Opinion of the Committee of the Regions on the "Communication from the Commission to the Council and the European Parliament Integrated Product Policy Building on Environmental Life-Cycle Thinking"
Date: 2003-11-20
Institutions: European Committee of the Regions
Subjects: EU environmental policy, manufactured goods, sustainable development, waste disposal, waste recycling

23.3.2004

EN

Official Journal of the European Union

C 73/51

Opinion of the Committee of the Regions on the ‘Communication from the Commission to the
Council and the European Parliament Integrated Product Policy Building on Environmental Life-
Cycle Thinking’

(2004/C 73/10)

THE COMMITTEE OF THE REGIONS,

having regard to the Communication from the Commission to the Council and the European Parliament
Integrated Product Policy — Building on Environmental Life-Cycle Thinking (COM(2003) 302 final);

having regard to the decision of the European Commission of 18 June 2003 to consult it on this subject,
under the first paragraph of Article 265 of the Treaty establishing the European Community;

having regard to the decision of its Bureau of 2 July 2002 to instruct its Commission for Sustainable
Development to draw up an opinion on this subject;

having regard to its opinion on the Green Paper on Integrated Product Policy (COM(2001) 68 final —
CdR 98/2001 fin) (1);

having regard to its opinion on the Communication on the sixth environment action programme of the
European Community — Environment 2010: Our future, our choice — the Sixth Environment Action
Programme — and the Proposal for a Decision of the European Parliament and of the Council laying
down the Community Environment Action Programme 2001-2010 (COM(2001) 31 final — CdR 36/
2001 fin) (2);

having regard to the draft opinion adopted by the Commission for Sustainable Development on
29 September 2003 (CdR 159/2003 rev.) (rapporteur: Mr Tilman Tögel, [member of Saxony-Anhalt
Landtag — DE, PES]);

Whereas:

1.

2.

3.

4.

integrated product policy (IPP) can be instrumental
in the implementation and operation of
sustainable development and responsible resource management, because the environmental policy
regulations hitherto in force in respect of the production and disposal of products are no longer in
tune with the requirements of a sustainable environmental policy and are supplemented by
provisions which take account of the complete life cycle of the product, including the use phase;

regional and local authorities represented on the Committee of the Regions are particularly keen for
IPP to work effectively and well as such a policy can substantially assist and support them in their
task of setting up and maintaining efficient waste treatment and waste disposal facilities;

IPP can be implemented only through a well co-ordinated, synergistic mix of instruments, including
voluntary measures, regulatory approaches (requirements and prohibitions), supply-side measures
(product design), demand-side tools (public procurement, consumer information) and incentives
(such as ecolabelling and life-cycle analyses);

recommendations and considerations that are now being looked at in connection with integrated
product policy have been under discussion for many years (product compatibility, technology
impact assessment, resource conservation, the internalisation of external environment costs etc.) and
are a key factor in the development of sustainability strategies and specific measures to achieve the
objectives of sustainable development, i.e. to meet the needs of the present generation with due
regard for resource conservation and environmental protection so that future generations are not
left to pick up the costs involved and have adequate scope to meet their own needs,

adopted the following opinion at its 52nd plenary session of 19 and 20 November 2003 (meeting of
20 November).

(1) OJ C 357, 14.12.2001, p. 53.
(2) OJ C 357, 14.12.2001, p. 44.

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Official Journal of the European Union

23.3.2004

1. The Committee of the Regions’ views

The Committee of the Regions

and, in that context, asks the Commission to specify
1.10.
in its future communication the product areas in which
determined application of environmental liability is possible
in order to ensure that environmental costs are effectively
included in product prices.

1.1.
recognises the European Commission’s commitment
to make integrated product policy a key tool of sustainable
environmental policy;

1.2.
regrets that the CoR was not explicitly included in the
list of bodies that have set out their views on the Green Paper,
and hopes that, with the adoption of the draft European
constitution, the Commission will take greater cognisance of
the Committee of the Regions as an advisory body (see Part I,
Title IV, Chapter II, Article 31(1); Part III, Title VI, Chapter I,
Article 292 et seq.; Protocol on application of the principles of
subsidiarity and proportionality);

stresses in this connection that the regions and local
1.3.
authorities are key players in the implementation and oper-
ation of IPP, firstly because, in most Member States, regional
and local authorities are responsible for waste disposal and
thus constantly have to deal with products that have reached
the end of their life cycle, and secondly because, as market
customers, they can do much to secure the success of a
procurement policy based on an IPP approach;

1.4.
explicitly welcomes the fact that a handbook for green
public procurement is to be drawn up and recognises its duty
to act as a relay body for promoting green public procurement;

is convinced that the voluntary and cooperative nature

1.5.
of IPP is a basic condition for its success;

1.6.
feels, however, that there is an urgent need for a
mandatory legal framework to implement environmentally-
friendly approaches and actions;

1.7.
deplores the fact that the Commission has now aban-
doned the use of VAT policy in relation to IPP, a measure
which was treated as a promising approach in the Green Paper;

1.8.
considers that there is a need to bring together the
various IPP instruments set out by the Commission and
welcomes the communication platform which the Com-
mission is making available for that purpose;

2. Committee of the Regions’ recommendations

The Committee of the Regions

2.1.
notes that, as far as waste management is concerned,
the Communication from the Commission Towards a thematic
strategy on the prevention and recycling of waste and the IPP
communication should be considered as a single entity. In
particular, the objectives and tasks of waste avoidance should
be pursued primarily through IPP, as IPP is a much more
focused way of achieving these objectives than by deploying
waste management tools;

2.2.
reiterates its proposal made in point 2.22 of its opinion
on the Green Paper on Integrated Product Policy (1) to put in
place a European scheme to collect experiences of
local
and regional authorities’ waste management and to use the
feedback thus obtained to prevent waste in the design and
consumption phases;

considers it expedient to define the term ‘life cycle’ as
2.3.
the impression is emerging that the life cycle that is the subject
of this communication ends when the product ceases to have
any useable value and does not
therefore include waste
avoidance and waste disposal. It should also be established
whether semi-finished stages of a product are to be included
in the life cycle;

2.4.
considers it necessary for the Commission to pursue
actively and consistently the objective of internalising external
environmental costs so that prices reflect products’ environ-
mental impact accurately;

2.5.
calls on the Commission also to make official infor-
mation such as the practical handbook for IPP-based procure-
ment fully available to those players who are involved only
occasionally in public procurement and thus do not have the
technical capacity to use the Commission’s online communi-
cation platform;

points out by way of clarification that the Commission
1.9.
does not pursue the issue of product and producer liability as
a potential means of including waste treatment costs in the
price and thus of applying life-cycle thinking right up to the
final stage of a product’s lifespan under the IPP approach;

(1) CdR 98/2001 fin.

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Official Journal of the European Union

C 73/53

advocates in particular making sufficient changes to
2.6.
the conditions of tender so that local and regional authorities
can meet the expectations placed on them and pursue a policy
of green procurement. In that connection, the Committee of
the Regions would draw attention to point 2.18 of its opinion
on the Green Paper and reiterate its call to exclude suppliers
who fail to meet local, regional, national or European environ-
mental standards from being eligible to supply public goods
or services;

would stress the key role of consumers when consider-

2.7.
ing environmental impact within the life-cycle of a product;

2.8.
considers it necessary to take up measures, goals and
resources developed in the field of consumer protection and
apply them not only to foodstuffs but also intensively as part
of the IPP strategy. Strategies should thereby be developed to
drive home to consumers the need to buy environmentally
sound products, to use them in a way that keeps environmental
impact to a minimum and to dispose of them properly;

asks the Commission to adopt back-up measures to
2.9.
alert consumers to the issues involved at an early stage and
to develop consumer information and consumer education
projects that encourage people to ‘buy green’ and raise
environmental awareness. In that process, the Committee of
the Region acknowledges its responsibility to proactively
advocate, through regional and local players, the incorporation
of environmental
issues into school and even pre-school
education and learning;

2.10.
asks the Commission to consider whether existing
European and national environmental labels are suitable for
IPP and, in doing so;

to bear in mind, on the one hand that the European
2.11.
environmental
less well-known and not as
successful as national labelling schemes (e.g. the German ‘Blue
Angel’ scheme that has been in place for twenty-five years);

is still

label

Brussels, 20 November 2003.

the aim can only be to find synergies, not to abolish national
labels; and

2.12.
on the other, to be sensitive to the fact that in the
interests of effective consumer information, European and
national environmental labelling schemes need to be harmon-
ised and made considerably more consumer-friendly. It is vital
not to flood consumers with excessive information as that
would be contrary to the IPP approach. The European energy
label can serve as a successful example of a consumer-friendly
label;

2.13.
urges that, alongside encouraging voluntary action
by companies and producers to provide reliable product
information in the interests of a transparent product life-cycle
analysis, producer liability be invoked to ensure the provision
of environmental information;

2.14.
calls for even more effective support for the IPP pilot
projects mentioned in point 6.1 from the EU financial
instrument LIFE-environment;

asks the Commission to extend considerably the
2.15.
deadline for suggestions for voluntary pilot projects — at least
until December 2003. To that end, it is also necessary to make
the public more aware of the Commission’s call for voluntary
pilot projects. In any case, the October 2003 deadline for
suggestions is too short;

2.16.
suggests a review of whether the proposed project
operating period of twelve months really gives sufficient
opportunity to consider products’ life cycles thoroughly;

2.17.
notes the Commission’s commitment to deal with
services subsequently, while focusing for the time being on
products and stresses the urgent nature of this issue. In many
cases, especially in the transport sector, the environmental
impact of various types of service is so diverse as to be
incomparable. The Commission must therefore address these
issues decisively.

The President

of the Committee of the Regions

Albert BORE