sustainable  Use  of  Resources  and  that  on
Prevention  and  Recycling  of  Waste.  It  is  also  closely  linked  to  the  forthcoming
Environmental  Technologies  Action  Programme.  Internationally,  IPP  will  also
constitute  a  major  input  to  the  ten-year  framework  of  programmes  on  sustainable
production  and  consumption  agreed  at 
the  World  Summit  on  Sustainable
Development in Johannesburg in September 2002.13

12

13

As set down in COM(2002) 276 final of 5.6.2002, the Communication from the Commission on Impact
Assessment
Paragraph  14  of  the  WSSD  –  Johannesburg  Plan  of  Implementation  and  paragraph  8  of  the  General
Affairs and External Relations Council’s conclusions of 30.10.2002

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Secondly, it will supplement existing product-related policies, by providing a wider,
“life-cycle”,  conceptual  framework  in  which  the  ramifications  for  any  other
environmental  problems  can  be  considered.  In  doing  so  it  will  take  account  of  the
fact that we are not starting with a blank slate, as some product-related policy areas
have already integrated life-cycle thinking to some degree, such as the Farm to Fork
concept in the field of agriculture and food safety.

Thirdly,  and most  importantly, it will  strengthen  the  co-ordination  and  coherence
between  existing  and  future  environment-related  product  policy  instruments.  This
will help to exploit the potential synergies between them fully and to encourage their
integrated  development.  In  addition,  through  integrating  the  life-cycle  approach,  it
will  make  product-related  environmental  policy  measures  more  effective  by
highlighting  the  necessary  trade-offs  and,  once  political  decisions  are  taken,  co-
ordinating  their  implementation.  This  strengthened  co-ordination  will  benefit  both
business competitiveness and the environment.

Achieving  this  objective  will  take  time.  The  Commission  will  focus  on  two,  inter-
related, actions to move towards it:

–  establishing 

the  framework  conditions  for 

the  continuous  environmental
improvement  of  all products  throughout  the  production,  use  and  disposal  phases
of their life-cycle;

–  developing  a  focus  on  products  with  the  greatest  potential  for  environmental

improvement.

This Communication outlines the steps that the Commission will take to implement
these  actions.  However,  the  active  co-operation  of  all  other  stakeholders,  through
looking to improve their environmental performance, is essential for IPP to succeed.
For  this  reason  the  policy  will  continue  to  be  developed  in  co-operation  with
stakeholders. An indicative list of what the Commission considers to be the roles and
responsibilities of Member States14 and other stakeholders can be found in Annex II.

To get IPP started, the Commission will begin by focusing on products15, rather than
services. This does not mean that services are excluded from the scope of IPP. It is
just a reflection of the fact that life-cycle thinking is more advanced for products than
for  services  and  that  there  is  a  more  developed  body  of  Community  legislation.  It
will therefore be easier for the Commission to bring the policy to life in this area.

5. 

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15

ESTABLISHING 
ENVIRONMENTAL IMPROVEMENT

THE 

FRAMEWORK 

CONDITIONS 

FOR 

CONTINUOUS

Many different policy tools already exist that are either already being used, not least
by industry, to green products or could be re-focused to do so. It is obvious that not
all  of  them  are  suitable  for  all  products..  These  tools  will  be  examined  in  the
following section.

Where Member States are referred to in this paper it should also be understood to apply to  Acceding
and Candidate Countries.
This Communication  does  not  seek  to  alter  any  of  the  existing  legal  definitions  of  what  constitutes  a
product, a producer, a type of product or such like.

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5.1. 

Tools for Creating the Right Economic and Legal Framework

Continual  environmental  improvement  requires  incentives  for  producers  to  make
new  product  generations  greener  than  their  predecessors  on  the  basis  of  life-cycle
thinking  and  taking  into  account  the  parameters  set  by  the  market.  It  also  requires
incentives  for  consumers  to buy  these. An  effective  IPP  requires  the  economic  and
legal framework to be conducive to greening products and to their purchase, ideally
with  minimum  government  intervention.  The  Commission’s  role  here  is  to  ensure
that the  instruments  for  which  it  is  competent  promote  movement  in  this  direction.
Policy tools that are suitable for this purpose are described in Box 1.

Box 1

a) Taxes and Subsidies

Getting  the  prices  right16,  through  internalising  environmental  externalities  into  the
price  of  a  product  so  that  its  environmental  impacts  are  accurately  reflected  in  the
price,  is  the  Commission’s  long-term  goal.  Price  signals  give  incentives  for  the
continuous  environmental  improvement  of  products  throughout  the  life-cycle.  They
facilitate  and  reinforce  measures,  such  as  greener  public  procurement  and  product
design  obligations,  by  improving  the  economic  rewards  for  green  design  and
production.  They  also  provide  consumers  with  important  information  and  encourage
them to buy products with lower environmental impacts. The Commission has already
made  several  proposals  on  energy-related  taxes  at  the  European  level17.  The  1997
proposal to restructure the Community framework for the taxation of energy products
has  now  obtained  unanimous  political  support  in  the  Council.  It  will  extend  the  EU
minimum tax rates to all energy products and thus provide the Member States with a
more coherent framework for using energy taxation as an instrument for pursuing their
environmental and other policy objectives. The Commission will continue to promote
and  encourage  the  use  of  fiscal  measures,  such  as  environmentally-related  taxes  and
incentives, at the appropriate local, national or Community level.18

However,  in  the  light  of  the  stakeholder  comments  received,  in  particular  from
Member  States,  the  Commission  will  not  develop  initiatives  to  apply  reduced  VAT
rates to products bearing the EU eco-label for the time being.19. For other types of tax,
Member  States,  where  appropriate,  should  promote  and  encourage  the  use  of  the
aforementioned fiscal measures to favour greener products.

Additionally,  in  the  framework  of  the  Sixth  Environmental  Action  Programme,  the
Commission  will  work  on  a  list  of  criteria  which  allow  environmentally  negative
subsidies to be recorded20. This will provide a reliable basis for their elimination. The
Commission has also  established  guidelines  on state aid for  environmental  purposes,

16

17

18

19

20

This means trying to ensure that the price paid by a consumer for a product includes the costs of all the
environmental impacts that it creates.
The Commission proposal of 2002 to amend Directives 92/81/EEC and 92/82/EEC to introduce special
tax arrangements for diesel fuel used for commercial purposes and to align the excise duties on petrol
and diesel fuel is still being negotiated in Council.
As  required  by  Article  3(4),  third  indent  of  Decision  1600/2002/EC  of  the  European  Parliament  and
Council  of  22nd  July  2002  laying  down  the  Sixth  Community  Environment  Action  Programme,  OJ  L
242,  10.9.2002,  p1-15.  Naturally  this  must  be  done  in  accordance  with  the  relevant  internal  market
legislation.
This analysis will also take account of the results of the experiment of applying reduced VAT rates to
labour intensive services.
Related work has started in the framework of the OECD International Energy Agency

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such  as  to  support  technological  change  in  favour  of  more  environmentally  friendly
products and services21.

b) Voluntary Agreements and Standardisation

To  green  products  effectively,  non-legislative  solutions,  such  as  environmental
agreements  and  the  standardisation  process,  need  to  be  considered  in  addition  to
legislation.  The  framework  for  environmental  agreements  at  the  Community  level  is
currently being considered following a Commission communication on the subject.22

On standardisation, the Commission will continue to use International Standardisation,
wherever  possible.  At  the  European  level  the  Commission  will  address  some  key
issues  concerning  European  standardisation  and  environmental  protection  in  a
Communication  in  2003.  The  Commission  has  also  awarded  a  service  contract  to
ECOS23, a consortium of European environmental non-governmental organisations, to
contribute 
the  European
integration  of  environmental  aspects 
standardisation process.

into 

the 

to 

c) Public Procurement Legislation

Public procurement constitutes around 16 % of Community Gross Domestic Product.
This is a vast section of the market that public authorities can use to drive the greening
of  products.  Detailed  Community  rules  exist  setting  down  the  procedures  to  be
followed  in  public  procurement  within  the  internal  market.  The  Commission’s
Interpretative Communication on Public Procurement and the Environment24 explains
the legal situation25 and shows that there are ample possibilities for taking into account
environmental  considerations  in  the  tendering  of  contracts  covered  by  these  rules,  a
situation  that  will  not  be  altered  by  the  ongoing  revision  of  the  public  procurement
directives.  The  real  tasks  for  greener  public  procurement  are  to  ensure  that  existing
possibilities are used by public purchasers.

d) Other Legislation

Community  legislation  for  any  product-related  measure  may  be  necessary  to  resolve
environmental problems particularly if market failures are not corrected or if the Single
Market  could  be  affected  without  Community  action.  This  is  the  case,  for  example,
with the Restriction of Hazardous Substances in Electrical and Electronic Equipment
directive26  and  will  be  for  the  follow  up  to  the  Commission’s  White  Paper  on
Chemicals.27  It  is  also  the  case  for  the  forthcoming  Commission  proposal  for  a
Directive establishing a framework for the eco-design of energy using products (EuP),
which  will,  in  addition,  enshrine  the  IPP  principles,  such  as  life-cycle  thinking,

21

22

23

24

25

26

27

Community Guidelines on State Aid for Environmental Protection, OJ C 37, 3.2.2001, pp. 3-15
Communication  from  the  Commission  to  the  European  Parliament,  The  Council,  The  Economic  and
Social  Committee  and  the  Committee  of  the  Regions  on  Environmental  Agreements  at  Community
Level  within  the  framework  of  the  Action  Plan  on  the  Simplification  and  Improvement  of  the
Regulatory Environment, COM(2002) 412 final, 17.7.2002
The European Environmental Citizens Organisation for Standardisation
Commission  of  the  European  Communities  (2001)  Commission  Interpretative  Communication  on  the
Community  law  applicable  to  public  procurement  and  the  possibilities  for  integrating  environmental
considerations  into  public  procurement,  COM(2001)  274  final,  4.7.2001.  This  can  be  found  at
http://simap.eu.int/EN/pub/src/welcome.htm
See website in footnote 24.
Directive  2002/95/EC  of  the  European  Parliament  and  of  the  Council  on  the  restriction  of  the  use  of
certain hazardous substances in electrical and electronic equipment, OJ L 37, 13.2.2003, p. 19-23
White Paper on the Strategy for a future Chemicals Policy, COM(2001) 88 final

9

                                                                                                                                                        
stakeholder  involvement  and  continuous  improvement  in  a  legislative  framework.
Legislation  is  also  necessary  where  extended  producer  responsibility  measures  or
deposit schemes are considered to  be the  most  effective  way  to  reduce  the  life-cycle
environmental impacts. Such initiatives also have a particular value at the Community
level  where  individual  Member  States  have  developed,  or  are  in  the  process  of
developing,  their  own  initiatives  in  this  area.  The  Commission  will  develop  these
points further in its Thematic Strategy on the Recycling and Prevention of Waste.

5.2. 

Promoting the Application of Life-Cycle Thinking

For  IPP  to  be  effective  life-cycle  thinking  needs  to  become  second-nature  for  all
those  who  come  into  contact  with  products.  Educational  and  awareness-raising
measures  are  best  undertaken  closest  to  the  citizen,  i.e.  on  a  national  and  regional
level. On a Community level three distinct sets of actions are required (Box 2).

a) Making Life-Cycle Information and Interpretative Tools Available

Box 2

Life-cycle data on which to base assessments – whether for design or labelling purposes
-  need  to  be  collected  systematically.  Several  Member  States  and  industries  have
developed  databases  to  help  with  this.  The  Commission  will  provide  a  platform  to
facilitate communication and exchanges. This will  include regular  meetings  supported
by the Commission and a directory of LCA databases to be updated at regular intervals.

Life-cycle data also needs to be made more accessible. To this end the Commission will
launch  a  co-ordination  initiative  involving  both  ongoing  data  collection  efforts  in  the
EU and existing harmonisation initiatives. This initiative will act as a European link to
the  ongoing  United  Nations  Environmental  Programme  Life-Cycle  Initiative.  The
Commission  will  begin  by  initiating  a  study  to  examine  the  existing  situation,  and
possible future directions.

LCAs provide the best framework for assessing the potential environmental impacts of
products  currently  available.  They  are  therefore  an  important  support  tool  for  IPP.
However,  the  debate  is  ongoing  about  good  practice  in  LCA  use  and  interpretation.
Through a series of studies and workshops, the Commission will further this discussion,
with the aim of producing a handbook within two years on best practice, based on the
best possible consensus attainable among stakeholders.

The  Commission is  also continuing  its  research  and  development  support  towards  the
implementation  of  this  part  of  the  IPP  approach.  The  Fifth28  and  Sixth29  Community
Research  Framework  Programmes  will  contribute  to  this  by  enhancing  knowledge  of
environmental  processes,  providing  base  data  and  measuring  systems  and  developing

28

29

Decision  No  182/1999/EC  of  the  European  Parliament  and  of  the  Council  of  22  December  1998
concerning  the  fifth  framework  programme  of  the  European  Community  for  research,  technological
development and demonstration activities (1998 to 2002), OJ L 26, 1.2.1999, p. 1-31
Decision 1513/2002/EC of the European Parliament and of the Council of 27 June 2002 concerning the
Sixth Framework Programme of the  European  Community  for  Research,  Technological  Development
and  Demonstration  Activities  contributing  to  the  creation  of  the  European  Research  Area  and  to
innovation (2002-2006), OJ L 232, p. 1-33

10

                                                
feasible solutions for greener products. IPP projects are already a significant part of the
scope of the Commission’s LIFE programme30.

b) Environmental Management Systems

Environmental management systems (EMS) provide a good framework for integrating
life-cycle  thinking  within  an  organisation’s  operations  and  for  achieving  continuous
improvement. The revision of EMAS in 2001 began the re-orientation from the process
dimensions towards products. Products are now clearly within the scope of the EMAS
Regulation  in  the  same  way  as  activities  and  services,  i.e.  their  significant
environmental  impacts  have  to  be  included in  the  environmental  review,  management
and  audit  system;  their  impacts  have  also  to  be  verified  by  an  EMAS  verifier,
information  about  them  has  to  be  included  in  the  environmental  statement  and  their
environmental performance has to be continuously improved. Since EMAS focussed in
the past more on industrial activities, the Commission will develop guidelines on how to
deal  with  product  issues  within  EMAS  by  the  end  of  2004.  EMS  are  relevant  for  all
types of organisations - public or private - and can be used to provide a framework for
all  types  of  tools,  from  the  greening  of  the  organisations  procurement  to  validating
green  information.  An  EMS  certification  by  itself  does  not  guarantee  a  specific
environmental product performance but in the case of EMAS it provides a framework
for validating information about such performance by the EMAS verifier.

The  Commission  will  also  monitor  and  evaluate  the  implementation  of  the  product
dimension in EMAS so that it can feed into the next revision of the Regulation, which is
due  by  2006.  The  Commission  will  decide  in  2004  whether  to    attain  EMAS  II
registration;  a  pilot  exercise  has  already  begun  with  three  directorates-general
participating.

c) Product Design Obligations

The  two  elements  outlined  above  should  stimulate  front-runners  to  develop  greener
products. In addition, the Commission will come forward with a discussion document in
2005  that  will  consider  ways  to  promote  implementation  of  the  IPP  approach  in
companies, including if appropriate general obligations for specific products. This will
build on discussions on the application of the New Approach in the environmental field
following the publication of the IPP Green Paper31. The reactions to the published drafts
of  a  Directive  on  the  eco-design  of  end-use  equipment  and  of  a  Directive  on  the
environmental  design  of  electrical  and  electronic  equipment  (EEE)  will  also  be  taken
into account. The experiences from the negotiations on the forthcoming proposal for a
directive  establishing  a  framework  for  the  setting  of  Eco-design  requirements  for
Energy  Using  Products  (EuP)  will also  be  considered.  Issues  to  be  addressed  will  be,
inter alia, the appropriate legal base; internal market considerations; international treaty
obligations; the scope of such actions; suitable products or product groups; the required
level of detail of the design requirements; the role of minimum product standards; the
appropriate  means  of  enforcement  and  reporting;  the  costs  and  benefits  of  such  an
approach; its likely environmental effects; and how it should be integrated with policies
and measures affecting the environmental dimensions of products, including IPP tools.

In the case of energy-using products sufficient experience was already available, and the

30

31

Regulation  (EC)  No.  1655/2000  of  the  European  Parliament  and  of  the  Council  concerning  the
Financial Instrument for the Environment (LIFE), OJ L 192, 27.7.2000, p. 1-9
See  www.europa.eu.int/comm/environment/ipp/standard.pdf  and  Godenman,  G.,  Hart,  J.  W.,  Sanz
Levia, L. (2002) The New Approach in Setting Product Standards for Safety, Environmental Protection
and  Human  Health:  Directions  for  the  Future,  Environmental  News  No.  66,  Danish  Environmental
Protection Agency.

11

                                                                                                                                                        
growing  environmental  impact  clear,  for  the  Commission  to  consider  and  EuP-style
framework  for  these  products.  This  framework,  which  will  allow  product-specific
legislative  measures  to  be  taken,  where  justified,  will  also  allow  room  for  self-
regulation by the industry where this would reduce environmental impacts faster and/or
with greater cost-effectiveness than legislation.

In  addition,  the  Commission  will  consider  how  best  to  ensure  that  information  on  a
product’s environmental performance and design is communicated to the public. Such
information  could  significantly  strengthen  companies’  public  documents,  such  as
environmental statements

5.3. 

Giving Consumers the Information to Decide

Consumers,  whether  private,  public  or  individual,  decide  whether  or  not  they
purchase  greener  products  and  once  bought,  how  they  are  used.  The  Community’s
role  here  is  to  provide  and  encourage  EU-wide  tools  and  frameworks  to    provide
consumers with product information. It is for the Member States to decide on what is
required to achieve the level of consumer awareness necessary for them to play their
full part in greening products. A number of suitable policy instruments are discussed
in Box 3. However, other factors relevant when purchasing products, like safety and
health aspects, cost and effectiveness have clearly to play their role as well.

Box 3

a) Greening Public Procurement

Positive  action  is  needed  to  encourage  public  authorities  to  use  the  possibilities  in
existing  public  procurement  legislation.  For  this  reason  the  Commission  will  initiate
several actions.

It will seek to determine the extent of greener public procurement because, at the
present  time,  only  limited  information  is  available  on  the  extent  to  which  greener
public  procurement  is  practised  in  the  Member  States.  By  the  end  of  2003  the
Commission will have undertaken a survey to assess the extent to which greener public
procurement is practised by public authorities. It is also co-financing a research project
to assess the potential impact on the environment and on the markets of greener public
procurement.

It therefore encourages Member States to draw up publicly available action plans for
greening  their  public  procurement.  These  should  contain  an  assessment  of  the
existing situation and ambitious targets for the situation in three years time. The action
plans  should  also  state  clearly  what  measures  will  be  taken  to  achieve  this.  They
should be drawn up for the first time by the end of 2006 and then revised every three
years. The action plans will not be legally-binding but will provide political impetus to
the  process  of  implementing  and  raising  awareness  of  greener  public  procurement.
They  will  allow  Member  States  to  choose  the  options  that  best  suit  their  political
framework  and  the  level  they  have  reached,  while  at  the  same  time  enabling  an
exchange of best practice in facilitating greener public procurement. The Commission
too, will draw up an action programme by the end of 2006 which brings together its
objectives  and  actions  for  its  own  procurement.  It  invites  the  other  Community
institutions and offices to do likewise and is prepared to share its expertise in this area
with them to facilitate this.

In  addition,  it  is  also  elaborating  information  measures  for  public  authorities  to

12

assist them in greening their purchasing policies. These are:

–  a practical handbook for public authorities which will explain the possibilities for
greener procurement in clear, simple and non-legal language. The first draft is planned
for mid- 2003. It will be revised, if necessary, in the light of further developments and
practical experience with its use;

–  a  product  group  database  This  will  gather  together  in  one  web-site  information  on
the  existing  product  criteria,  such  as  those  used  by  eco-labelling  and  environmental
product declaration schemes, in order to provide corporate and public purchasers with
background information on what criteria are relevant for a particular product. The first
prototype is expected in 2003;

–  a “greening public procurement” web site which will gather together the handbook,
the product database and the relevant legislation. This will be in place by the  end of
2004.

b) Greener Corporate Purchasing

The  private  sector  can  demand  greener  products  and  greener  production  processes
from  their  suppliers.  They  have  considerable  potential  to  influence  the  market  for
greener  products,  should  they  choose  to  do  so,  through,  for  example,  demanding  a
certified environmental management system, such as EMAS.

The  tools  being  developed  for  greening  public  procurement  and  listed  above  should
also facilitate greener corporate purchasing. In addition, the different types of labelling
mentioned  below  will  also  be  of  use.  The  Commission  has  also  begun  working  to
stimulate the large  corporate  purchasing  market  by  pushing  for  corporate  purchasing
practices to be more transparent through reporting32.

c) Environmental Labelling

In  the  labelling  field  the  Commission  is  already  running  several  important  labelling
schemes  that  provide  consumers  with  reliable  and  easily  understandable  information
on which to make their product choice. These fit well within an IPP framework.

The presence of the EU Eco-label33 on a product tells the consumer that that product is
certified to be more environmentally-friendly than most other like products across the
whole of its life-cycle. As there are currently no other comparable labels covering the
whole EU  market,  it  is  the  best  available label from  the  perspective  of  an  EU  IPP34.

32

33

34

The Commission has invited all publicly-quoted companies with at least 500 staff to publish a  “triple
bottom line” in their annual reports to shareholders that measures their performance against economic,
environmental  and  social  criteria  (Communication  from  the  Commission:  A  sustainable  Europe  for  a
better world: A European strategy for sustainable development, COM (2001) 264, 15.5.2001). To assist
this process the Commission has produced a Recommendation on how environmental issues should be
disclosed  (Commission  Recommendation  of  30  May  2001  on  the  recognition,  measurement  and
disclosure  of  environmental  issues  in  the  annual  accounts  and  annual  reports  of  companies
(2001/453/EC), OJ L 156, 13.6.2001, p33.). It has also called for the development of commonly agreed
guidelines and criteria for  measurement, reporting and assurance by  mid-2004. (Communication  from
the  Commission  concerning  Corporate  Social  Responsibility:  A  Business  Contribution  to  Sustainable
Development, COM (2002) 347, 2.7.2002, page 15).
This, as with national EU labels, is also known as an ISO Type I label.
This does not preclude, however, that other labels may, in the future, through equivalence arrangements
or new developments, play a significant role in providing such consumer information.

13

                                                
The  EU  energy  label35  is  now  attached  to  many  products,  particularly  in  the  white
goods sector, where energy use usually represents the most significant environmental
impact  across  the  product’s  life-cycle.  It  has  a  particularly  high  recognition,  largely
due to its mandatory presence on products. The European car-labelling scheme36 is
also providing the consumer with important information on the CO2 emissions of new
vehicles.

The scope of all of these labels will be gradually expanded to provide consumers with
more  choice.  At  the  same  time  the  Commission  will  pursue  enforcement  of  the
Misleading  Advertising  directive37  by  Member  States  and  bring  to  a  conclusion  its
work  on  green  claims38  guidelines.  This  should  go  some  way  to  ensuring  that
misleading green claims do not reduce the overall level of confidence in environmental
product information. The Commission will investigate the possibilities for such claims
to be independently verified through the EMAS scheme. In addition, in the framework
of  the  current  Consumer  Policy  Strategy39,  the  effectiveness  of  private  labelling
measures and the need for further measures will be assessed.

The comparatively new tool of environmental product declarations (EPDs)40 may need
to  be  developed  within  a  European  framework.  EPDs  are  a  means  of  presenting
quantified, life-cycle based information – such as on CO2 or NOx emissions - about a
product in a standardised way. No judgement is made about how “environmental” the
product  itself  is,  instead  the  quantified  information  can  be  used  by  a  potential
purchaser  to  make  their  own  judgement,  or  to  feed  into  a  LCA.  The  Commission
financed a study41 to examine the existing EPD type schemes (and those which have
similar  characteristics)  and  to  look  at  the  possible  options  for  development.42
Stakeholders were invited to comment on these results43 and, by the end of 2005, the
Commission  will  take  a  decision  on  whether  any  action  needs  to  be  taken  at
Community  level  to  stimulate  the  development  of  this  potentially  important
instrument.  This  will  take  into  account  the  ongoing  development  of  an  International
Standard for EPD schemes.

35

36

37

38

39

40

41

42

43

Council Directive 92/75/EEC of 22 September 1992 on the indication by labelling and standard product
information  of  the  consumption  of  energy  and  other  resources  by  household  appliances,  OJ  L  297,
13.10.1992, p16
Directive 1999/94/EC of the European Parliament and of the Council of 13 December 1999 relating to
the  availability  of  consumer  information  on  fuel  economy  and  CO2  emissions  in  respect  of  the
marketing of new passenger cars, OJ L 12, 18.1.2000, pp 16-19
Council  Directive  84/450/EEC  of  10  September  1984  relating  to  the  approximation  of  the  laws,
regulations and administrative provisions of the Member States concerning misleading advertising, OJ
L  250,  19.09.1984  p.  17-20.  The  Commission  will  adopt,  during  2003,  a  proposal  for  a  framework
directive  on  unfair  commercial  practices.  If  agreed  by  the  Council  and  Parliament  this  will  partially
replace some of the provisions of this existing Directive.
Green  claims  are  also  sometimes  referred  to  as  ISO  Type  II.  They  are  statements  about  the
environmental  characteristics  of  a  product  that  are  generally  not  subject  to  any  form  of  third-party
verification.
Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  Economic  and
Social  Committee  and  the  Committee  of  the  Regions  on  Consumer  Policy  Strategy  2002-2006,
COM(2002)208 final of 7.5.2002
These are also often referred to as ISO Type III.
The final report from this study is available on http://europa.eu.int/comm/environment/ipp/epds.htm
A parallel study, focusing on LCA/EPD tools in the construction sector has also been financed by the
Commission. This can be found on
http://europa.eu.int/comm/enterprise/construction/internal/essreq/lcarep/lcafinrep.htm
These can also be found on the website in footnote44.

14

                                                                                                                                                        
6. 

DEVELOPING A FOCUS ON PARTICULAR PRODUCTS

6.1. 

Voluntary Pilot Projects

Life-cycle  thinking  has  already  been  widespread  practice  for  many  businesses  for
some time now.  Nevertheless, for others more remains to be done to make life-cycle
thinking  operational.  Given  the  importance  of  life-cycle  thinking  for  a  successful
product  policy,  this  challenge  has  to  be  addressed  as  a  matter  of  priority.  The  best
way  to  demonstrate  the  advantage  of  this  concept  is  by  demonstrating  its  practical
application.  The  Commission  therefore  considers  that  the  concept  can  best  be
brought to life by applying it to a number of products individually in a pilot project
exercise.  For this purpose the Commission will carry out a number of pilot projects
to demonstrate the potential benefits of IPP in a practical way. Stakeholders will then
be  able  to  apply  this  thinking  to  their  everyday  activities  and  to  the  products  with
which they come into contact.

Stakeholders’  participation  in  such  pilot  projects  is  crucial  to  their  success  and  all
parties  concerned  with  a  particular  product  –  all  along  the  life-cycle  –  will  be
welcome  to  participate  on  a  voluntary  basis.  Stakeholders  who  volunteer  to  be
pioneers will benefit from enhanced visibility that they will be given across Europe.
The Commission invites  all  stakeholders  to  submit their  suggestions  for  these  pilot
products. These should arrive by the end of October 2003. The Commission will
then  analyse  these  suggestions  on  the  basis  of  practical  factors  such  as  their
feasibility  and  the  willingness  of  all  stakeholders  to  participate.  Given  the
demonstration character of  these projects, issues such  as  whether  the  product  has  a
high environmental impact, or whether it has the greatest potential for improvement
will not be the determining factor. As a result the choice of the product or products
for a pilot exercise will in no way be a judgement of either of these attributes.

The Commission envisages that each project will last around 12 months. It will start
on  the  basis  of  a  common  understanding  of  the  work  to  be  undertaken  with  all
stakeholders.  The  Commission  envisages  that  each  pilot  product  could  follow  the
same basic path to a solution, namely:

(1) 

(2) 

(3) 

(4) 

document  and  analyse  all  the  environmental  impacts  of  the  product
throughout its life cycle;

analyse  the  potential  environmental,  social  and  economic  effects  of  all
possible  options  to  reduce  the  environmental  impacts,  including  examining
the effectiveness of existing policy tools;

identify, with stakeholders, the most feasible options for improvement;

agree  on  implementation  plans,  identifying  the  responsibilities  of  different
stakeholder groups;

(5) 

implementation.

An indicative worked example is given in the box below.

15

(1) 

(2) 

(3) 

Example of the Car Tyre

Existing life-cycle inventory and LCA data, ideally provided by industry, will
first be collected  and  analysed to obtain  a  picture  of  the  whole  life-cycle  of
the tyre. Any assessment will follow the relevant rules, standards and norms.

For tyres it is clear that there are impacts in all phases of the life-cycle. For
the  purposes  of  this  example  though,  it  will  be  assumed  that  these  are
concentrated in the use phase. Here, the tyre’s rolling resistance contributes to
CO2 emissions through fuel consumption and to the pollution of soil, waters
and air through abraded rubber particles and chemicals attached to them. As,
on  an  EU  level,  the  emissions  of  CO2  are  likely  to  be  most  significant  the
remainder of this example will concentrate on this.

It is then possible to attempt to identify the measures needed to reduce CO2.
Here  one  has  to  consider  all  the  tools  potentially  available,  including  any
instruments  or  measures  that  are  already  applied  under  the  existing
Community  policies.  Reducing  the  rolling  resistance  through  innovations  in
tyre  design  could  be  one  option.  For  example  new  materials  could  help,  as
was  shown  in  the  case  of  silica  compounds.  Re-treading  might  be  another
issue  to  be  addressed.  These  are  of  course  only  examples  and  additional
possibilities  might  be  found.  Before  deciding  on  any  particular  action  one
would  assess  its  potential  impact  along  the  whole  life  cycle,  so  that  any
adverse  effects  would  not  outweigh  the  sought  improvement.  Clearly,  in  an
integrated  approach,  any  options  would  have  to  be  assessed  for  their
consistency with measures under other Community policies. They would also
have  to  take  account  of  cost  and  functionality  and,  in  the  present  example,
transport policy and road safety.

(4) 

The  next  stage will  be to agree on  who  undertakes  the  different  measures  –
and how to implement them. For example, if tyre design were to be tackled,
industry  would  need  to  take  the  lead  in  designing  new  tyres.  Public
authorities  might,  for  example,  have  to  address  issues  like  harmonised
certification.

(5) 

The  final  stage  will  be  the  implementation  of  the  measures  and  monitoring
and reporting on progress.

While it is clear that some of the lessons learned from the pilot products exercise are
likely to be product-specific, the Commission believes that, as this is practically the
first time  such an exercise  has been  attempted  at  the  European  level,  much  will  be
learned  about  the  dynamics  and  organisation  of  such  an  exercise.    Should  this
exercise,  on  the  basis  of  pilot  projects  and  sufficient  additional  evidence,  reveal
important  policy  inconsistencies  that  hamper  a  balanced  integration  of  economic,
social and environmental objectives, the Commission will examine what actions may
be necessary to enhance the coherence of existing legal and other instruments.

16

6.2. 

Identifying  which  products  have  the  greatest  potential  for  environmental
improvement

At the same time as raising the general awareness of IPP through pilot projects, the
Commission will also seek to identify and stimulate action on those products with the
greatest  potential  for  environmental  improvement.  In  assessing  this  improvement
potential  the  likely  socio-economic  effects  of  any  such  change  will  be  taken  into
account. However, as yet, there is no analytically-based consensus on which products
have  the  greatest  environmental  impact,  nor  therefore  on  those  which  have  the
greatest potential for environmental improvement.

The  Commission  will  therefore  initiate  the  development  of  a  methodology  for
identifying  these  products  at  the  European  level.  This  will  build  on  existing
experiences,  such  as  those  in  Belgium.44  This  methodology  will  then  be  discussed
with  stakeholders  with  the  aim  of  achieving  a  broad  level  of  consensus.  Following
this a further study will be conducted that will apply this methodology and identify
the  products  with  the  greatest  environmental  impact.  Once  this  has  been  done,  for
those  that  are  towards  the  top  of  the  list,  further  analysis  will  be  undertaken  to
identify  all  possible  ways  in  which  the  environmental  impacts  can  be  reduced.  For
each  of  these  possible  ways  the  potential  socio-economic  impacts  of  each  measure
will be assessed. This whole exercise is likely to take three to four years.

Once this exercise has been completed, the Commission will seek to address some of
the  products  with  the  greatest  potential  for  environmental  improvement  at  least
socio-economic  cost individually. The experiences  in  the  pilot  project  exercise  will
be a valuable input to this process.

7. 

CO-ORDINATION AND INTEGRATION

The  IPP  approach  requires  that  the  synergies  between  the  different  tools  are
exploited.  To  do  this  there  is  a  need  to  ensure  that  “IPP  thinking”  permeates  all
aspects of the management of these tools. At the same time there is a need for  IPP
thinking to be integrated further into other policy areas than environment. To this end
the  Commission  will  encourage  individual  sectors,  in  their  reports  pursuant  to  the
Cardiff  Process45,  to  be  more  explicit  in  how  they  intend  to  integrate  the  IPP
approach into their work.

In  addition,  the  Commission  will  initiate  a  number  of  processes  to  facilitate  co-
ordination and monitor progress.

It  will  develop  suitable  indicators,  in  co-operation  with  Member  States  and  the
European  Environment  Agency,  to  measure  the  environmental  improvements
induced by the IPP approach.

44 

45

Institut Wallon de Développement Économique et Social et d’Aménagement du Territoire et Vlaamse
Instelling voor Technologisch Onderzoek (2002) Identifying Key Products for the Federal Product and
Environment Policy, Draft Final Report, November 2002
At  the  1998  European  Council  meeting  in  Cardiff  several  other  sectors  were  asked  to  develop
integration strategies, including indicators (transport, energy, agriculture), with a view to help solve the
climate change problem and advance environmental concerns in the Agenda 2000 process. This process
has subsequently been extended to other sectors.

17

                                                
It will also prepare a report on progress being made in implementing IPP and submit
it  to  the  European  Parliament  and  Council.  This  will  be  based  on  reports  which
Member States should submit to the Commission every three years, beginning at the
end  of  2006,  detailing  the  measures  taken  and  progress  made  in  implementing  the
IPP  approach.  Industry  sectors  and  consumer  organisations  are  also  asked  to  do
likewise.

In  addition,  it  will  also  chair  regular  meetings  where  both  Member  States’  and
Stakeholders’  representatives  attend.  These  will  assist  the  Commission  in  its
development  and  implementation  of  IPP,  as  well  as  monitoring  progress  in  the
Member  States.  Where  particular  areas  merit  closer  attention,  such  as  on  reporting
formats, the Commission may initiate working  groups  or  utilise  existing  structures.
The  Commission  would  suggest  that  the  IPP  Informal  Network,  established  by
Member  States  on  their  initiative46,  continues  with  its  parallel  task  of  information-
sharing  under  the  Chair  of  the  Council  Presidency.  It  also  suggests  that  its
membership be extended to Acceding and Candidate Countries.

It will seek to promote the IPP approach on the international level by explaining
its  potential  benefits  of  the  IPP  approach  for  the  environment  and  sustainable
development. A common understanding of the IPP approach, taking into account the
particular  needs  of  developing  countries,  will  further  the  development  of  IPP  and
assist in responding to global environmental challenges.

including
The  Commission  will 
consultation exercises, via its website – www.europa.eu.int/comm/environment/ipp –
and its mailing list service.

inform  stakeholders  of  all  developments, 

46

And which the Commission attends as an observer.

18

                                                
Annex I: Stakeholder Consultations following the adoption of the IPP Green
Paper

The Green Paper contained several questions on how IPP should be developed, both
in terms of the overall approach and different instruments. Stakeholders were invited
to  submit  written  comments  to  the  Commission  by  the  end  of  June  2001.  133
stakeholder  groups  did  so.  Many  of  these  comments  can  be  accessed  via  the
Commission’s IPP webpages. 47

Of the 133 contributions, 78 were from industry, 30 from governmental organisations
(including  other  European  Institutions),  10  from  individuals,  6  from  consumer
organisations,  4  from  academia,  3  from  environmental  NGOs  and  2  from
standardisation bodies.

Most stakeholders welcomed the Green Paper and endorsed the new policy logic set
out  in  IPP.  The  opinions  on  the  merits  of  the  various  instruments  were,  however,
more  divergent.  While  many  stakeholders  were  in  favour  of  a  market-oriented
approach, their enthusiasm often did not extend to using differentiated taxation. The
idea  of  applying  a  reduced  VAT  rate  to  products  bearing  the  EU  Eco-label  was
opposed  by  most  industrial  and  governmental  stakeholders,  while  environmental
NGOs  were  more  welcoming.  The  balance  between  voluntary  and  mandatory
instruments was also the subject of divergent opinions. Industry generally favoured a
more  voluntary  approach,  while  other  stakeholders  underlined  the  importance  of
legislation as a necessary tool.

On  the  subject  of  life-cycle  assessment,  several  stakeholders  pointed  to  the
limitations of the methodology, while others expressed support for the development
of life-cycle information databases and awareness-raising measures to support good
practice. As far as using the New Approach is concerned, all stakeholders expressed
considerable  concerns  about  its  use  for  environmental  goals.  For  greening  public
for  awareness-raising  measures.
support 
procurement 
Environmental  labelling  was  held  to  be  important,  however  different  stakeholders
supported  different  types.  It  was  generally  agreed  that  environmental  management
systems  (EMAS,  ISO  14001  or  even  POEMS  (Product-Oriented  Environmental
Management  Systems))  could  be  a  useful  tool.  The  product  panels  idea  was  found
interesting, although several stakeholders had doubts about their likely success at the
European level.

there  was  general 

In addition, to the written comments from stakeholders, the European Parliament and
the Council of Ministers also produced opinions on the Green Paper. The Council of
Ministers was generally supportive of the approach but the European Parliament was
guarded  in  its  welcome,  calling  for  clarification  of  how  IPP  would  be  applied  in
practice.  The  decision  to  organise  a  pilot  project  exercise  was  taken  partly  in
response to this call.

In  addition  to  the  written  comments  and  opinions  the  Commission’s  services  also
organised several expert meetings and a stakeholder conference to discuss the paper.
It also held numerous bilateral meetings with interested stakeholders.

47

http://europa.eu.int/comm/environment/ipp/tablelisting.htm

19

                                                
This Communication builds on these consultations and attempts to strike the balance
between the different opinions expressed during them.

20

Annex II: Possible Roles and Responsibilities of Stakeholders48

1. 

MEMBER STATES

Establish framework for national voluntary agreements

Promote  integration  of  environmental  considerations  into  national  standardisation
bodies

Removal of impediments to greening public procurement in national laws

Promote  and  encourage,  where  appropriate,  the  use  of  fiscal  measures,  such  as
environmentally-related taxes and incentives, in order to promote greener products

Elimination of environmentally negative subsidies

Provide  public  funding  to  support  technological  change  in  favour  of  more
environmentally friendly products and services

Education, training and awareness-raising measures on life-cycle thinking

Contribute to Community efforts on life-cycle databases

Promoting the uptake of eco-design and LCA

Directing national research programmes towards IPP related research

Promoting uptake of EMS, including in national administrations

Drawing up publicly available plans for greening public procurement

Encouraging  uptake  of  information  measures  for  public  authorities  for  public
procurement

Promoting the development and use of the European Eco-label

Ensuring implementation of the Misleading Advertising Directive

Ensuring the integration of IPP thinking into non-environment policy areas

Assisting with the development of indicators

Reporting on the implementation of IPP

Information sharing on IPP implementation with Member States

Promotion of IPP on the international level

48

The Commission is not included in this list, because the main body of the text sets out what it considers
it should do.

21

                                                
2. 

EXTRACTORS, 
INDUSTRY 
DISTRIBUTORS, RETAILERS AND RECYCLERS)49

(INCLUDING 

DESIGNERS, 

MANUFACTURERS,

Proposing environmental agreements

Promote  integration  of  environmental  considerations  into  national  standardisation
bodies

Employee education, training and awareness-raising measures on life-cycle thinking
and environmental information tools

Contribute to Community efforts on life-cycle databases

Promoting the uptake of eco-design and LCA

Integrating IPP thinking into company RTD programmes

Using EMS, including the product dimension

Practising corporate green purchasing

Applying for and supporting the development of the European Eco-label

Following guidelines on green claims

Customer and supplier education and training /information on life-cycle thinking

Participating in pilot products projects

Reporting  on  the  implementation  of  IPP,  including  in  company  environmental
reports

Information sharing on IPP implementation with other companies and stakeholders

3. 

CONSUMER ORGANISATIONS

Promote  integration  of  environmental  considerations  into  national  standardisation
bodies

Education and awareness-raising measures on life-cycle thinking and environmental
information sources

Promoting the development and use of the European Eco-label

Purchasing greener products

Reporting on the implementation of IPP

Information sharing on IPP implementation with Member States

49

This applies to industry outside the EU too, where appropriate

22

                                                
4. 

ENVIRONMENTAL ORGANISATIONS

Promote  integration  of  environmental  considerations  into  national  standardisation
bodies

Education and awareness-raising measures on life-cycle thinking

Promoting uptake of EMS, including in national administrations

Commenting on publicly available plans for greening public procurement

Encouraging  uptake  of  information  measures  for  public  authorities  for  public
procurement

Promoting corporate green purchasing

Promoting the development and use of the European Eco-label

Ensuring the integration of IPP thinking into non-environment policy areas

Assisting with the development of indicators

Reporting on the implementation of IPP

5. 

CONSUMERS

Purchasing greener products

Using and maintaining products so as to minimise environmental impacts

Disposing of products correctly

23

LEGISLATIVE FINANCIAL STATEMENT

Policy area(s): Environment

Activit(y/ies): Policy Development

TITLE OF ACTION: COMMUNICATION “INTEGRATED PRODUCT POLICY”

1.

BUDGET LINE(S) + HEADING(S)

2.

2.1.

2.2.

2.3.

(a)

B4-3040 A

OVERALL FIGURES

Total allocation for action (Part B): € 1.605 million for commitment

Period of application: 2003 - 2007

Overall multiannual estimate of expenditure:

Schedule  of  commitment  appropriations/payment  appropriations 
intervention) (see point 6.1.1)

(financial

€ million (to three decimal places)

Year
2003

2004

2005

2006

2007

2008
and
subs.
Years

Total

Commitments

Payments

(b)

Technical and administrative assistance and support expenditure(see point 6.1.2)

Commitments

0.526

0.442

0.266

0.208

0.163

0.000

1.605

Payments

0.200

0.400

0.350

0.350

0.200

0.105

1.605

Subtotal a+b

Commitments

0.526

0.442

0.266

0.208

0.163

0.000

1.605

Payments

0.200

0.400

0.350

0.350

0.200

0.105

1.605

(c)

Overall  financial  impact  of  human  resources  and  other  administrative  expenditure
(see points 7.2 and 7.3)

Commitments/
payments

0.661

0.661

0.661

0.661

0.661

3.305

24

TOTAL a+b+c

Commitments

1.187

1.103

0.927

0.869

0.824

0.000

4.910

Payments

0.861

1.061

1.011

1.011

0.861

0.105

4.910

The  estimative  credits  foreseen  in  this  planning  shall  be  covered  within  the
allocations  of  appropriations  on  the  B4-3040A  granted  to  the  managing  DGs  (DG
Environment and others) in the framework of the annual budget procedure.

2.4.

Compatibility with financial programming and financial perspective

[X] Proposal is compatible with existing financial programming.

[…] Proposal  will  entail  reprogramming  of  the  relevant  heading  in  the  financial

perspective.

[…] Proposal  may  require  application  of  the  provisions  of  the  Inter-institutional

Agreement.

2.5.

Financial impact on revenue:

[X] Proposal  has  no  financial  implications  (involves  technical  aspects  regarding

implementation of a measure)

OR

[…] Proposal has financial impact – the effect on revenue is as follows:

(NB All details and observations relating to the method of calculating the effect on
revenue should be shown in a separate annex.)

(€ million to one decimal place)

Budget line

Revenue

Prior to
action
[Year n-
1]

[Year
n]

Situation following action

[n+1]

[n+2]

[n+3]

[n+4]

[n+5]

a) Revenue in absolute terms

b) Change in revenue

 (cid:1)

(Please specify each budget line involved, adding the appropriate number of rows
to the table if there is an effect on more than one budget line.)

3.

BUDGET CHARACTERISTICS

Type of expenditure

New

EFTA
contribution

Contributions
form applicant
countries

Heading in
financial
perspective

Non-comp

Diff

NO

NO

NO

No [3]

25

4.

LEGAL BASIS

Treaty establishing the European Community (in particular Article 95 or 174 as appropriate)
and Decision 1600/2002/EC of the European Parliament and of the Council laying down the
Sixth Community Environment Action Programme, OJ L 242, 10.9.2002, p. 1-15.

5.

DESCRIPTION AND GROUNDS

5.1.

Need for Community intervention

5.1.1. Objectives pursued

To reduce the overall environmental impacts of products through their life-cycle.

5.1.2. Measures taken in connection with ex ante evaluation

In order to assess the need for a Community approach to Integrated Product Policy a Green
Paper  was  adopted  in  February  2001.  In  the  stakeholder  responses  to  this  paper  it  became
clear that the development of such an approach at a European level was broadly welcomed.

5.1.3. Measures taken following ex-post evaluation

This will be covered by regular reports mentioned under 8.2.

5.2.

Action envisaged and budget intervention arrangements

Following  adoption  the  Communication  will  be  transmitted  to  the  Council  and  to  the
European Parliament for discussions. Stakeholders will also be welcome to submit comments.
It  may  be  that  legislation  on  particular  aspects  of  IPP  will  be  required  in  the  future.  Please
note that these financial arrangements do not include any actions related to the adoption and
implementation of the Draft Directive on the Eco-design of Energy-Using Products. This will
be covered by a separate proposal from the responsible services.

All those who come into contact with products and services throughout their life-cycle (i.e. in
particular producers, consumers and government) are concerned by the policy. They will all
be asked to implement life-cycle thinking into their product-related activities. Environmental
NGOs  will  also  have  a  subsidiary  role  in  using  their  independence  to  promote  greener
purchasing choices and promoting environmental reporting.

5.3.

Methods of implementation

The promotion of the  strategy  itself  will be  largely  an information-led  exercise.  The  further
development  of  the  particular  tools  in  the  “IPP  Toolbox”  will  necessitate  a  combination  of
legislation,  encouragement  (name  and  fame),  co-operation  and  information.  These  financial
estimates are based on the assumption that only one “pilot product” will be investigated at any
one  time.  Should  several  products  be  worked  on  in  parallel,  or,  if  particular  measures  are
required  following  the  application  of  the  IPP  approach  to  the  “pilot  products”,  then  the
resource  implications will  have  to be reassessed. However,  any  additional  resources  will  be
covered by the existing allocations.

26

6.

FINANCIAL IMPACT

6.1.

Total financial impact on Part B - (over the entire programming period)

(The method of calculating the total amounts set out in the table below must be explained by
the breakdown in Table 6.2. )

6.1.1.

Financial intervention

Commitments (in € million to three decimal places)

Breakdown

2003

2004

2005

2006

2007

Total

2008 and
subs.
Years

Action 1

Action 2

etc.

TOTAL 0

0

0

0

0

0

0

0

0

0

6.1.2.

Technical  and  administrative  assistance,  support  expenditure  and  IT  expenditure
(commitment appropriations)

2003

2004

2005

2006

2007

Total

2008 and
subs.
Years

1) 
administrative assistance

Technical 

and

Technical 

a) 
offices

assistance

b)  Other 
administrative assistance:

technical 

and

- intra muros:

- extra muros:

of  which  for  construction
and 
of
maintenance 
computerised  management
systems

Subtotal 1

2) Support expenditure

a) Studies

0.461

0.381

0.222

0.169

0.128

b) Meetings of experts

0.065

0.061

0.044

0.039

0.035

1.361

0.244

c) Information and
publications

Subtotal 2

TOTAL 0.526

0.442

0.266

0.208

0.163

0.000

1.605

27

6.2.

Calculation  of  costs  by  measure  envisaged  in  Part  B  (over  the  entire
programming period)

Commitments (in € million to three decimal places)

Breakdown

Type
of outputs
(projects, files )

Number of
outputs

Average unit
cost

(total for years
1to 5)

Total cost

(total for years

1to 5)

1

2

3

4=(2X3)

Development of IPP toolbox

- expert consultations

- studies

IPP pilot products

- expert consultations

- studies

Progress monitoring

- expert consultations

- studies

TOTAL COST

Meeting reports

Study 

reports

20

11

Meeting reports

24

Study 

reports

4

Meeting reports

Study reports

17

2

4000 €

80,000 €

4,000 €

80,250 €

4,000 €

80,000 €

0.080 Mio €

0.880 Mio €

0.096 Mio €

0.321 Mio €

0.068 Mio €

0.160 Mio €

1.605 Mio €

The allocation of studies to the three actions is indicative. Depending on different grades of
complexity encountered in the second action, more studies may have to be aimed at the pilot
products and fewer at the other two actions. Depending on the exact subject of the studies and
also  depending  on  the  results  achieved  in  the  first  years  some  studies  may  be  combined  to
cover the first two actions.

7.

IMPACT ON STAFF AND ADMINISTRATIVE EXPENDITURE

The  needs  for  human  and  administrative  resources  shall  be  covered  within  the  allocation
granted to the managing DGs (DG Environment and others) in the framework of the annual
budget procedure.

7.1.

Impact on human resources

Types of post

Staff to be assigned to management of the
action using existing and/or additional
resources

Number of
permanent posts

Number of
temporary posts

Officials 
temporary staff

or

A

B

C

Other human resources

Total

4

0.5

1.5

6.0

Description of tasks deriving from the
action

Desk officers and management

Study contracts, payments, informatics

Secretarial support

Total

4

0.5

1.5

6.0

28

7.2.

Overall financial impact of human resources

Type of human resources

Amount (€)

Method of calculation *

Officials

Temporary staff

Other human resources

0.648 Mio €

6.0 x 108,000 €

(specify budget line)

Total

0.648 Mio €

The amounts are total expenditure for twelve months.

7.3.

Other administrative expenditure deriving from the action

Amount €

Method of calculation

0.013 Mio €

10 x 1300 € (based on two-day missions
including  300€ 
indemnity  +  850€
travelling + 150€ accommodation)

Budget line

(number and heading)

Overall allocation (Title A7)

A0701 – Missions

A07030 – Meetings
A07031 – Compulsory committees 1
A07032 – Non-compulsory committees 1

A07040 – Conferences

A0705 – Studies and consultations

Other expenditure (specify)

Information systems (A-5001/A-4300)

Other expenditure - Part A (specify)

Total

0.013 Mio €

See above

The amounts are total expenditure for twelve months.

1 Specify the type of committee and the group to which it belongs.

I.

II.

III.

8.

Annual total (7.2 + 7.3)

Duration of action

Total cost of action (I x II)

0.661 Mio €

5 years

3.305 Mio €

FOLLOW-UP AND EVALUATION

8.1.

Follow-up arrangements

The Commission proposes to review the effectiveness of the IPP approach every three years
following publication of the Communication. For this purpose the Commission will prepare a
report which will be published and submitted to the institutions.

29

8.2.

Arrangements and schedule for the planned evaluation

The precise modalities for the implementation will have to be arranged, but it will be based on
the information submitted by Member States and other stakeholders to the Commission. The
Commission  will  convene  meetings  of  Member  States  and  stakeholders  to  co-ordinate
reporting  formats  to  facilitate  useful  reporting.  The  Commission  will  also,  in  co-operation
with the European Environmental Agency, try to develop indicators that can assess progress
in implementing the policy.

9.

ANTI-FRAUD MEASURES

The proposed activities only consist of expenditure on personnel, expert meetings and study
contracts.  The  latter  will  be  subject  to  the  Commission’s  usual  control  mechanisms  and
therefore there is no need for supplementary anti-fraud measures.

30