Opinion of the European Economic and Social Committee on 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)
Date: 2003-12-10
Institutions: European Economic and Social Committee
Subjects: ESC opinion, EU environmental policy, manufactured goods, pollution control measures, product life, waste recycling

30.3.2004

EN

Official Journal of the European Union

C 80/39

Opinion of the European Economic and Social Committee on 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)

(2004/C 80/11)

On 18 June 2003 the Commission decided to consult the European Economic and Social Committee,
under Article 262 of the Treaty establishing the European Community on the above-mentioned
communication.

The Section for Agriculture, Rural Development and the Environment, which was responsible for
preparing the Committee’s work on the subject, adopted its opinion on 13 November 2003. The
rapporteur was Mr Adams.

At its 404th plenary session held on 10 and 11 December 2003 (meeting of 10 December) the European
Economic and Social Committee adopted the following opinion by 81 votes for, one against and three
abstentions.

1.

Introduction

1.1.
The Communication on Integrated Product Policy (IPP)
is one of the coordinated initiatives from the Commission
which begins to tackle sustainability in production and
consumption — in this instance with particular reference to
product life-cycle planning and the minimising of waste and
negative environmental impact. It is part of a larger strategy in
which the European Union recognises that unsustainable
production and consumption are contributory factors to
environmental degradation and global inequity.

The European Union is strongly committed to sustain-
1.2.
able development. This has been increasingly evident
in
numerous statements and strategies preceding and supporting
the Johannesburg Declaration resulting from the 2002 World
Summit on Sustainable Development. This defined a collective
responsibility to achieve the objectives of poverty eradication,
changing consumption and production patterns and protect-
ing and managing the natural resource base for economic and
social development. The Commission has also adopted a report
presented in March 2002, on Environmental Technology
for Sustainable Development (1) and a Communication on
Developing an Action Plan for Environmental Technology (2),
as well as most recently, a Communication Towards a
Thematic Strategy on the Sustainable Use of Natural
Resources (3).

1.3.
The Commission’s Communication on Integrated
Product Policy (IPP) has been prompted by its commitment to
sustainable development and a recognition that IPP represents
an important element of the future strategy on the sustainable

use of natural resources and the prevention and recycling of
waste, and, more generally, that it has a role to play in
contributing to sustainable development and as such relates
both to fulfilling the aims of environmental protection and
helping eradicate poverty in the world.

1.4.
The Communication takes note that an environmental
dimension to product policy is needed because greater dispos-
able income in Europe means that the overall quantity of
products in the EU is increasing. At the same time, the global
reality of poverty must also be born in mind as IPP is an
important aspect for helping to fulfil the EU’s commitment to
global sustainable development. The poorest 40 % of the
world’s people account for only 11 % of world consumption;
the top 15 % account for 56 %. Increasing imports of resources
are also helping shift the environmental burden from the
consuming to the exporting countries.
Imports currently
constitute almost 40 % of the total material requirement of the
EU and they have grown particularly rapidly in the 1990s (4).

1.4.1.
Poverty, environmental degradation and the despair
that they breed are not only morally unacceptable, they
provide the ingredients for the destabilisation of countries and
even entire regions. Amongst the diverse causes and effects of
poverty, unsustainable production and consumption are highly
relevant to the issues and problems that the EU’s sustainable
development strategy are trying to address.

The EU has pressed for sustainable consumption
1.5.
and production to be tackled earlier in the Johannesburg
Implementation Plan and the decision that it will only be
discussed in 2010/2011 indicates a fundamental problem.

(1) COM(2002) 122 final.
(2) COM(2003) 131 final.
(3) COM(2003) 572 final.

(4) See Third Environmental Assessment, European Environmental

Agency, May 2003.

C 80/40

EN

Official Journal of the European Union

30.3.2004

Countries with newly developing economies have reservations
that sustainability may mean restrictions to economic growth
whilst many developed economies have production and con-
sumption patterns that require significant adjustment
to
become sustainable. If the goal of sustainable growth is to be
achieved in a way that satisfies the differing needs of the
developing and developed world, economic activities will have
to take closer account of sustainable development criteria
and indicators. This may involve encouraging economic
development to take a more explicit direction towards positive
human values such as personal development and quality of
life, participation in society, democracy, and justice, and the
monitoring of economic performance according to these goals,
while at the same avoiding unnecessary costs that might
hamper economic development and prosperity.

In particular,

1.6.
The EESC has consistently and energetically sought to
apply principles leading to sustainable development wherever
appropriate in its opinions.
the EESC has
supported the aims of Sustainable Development in its opinions
on the Commission’s Packaging Waste Proposal (1); on the
Directive on Waste from Electrical and Electronic Equipment
(WEEE) (2); on the Commission Communication regarding the
restructuring of the EU fishing industry (3); on the Commission
Communication on a strategy for the sustainable development
of European aquaculture (3); and, in its own-initiative opinion
on the EU’s Lisbon Strategy and Sustainable Development (4).

1.7.
There is an urgent need to reduce negative environmen-
tal impacts of products and services across their life cycles
because the Earth does not have an unlimited capacity to
absorb pollution and supply natural resources. This is the main
focus of the Commission’s Communication on Integrated
Product Policy (IPP). The whole life cycle of products and
services must be taken into consideration in order to prevent
their negative environmental impact merely being moved from
one part of their life cycle to another. Such an approach will
require a change in business perceptions and consumer
behaviour in Europe and all developed economies.

1.7.1.
The principal challenge is to protect the environment
and at the same time to allow economic and social develop-
ment, which are heavily influenced by the production and
consumption of goods. By adding market-based instruments
to traditional ones of command and control, the Integrated
Product Policy (IPP) provides new solutions and opportunities
for achieving sustainable development.

(1) OJ C 221, 17.9.2002, pp. 31-36.
(2) OJ C 367, 20.12.2000, p. 33.
(3) OJ C 208, 3.9.2003.
(4) OJ C 95, 23.4.2003, p. 54.

Experience has shown that in European countries some
1.8.
achievements have been made in the efficient use of natural
resources which has contributed to a stabilisation of the overall
quantity of raw materials used relative to economic growth.
However these flows are not reducing in absolute terms (5).
This implies that the environmental burden related to resource
use remains constantly high and in specific countries an
absolute decline indicates that a ‘business-as-usual’ approach
does not lead to reduced resource use. Furthermore with the
accession of ten new member states to the EU the likely trend
is to increase the flows as they seek to achieve the same
material and product wealth (6).

1.9.
In spite of improvements in minimising environmental
impacts and efforts at reducing wealth discrepancies between
rich and poor countries the net effect of the present patterns
of production and consumption in the developed world
contributes to an increase in global environmental impact and
is one of
the factors hampering the capacity of poorer
If
countries to close the development gap economically.
industrialised countries are to significantly reduce their
environmental impacts, contribute to sustainable development
and play their part in implementing the UN’s Millennium
Development Goals — there is a need for a strategy on
sustainable development which can be consistently applied
across all economic areas and supported by governments and
other institutional actors.

1.10.
This is recognised in the IPP Communication where
it is stated that ‘The challenge is to combine improving life
styles and well being — which are often directly influenced by
products — with environmental protection’. The IPP is there-
fore a fundamental part of the strategy for sustainability. Also
underdevelopment is a strategy on the sustainable use of
natural resources, a thematic waste strategy with increased
emphasis on waste prevention (7), promoting green procure-
ment and fostering environmentally sound technologies (8).
What remains to be adequately covered in the Commission’s
portfolio of strategic initiatives on sustainable development is
the most complex issue — how we modify our behaviour in
order to achieve more sustainable production and consump-
tion patterns.

(5) Resource use in European countries — an estimate of materials and
waste streams in the Community, including imports and exports using
the instrument of material flow analysis, March 2003 — ETCWMF
and EEA.

(6) The EEA’s Third Environment Report (op. cit) shows that new EU
member states will find it difficult to avoid moving towards
unsustainably high levels of direct material input.

(7) COM(2003) 301 final.
(8) COM(2003) 131 final.

30.3.2004

EN

Official Journal of the European Union

C 80/41

This opinion therefore, whilst dealing directly with
1.11.
the Commission’s Communication on IPP, also suggests a way
forward must be found on an essential counterpart without
which such a strategy cannot be effective. This will involve
active cooperation between the different stakeholders —
industry,
the service sector, environmental NGOs,
consumers and governments. The EESC, from its position of
representing civil society, believes that it is necessary also to
identify key elements in encouraging a positive response to
sustainability.

trade,

1.12.
The involvement of businesses and the other relevant
actors mentioned implies, on the one hand, a coherent
information policy, particularly on measures to improve the
protection of the environment along the whole chain of
production and throughout the life cycle of products and, on
the other, a strategy for introducing innovation, identifying
win-win options and adopting best practice, and for taking
advantage of the opportunities that these offer.

2. Gist of the communication

The IPP aims to support sustainable development by
2.1.
impacts of products
reducing the negative environmental
throughout their life-cycle ‘from cradle to grave’. The life cycle
of a product is often long and complicated. It covers all the
areas from the extraction of natural resources, through their
design, manufacture, assembly, marketing, distribution, sale
and use to their eventual disposal as waste. At the same time it
also involves many different actors such as designers, industry,
wholesalers, importers, retailers, the service sector, marketing
people and consumers. IPP attempts to stimulate each part
of these individual phases to improve their environmental
performance.

It

2.2.
is suggested that with many different products
and actors there cannot be one simple policy measure for
everything. Instead, a whole variety of tools — both voluntary
and mandatory — are proposed to achieve this objective.
These include measures such as economic instruments, sub-
stance bans, voluntary agreements, environmental
labelling
and product design guidelines.

— developing a focus on products with the greatest potential

for environmental improvement.

These actions should be carried out along the lines
IPP principles such as life-cycle thinking, stakeholder

2.4.
of
involvement and continuous improvement.

3. General comments

3.1.
The IPP Communication follows the Commission’s
Green Paper of February 2001, which launched a broad
stakeholder consultation on the topic. The EESC adopted its
opinion on this Green Paper in July 2001 (1).

3.2.
In its Opinion on the Green Paper the EESC, whilst
welcoming the intentions of IPP, highlighted a number of
concerns with the approach being advocated. These were:

a)

dependence on broad tax instruments which have consist-
ently generated controversy in an environmental context
and have proved ineffective in substantially curbing the
environmental impact of production activities;

b)

over-reliance on various forms of eco-labelling process as
a generator of consumer and business buy-in (2);

c)

lack of recognition of consumer education campaigns;

d)

e)

underplaying the fact that the adoption of such vitally
important measures as Life-Cycle Analysis (LCAs) and
eco-design necessitates major financial, managerial and
legislative efforts;

the need for stronger action in promoting policies
to support research and innovation tailored to SMEs,
particularly focusing on disseminating information and
on framing innovative processes to develop greener
products.

On the positive side, the Communication, resulting
3.3.
from the Green Paper, does now put some resources behind
product selection methodology and product pilot projects. It
proposes setting up Commission-run working groups and
some steering mechanisms. It also commits to:

2.3.
Two actions are focused on as being able to stimulate
a continuous improvement in the environmental performance
of products:

a)

developing IPP indicators
improvements;

to assess

environmental

— establishing the framework conditions for the continuous
environmental improvement of all products throughout
the production, use and disposal phases of their life-cycle;

(1) OJ C 260, 17.9.2001 p. 35-38.
(2) Point 3.2.4, CES 776/97, OJ C 296, 29.9.1997, p. 77.

C 80/42

EN

Official Journal of the European Union

30.3.2004

b)

c)

a framework for continuous environmental improvement
including examining the effectiveness of existing policy
tools;

promoting the application of lifecycle thinking through
encouraging EU level voluntary pilot projects, on individ-
ual products, aimed at demonstrating and gaining experi-
ence on how IPP can work, as well as other research and
development;

d)

requiring Member States to report on IPP implementation;

e)

f)

g)

stressing the importance of information to consumers
through labelling etc, bearing in mind that consumers
have become more used to production information as a
way of assisting them to be able to make a more informed
choice when purchasing products;

working with the positive aspects of
establishing supply and innovation incentives;

the market

in

calling on Member States to draw up action plans on
greening Public Procurement and clarifying the scope of
public authorities, especially where they also act as service
providers, to apply sustainability criteria.

3.4.
In essence, the IPP Communication is describing an
extended process which will run in conjunction with a
portfolio of other initiatives designed to achieve sustainable
development in general and the reduction of resource use and
environmental
impact of waste in particular. Nevertheless,
there could be greater recognition of the need for a clearer
knowledge based societal consensus and market ‘pull’ — by
both consumers and manufacturers — and for the ultimate
need for coordinated political leadership through comprehen-
sive policy to make effective use of the positive actions noted
in point 3.3.

4. Specific comments

At the same time social cost-benefit analyses and
4.1.1.
environmental impact assessments of alternative policy choices
should form the basis for ensuring that the most efficient
policies are agreed upon and applied. Such analyses should
also include assessments of the consequences for the free
circulation of goods in the Internal Market.

4.2. While the EESC understands that the Commission
Communication cannot be rewritten or changed,
it urges
the Commission to consider the following points for any
subsequent policy strategy or action aimed at developing IPP:
(future IPP strategy) provides:

a) more comprehensive introduction about the role of IPP
in fulfilling the specific commitments made in the Sixth
Environmental Action Programme and other related
policy programmes, in particular recognition of existing
Community environmental and health-related targets
from existing policy frameworks;

b)

a clear indication of the direction and scale of the future
innovations necessary;

c)

a commitment to developing the most appropriate and
effective policy option from the diverse mix of policy
instruments mentioned in the EU’s Sixth Environmental
Action Programme. This should include:

i)

ii)

laying down clear environmental objectives and
ambitions, based on existing policies and strategies
such as Kyoto, the European Community Air Quality
Framework, future Waste Prevention, Recycling and
Resource Strategies and Chemical Substance Restric-
tion Lists (such as OSPAR or the Convention on
Persistent Organic Pollutants);

laying down a timeframe, the scope (which product
or
evaluation and
reporting;

function areas),

indicators,

4.1.
The EESC welcomes the proposal to establish pilot
projects to explore operational thinking which will form a
basis for further suggestions on which sustainable development
measures can be chosen, but also notes that as these are
voluntary it will not always be the case that areas essential to
the success of IPP will be covered. Making further progress
over time on the practical implementation of aspects of IPP
should not be dependent only on the outcomes of voluntary
pilot projects.

iii)

establishing an IPP steering committee and sub-
sequent working groups on specific IPP tools;

iv)

laying down rules and structures for balanced stake-
holder participation at both steering level, in work-
ing groups and on any product specific initiatives;

30.3.2004

EN

Official Journal of the European Union

C 80/43

v)

integrating IPP aims and objectives into public
tendering processes for goods and services;

xiii) recognition of the necessity to create efficient, tailor-
made resources such as an IPP or Benchmarking
Institute and setting up of important ‘consumer
information tools’ such as EU Eco-test networks;

vi)

building on existing scientific knowledge of harmful
substances and commitments to product prioritisa-
tion when deciding on the creation of specific
product
legislation in setting minimum require-
ments on those products which have the greatest
environmental
impacts and engaging with the
related issues of analysis and definition;

vii) driving the integration of product lifecycle thinking
and eco-design across the board for all producers
via continuous improvement with externally and
independently set goals and benchmarks to be
compared to;

xiv) acknowledgement that effective use of IPP to mini-
mise environmental impact and resource use will
require a clearer framework linking all current
initiatives and a capacity to introduce new general
policy themes such as stimulating consumer aware-
ness and building an active consensus in society for
sustainable development;

xv)

recognition that in the long term further action may
be required to progressively adjust economic activity
in accordance with agreed sustainability intentions;

viii) setting up the necessary resources to be able to
provide producers, policy makers and standard
setters with vital and independent technical infor-
mation such as product lifecycle data and product
benchmarks (best available technique [BAT] etc);

xvi) recognition that SMEs face particular problems in
research and the cost of implementation of IPP
initiatives and the need to provide practical support
for smaller companies in manufacturing and the
service industries who make a commitment
to
sustainable methodologies;

ix) overseeing potential future ‘daughter’ initiatives such
as the Eco-design Framework on Energy Using
Products (1) in order not to have widely diverging
methodologies;

xvii) promoting interdisciplinary research to identify the
opportunities and challenges of sustainable pro-
duction and consumption;

x)

a commitment to increase the availability of compre-
hensive product lifecycle data on priority products
and work towards a standardisation of data formats;

xviii)promoting the role of research in implementing
scientific knowledge
environmental
about
impact of various products and creating a sound
basis for developing green technologies, products
and services.

the

xi)

concrete support of economic tools;

xii) notwithstanding the need for a balance between
economic impact assessment and protection of the
environment as well as between producers’ and
consumers’ responsibility, a clear route map is
needed in order to encourage producers and con-
sumers to support a more sustainable products
process across their entire life cycle, from cradle to
grave;

5. Summary

(1) Commission Proposal for a Directive the European Parliament
and of the Council on establishing a framework for the setting of
Eco-design requirements for Energy-Using Products and amending
Council Directive 92/42/EEC, COM(2003) 453 final.

5.1.
It is the view of the EESC that civil society recognises
the need for an environmentally proactive and balanced
policy towards creating a more sustainable production and
consumption. The EESC regards this communication as a
starting point. IPP can make an important contribution to
sustainable development and in implementing the EU’s prio-
rities
regarding environmental protection, but could be
enhanced by a clearer and more detailed policy approach as
outlined above.

C 80/44

EN

Official Journal of the European Union

30.3.2004

It is the view of the EESC that civil society is gradually
5.2.
coming to recognise the need for a paradigm shift towards
genuinely sustainable production and consumption, even if
there is not yet an equivalent willingness to make the
appropriate lifestyle and behavioural changes on a personal
level. Supporting this awareness requires advocating new
priorities in the market — a partnership between consumers
and producers. Consumers are seeking a lead from industry
and government, industry needs the assurance of consumer
support and targeted market incentives, government looks to

civil society for its mandate on new sustainability initiatives.
The EESC urges the Commission to increase its efforts
on achieving a sustainability strategy in a world where
unsustainable production and consumption may prove to be
two of the most toxic elements in the environment (1) (2).

(1) The conclusion of Green Choice: what choice?, a research programme
by the UK National Consumer Council published July 2003.
(2) Policies for Sustainable Consumption September 2003, UK Sustaina-

ble Development Commission.

Brussels, 10 December 2003.

The President

of the European Economic and Social Committee

Roger BRIESCH