Commission staff working document accompanying the proposal for a Regulation of the European Parliament and of the Council on a Community Ecolabel scheme - Impact assessment {COM(2008) 401 final} {SEC(2008) 2119}
Date: 2008-07-02
Institutions: European Commission
Subjects: EU market, European standard, consumer information, eco-label, environmental protection, goods and services, quality label

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COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 16.7.2008 
SEC(2008) 2118  

COMMISSION STAFF WORKING DOCUMENT 

accompanying the 

Proposal for a  

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

on a Community Ecolabel scheme 

IMPACT ASSESSMENT 

{COM(2008) 401 final} 
{SEC(2008) 2119} 

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TABLE OF CONTENTS 

Executive summary  

Section 1: Procedural issues and consultation of interested parties  

Section 2: Policy Background 

Section 3: Problem definition  

Section 4: Objectives  

Section 5: Policy options  

Section 6: Analysis of impacts  

Section 7: Comparison of options  

Section 8: Administrative costs  

Section 9: Monitoring and Evaluation 

Section 10: Conclusion 

Annex - List of current product groups 

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EXECUTIVE SUMMARY 

According to Article 20 of the Ecolabel Regulation1, the EU Ecolabel scheme, which has been 
in  place  since  1992,  has  to  be  reviewed  and  the  Commission  must  then  propose  any 
appropriate amendments to the Regulation. 

The  overall  objectives  of  the  scheme  are  to  encourage  the  sustainable  production  and 
consumption  of  products,  and  the  sustainable  provision  and  use  of  services,  by  setting 
benchmarks  for  good  environmental  performance.  By  guiding  consumers  towards  them,  the 
Ecolabel  should  promote  those  products  and  services  that  have  met  these  benchmarks 
compared to others in the same category. The Ecolabel scheme also needs to be usable as an 
integral  and  effective  part  of  the  wider  Sustainable  Consumption  and  Production  policy 
framework of the European Commission, linking well with other instruments, such as Green 
Public Procurement (GPP), the Eco-Management and Audit Scheme (EMAS), the Eco-design 
directive and the Environmental Technologies Action Plan (ETAP), etc. 

The Ecolabel review and impact assessment process began in February 2002, with the launch 
of  a  large-scale  evaluation  study  on  Ecolabel2  In  addition  to  the  review,  a  number  of 
stakeholder consultations have taken place, culminating in a public internet consultation at the 
beginning of 2006, the results of which indicated strongly the need for significant changes to 
be made to the Ecolabel Regulation. The impact assessment shows that the current scheme is 
unable to achieve its objectives as it suffers from low awareness of the label and low uptake 
by 
industry  resulting  amongst  others  from  excessively  bureaucratic  processes  and 
management.  

Three  main  or  macro-options  are  considered  in  this  impact  assessment:  continuing  with  the 
present approach; phasing out the scheme; or making modifications to the scheme. Within the 
last  option  a  number  of  micro-options  are  analysed  and  then  considered  as  a  package  of 
measures representing the best modifications of the scheme. Following the analysis of impacts 
this last option has been chosen. The following package of measures is therefore proposed for 
the modification and simplification of the scheme: 

•  Design  Regulation  to  better  fit  into  the  other  sustainable  production  and  consumption 

actions of the Commission; 

•  Open up the scope of the label; 

•  Introduce  measures  to  encourage  harmonisation  with  other  eco-labelling  schemes:  EU 
Ecolabel  criteria  as  a  standard  for  other  eco-labels;  fast  track  procedure  to  adopt  criteria 
developed by national ecolabel schemes; 

•  More product groups / quicker criteria development; 

•  Introduce a template for criteria documents to ensure they are more user friendly; 

•  Incorporate guidance for Green Public Purchasing into criteria development; 

•  Simplification  of  the  assessment  and  verification  procedures  and  abolition  of  the  annual 

fee; 

•  Peer review for Competent Bodies; 

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2 

Regulation  (EC)  No  1980/2000  of  the  European  Parliament  and  of  the  Council  of  17  July  2000  on  a 
revised Community eco-label award scheme 
(http://ec.europa.eu/environment/ecolabel/pdf/regulation/001980_en.pdf) 
http://ec.europa.eu/environment/ecolabel/revision_en.htm 

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•  Boost marketing. 

It can be expected that this modification and simplification of the scheme will lead, on the one 
hand to a considerable increase in companies using the label, therefore also to an increase in 
Ecolabelled products on the market and, on the other hand, to an  increase in the number of 
consumers  that  know  about,  and  are  prepared  to  buy,  Ecolabelled  products  as  well  as  to  an 
increase in the use of EU Ecolabel criteria in public procurement. The Ecolabel will be better 
tailored to policy makers, particularly within the framework of the Sustainable Consumption 
and  Production  Action  Plan,  and  will  be  a  useful  benchmark  and  information  tool  on  the 
environmental performance of products and services. 

The  economic  and  environmental  impacts  of  the  scheme  will  depend  on  the  Ecolabel's 
success and this will in turn depend, amongst other factors, on how well it co-ordinates with 
other  policy  instruments  aiming  at  promoting  innovation  in  the  life-cycle  environmental 
performance of products. Forthcoming Commission actions on Sustainable Consumption and 
Production will examine ways to use a range of product policy instruments in a coherent and 
co-ordinated way to maximise their effect as a whole in driving both innovation and sales of 
better performing products. As the Ecolabel would be a part of such a package of instruments, 
its impact will need to be judged as part of that package. 

This  impact  assessment  concludes  that,  as  a  voluntary  instrument,  a  modified  Ecolabel  can 
have  net  economic  benefits  for  the  EU  economy,  and  increase  both  competition  and 
competitiveness.  The  Ecolabel  therefore  works  with  the  market  and  –  with  its  simplified 
approach – is a model "better regulation" policy instrument.  

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SECTION 1: PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 

1.1. 

Organisation and Timing 

Work Programme reference: 2007/ENV/011 

General chronology of the Impact Assessment: 

The  impact  assessment  process  began  in  February  2002,  when  the  Ecolabel  Policy 
Management  Group  first  met  and  was  given  the  task  to  "continue  to  develop  and  adapt  the 
long-term policy and strategy of the scheme, as well as the integration of the Ecolabel in the 
various policies being developed in relation to sustainable consumption". A sub-task of this 
multi-stakeholder group, set up by the European Union Ecolabelling Board according to their 
roles  defined  by  Commission  Decision  200/730/EC3,  was  to  prepare  for  the  revision  of  the 
scheme. The official evaluation study (named the 'EVER' study – see below) was launched in 
2005.  This  study  was  accompanied  by  a  Commission  inter-service  group  that  met  on  two 
occasions. 

Task 

Deadline 

Status 

External evaluation 

Dec 04 - Dec 05 

Completed 

Selected stakeholder consultation 

Jan 06 – Dec 06 

Completed 

Draft main direction revision 

May 06 – June 06 

Completed 

Internal agreement main direction 

June 06 – Nov 06 

Completed 

Draft text Regulation 

Nov 06 – Aug 07 

Completed 

Impact assessment 

Dec 06 - Apr 07 

Completed 

(incl. stakeholders consultation) 

Internal agreement draft text 

May 07 - July 07 

Completed 

Revise draft text I 

Aug 07 - Feb 08 

Completed 

Stage  delayed  due  to  integration  into 
SCP Action Plan 

Inter-service consultation 

Mar 08 - Apr 08 

Underway 

Revise draft text II 

Apr 08 – May 08 

To be completed 

Commission adoption new Regulation 

June 08 

To be completed 

EP – Council co-decision 

Sep 2008 - End 2009  

To be completed 

Adoption new Legislation 

Beg 2009 – End 2010 

To be completed 

3 

Commission Decision of 10 November 2000 establishing the European Union Ecolabelling Board and 
its rules of procedure (OJ L 293 p24-30) 

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1.2. 

Consultation and expertise 

External expertise used: 

External  expertise  was  used  to  conduct  the  evaluation  study  of  the  existing  EMAS  and 
Ecolabel Regulations. A large-scale evaluation study on the EMAS and Ecolabel instruments 
was  carried  out  by  a  consortium  of  consultants  led  by  Bocconi  University,  known  as  the 
‘EVER’  study.4  This  study  included,  as  well  as  a  major  literature  review,  two  stakeholder 
workshops  and  in  depth  interviews  with  participants  and  non-participants  in  the  schemes  as 
well as other interested parties. The Policy Management Group also provided input and was 
made  up  of  representatives  of  Member  States,  consumer  and  environmental  NGOs  and 
industry. This group met on twelve occasions and produced four reports on the future of the 
Ecolabel scheme. A second important source was the study carried out for the Commission by 
AEA Technology "The Direct and Indirect Benefits of the European Ecolabel"5. 

In  addition  this  impact  assessment  makes  use  of  the  findings  of  the  Working  Group  on 
Product  Information  Needs6  (one  of  the  EU  Integrated  Product  Policy  working  groups 
consisting of experts from government, industry and NGOs). 

Stakeholder consultation: 

Significant  consultation  has  taken  place  with  members  of  the  multi  stakeholder  EU 
Ecolabelling  Board  (EUEB)  based  on  informal  discussion  documents  prepared  by  DG 
Environment (including six days of documented workshops spread over the last two years at 
EUEB  meetings  in  Brussels  and  EUEB  Presidential  meetings  in  the  Member  States).  These 
discussions  have  generated  detailed  written  responses  from  key  stakeholders  (i.e.  from 
Member  States,  environmental,  consumer  and  industry representatives) that have guided the 
Commission  in  the  early  stages  of  developing  options  for  the  revision  of  the  scheme.  The 
above mentioned evaluation study (EVER) is partly built on detailed interviews with different 
stakeholders. 

Finally,  as  part  of  the  Impact  Assessment,  a  public  stakeholder  consultation  using  the 
integrated  policy  making  (IPM)  internet  consultation  tool  was  organised  in  January  and 
February  2007.  This  on-line  questionnaire  enabled  all  types  of  stakeholders  to  input  their 
opinion on options proposed for the Ecolabel revision. The results of the 185 responses have 
been  analysed  and  a  report  has  been  prepared  in  line  with  Commission  guidelines.7  These 
results support the main directions of the revision options proposed, although in general they 
would favour a more radical change to the running of the Ecolabel (away from Commission 
Decision) and more radical rules on the influence of the criteria, such as them being used for 
reduced taxation or as the minimum standards for green claims. 

Commission's minimum standards: 
The Commission’s minimum standards on consultation have been met.8 The time allowed for 
stakeholders  to  reply  to  the  internet  stakeholder  consultation  was  more  than  8  weeks,  the 
minimum  standard  for  the  Commission.  Additionally,  as  outlined  above,  extensive 

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http://ec.europa.eu/environment/ecolabel/revision_en.htm 
http://ec.europa.eu/environment/ecolabel/pdf/market_study/benefitsfinalreport_1104.pdf 
http://ec.europa.eu/environment/ipp/pdf/20070115_report.pdf 
http://ec.europa.eu/environment/ecolabel/pdf/revision/revision_report2007.pdf 
COM  (2002)  704  final,  Communication  from  the  Commission:  Towards  a  reinforced  culture  of  consultation  and 
dialogue - General principles and minimum standards for consultation of interested parties by the Commission 

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stakeholder consultation has been on-going with all types of stakeholder and interested parties 
beginning in 2005 and continuing during the course of 2006 and 2007. 

Main results of the consultation: 

The  main  conclusion  from  the  consultation  exercise  is  that,  while  the  Ecolabel  scheme  has 
significant  potential,  a  number  of  changes  would  be  necessary  for  a  more  successful 
implementation: 

•  There is a strong need to integrate different instruments for environmental product policy. 
The EU Ecolabel scheme therefore has to be revised in such a way as to best fit within the 
mix  of  other  environmental  and  sustainable  product  policy  instruments.  The  Ecolabel 
cannot be a stand-alone instrument, but part of a well organised Sustainable Consumption 
and Production policy9, where outputs such as Ecolabel criteria, Green Public Procurement 
criteria, ETAP performance targets and Eco-design criteria etc. are linked closely together. 

•  The  management  of  the  scheme  needs  to  be  improved.  In  other  words,  who  does  what 
needs to be more clearly defined and the bureaucratic processes imbedded in the scheme 
need to be rationalised, allowing it to be run in a more business-like way. 

•  The  bureaucracy  linked  to  criteria  development  for  product  groups  and  to  application 
procedures needs to be reduced whilst at the same time keeping the ambition level high. 

•  Criteria documents have to be much more user friendly with a standardised format. 

•  The  assessment  and  verification  procedures  for  the  scheme  have  to  be  simplified  to 
improve  access  to  the  scheme  and  to  align  it  with  other  Commission  product  labelling 
schemes. 

•  The  number  of  product  groups  as  well  as  of  licence  holders  has  to  be  substantially 
increased, targeting those areas of highest environmental impact and where the possibility 
of improvement is highest.  

•  A more successful Ecolabel will, above all, depend on a substantially increased marketing 

budget. 

•  There  is  a  clear  need  to  better  co-operate  and  co-ordinate  with  established  national  and 

regional ecolabel schemes. 

1.3. 

Impact Assessment Board 

A previous version of this IA was sent to the Commission's Impact Assessment Board which 
delivered  its  opinion  on  30  May  2007.  This  has  led  to  a  number  of  changes  to  the  text 
including the following: 

•  Extending  Section  3:  Problem  Definition,  especially  with  regard  to  the  justification  for 

having a third-party-verified ecolabel at EU level. 

•  Re-arrangements of the micro-options in Section 5: Policy Options. 

9 

The June 2006 European Council conclusions9 on the EU SDS established SCP as a new key priority 
policy  area  for  action  alongside  climate  change,  clean energy,  sustainable  transport,  natural  resources 
and  public  health.  It  called  for  the  Commission  to  put  forward  an  Action  Plan  by  2007  to  "help  to 
identify  and  overcome  barriers  for  SCP,  ensure  better  coherence  between  the  different  related  policy 
areas, and raise awareness among citizens and change unsustainable consumption habits". 

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•  Deepening the analysis of impacts in Section 6, amongst others concerning Ecolabel as a 
driver  for  innovation,  social  impacts  and  macro-options  1  and  2  (business  as  usual  and 
phasing out the scheme). 

•  Adding more substance to the description of administrative costs in Section 8. 

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SECTION 2: POLICY BACKGROUND 

To  understand  the  possible  need  for  a  revision  of  the  Ecolabel  Regulation  we  first  need  to 
develop an understanding of how the current scheme works. The following gives an overview 
of the structure, procedures and bodies of the EU Ecolabel under the current Regulation: 

European Union Ecolabel scheme – an overview 

THE MAIN ELEMENTS OF THE SCHEME 

Being  a  voluntary,  market-based  instrument,  the  primary  function  of  the  EU  Ecolabel  is  to 
stimulate  both  the  supply  and  demand  of  products  that  have  a  lower  environmental  impact 
compared  to  others  in  the  same  category.  On  the  demand  side,  the  scheme  gives  European 
consumers  the  means  to  make  informed  environmental  choices  when  purchasing  products. 
With respect to supply, the EU Eco-label has the clear objective of encouraging businesses to 
market  greener,  officially  licensed,  products.  The  "Flower"  is  the  assurance  that  a  product 
which is marketed as "green", really belongs to the high end of the environmental market. 

The  Europe-wide  coverage  of  the  scheme  means  that  companies  do  not  have  to  make 
applications in every country where they wish to market their products, and thus avoids time-
consuming and costly procedures. The same logo is used regardless of the product group in 
question,  thereby  reducing  consumer  confusion  due  to  the  numerous  self  claims  and  green 
logos in existence. 

The  label  is  awarded  only  to  those  products  and  services  that  meet  the  selective  criteria 
developed and decided in a transparent process with representatives from industry, commerce, 
environmental  and  consumer  organisations.  Ecolabel  criteria  are  based  on  studies  which 
analyse the impact of the product or service on the environment throughout its environmental 
life-cycle,  starting  from  raw  material  extraction  in  the  pre-production  stage,  through 
production, distribution and disposal. 

It is for the producer, retailer or service provider to decide whether or not to apply, once the 
criteria are published in the Official Journal. The voluntary nature of the scheme means that it 
does not create barriers to trade. Foreign and Community producers may apply for the logo if 
they meet the criteria and want to market their products in the EU/EEA. 

THE ACTORS 

The Commission 

The Commission is responsible for the overall management and coordination of the scheme. It 
has the power of "proposal" on every legal document for the implementation of the scheme 
(criteria  documents,  fee  structure,  rules  of  procedures  of  the  different  groups,  standard 
contract are all published as Commission Decisions in the Official Journal), as is the case with 
all legal acts coming from the EU. These proposals, agreed via inter-service consultation, are 
then submitted to a "Regulatory Committee", i.e. a vote by Member States. Together with the 
Member States the Commission is responsible for marketing the Ecolabel. It gives financial 
support to NGOs to ensure a balanced stakeholder participation. 

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Competent Bodies 

The  Ecolabel  Regulation  requires  each  Member  State  to  designate  a  Competent  Body  (CB) 
which  is  responsible  for  implementing  the  Ecolabel  scheme  at  MS  level.  The  CBs  have  to 
contribute to criteria development, they have to consult stakeholders at MS level, market the 
scheme  (shared  responsibility  with  the  Commission),  receive  applications  from  companies 
and they award the label after verification as to whether all the criteria have been met. 

The Consultative Forum 

The  Consultative  Forum  is  the  stakeholder  forum  and  is  composed  of  representatives  from 
industry, trade unions, SMEs and consumer and environmental NGOs. 

The EU Ecolabelling Board (EUEB) 

Composed  of  representatives  of  the  CBs  and  the  members  of  the  Consultative  Forum,  the 
EUEB meets 3 to 5 times a year and discusses draft criteria documents as well as any other 
issue relevant for the implementation of the scheme. The EUEB has several sub-groups: the 
so-called Management Groups (currently for Marketing and Co-operation and Co-ordination) 
and the ad-hoc working groups which discuss draft criteria for product groups at expert level. 
The Commission acts as the Secretariat for the EUEB. 

The Competent Body Forum 

In this forum, CBs discuss implementation issues related to the criteria documents in order to 
ensure a harmonised approach across the EU. 

The Regulatory Committee  

Representing  the  MS  governments,  this  Committee  votes  on  draft  criteria  documents  tabled 
by the Commission (after they have been prepared and discussed by ad-hoc working groups 
and  the  EUEB).  The  voting  rights  are  the  same  as  in  Council,  and  a  qualified  majority  is 
needed. 

THE PROCEDURES 

Award criteria development 
The  initiative  for  selecting  a  product  group10  is  taken  either  by  the  Commission  or  by  the 
EUEB. Once a product group is selected for the development of new criteria, the Commission 
gives  a  mandate  (Commission  Decision)  to  the  EUEB  to  proceed  with  the  work.  After  the 
completion of official tender procedures, one of the Competent Bodies is awarded a contract 
to take the lead for this product group. 

The  EUEB  procedures  foresee  a  certain  amount  of  preparatory  work  led  by  this  lead 
Competent Body to determine whether the product group falls within the scope of the scheme, 
notably  representing  a  significant  volume  of  sales,  involving  a  significant  environmental 
impact and equivalent potential for improvement and a significant sales volume. 

A  feasibility  and  market  study  is  carried  out  to  collate  data  on  the  following  aspects:  the 
market structure and the various types of product groups on the EU market, the opinions of all 
interested  parties,  the  key  environmental  impacts  and  key  elements  relating  to  the  product's 
fitness  for  use,  an  inventory  of  eco-labels,  standards,  test  methods  and  studies.  Consumer 
perception, functional differences between types of products and the need for identifying sub-
groups will be assessed. Generally the interests of the main parties and SMEs concerned and 

10 

The Ecolabel regulation defines a product group as "any goods or services which serve similar purposes 
and are equivalent in terms of use and consumer perception." 

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the overall impact are key elements for the selection of a product group and the development 
of the scheme. 

An  ad-hoc  working  group  is  organised  by  the  lead  Competent  Body.  Composed  of  experts 
from  the  Member  States  and  representatives  of  all  interested  parties  concerned,  the  group 
evaluates the preparatory phase and discusses possible criteria. On the basis of these results 
and  consultations  (usually  3  or  4  meetings  per  product  group),  the  lead  Competent  Body 
drafts a criteria document which is then presented to and discussed by the EUEB (usually also 
3 to 4 times). Once the draft criteria are sufficiently negotiated in the EUEB, the  document 
goes  into  an  inter-service  consultation  process  within  the  Commission  where  all  relevant 
Commission  services  either  give  their  agreement  or  require  changes  to  the  presented  draft. 
After  a  consensus  has  been  reached  within  the  Commission,  the  draft  document  goes  to  a 
Regulatory  Committee  (Member  States  delegates)  where  it  needs  to  achieve  a  qualified 
majority for adoption (Comitology). 

After a positive vote, the document is translated into all the official EU languages before it is 
published in the Official Journal as a Commission Decision. This whole process can take up 
to four years and sometimes criteria may be outdated by the time they enter into force. Even 
small changes that may turn out to be necessary as a result of the first applications (see below) 
for these new product groups can take up to two years before entering into force. 

Applications and award of the label 

Companies which want to use the Ecolabel have to apply to the Competent Body in the MS 
where  the  product  is  manufactured  (if  it  is  manufactured  in  several  MS  the  company  can 
choose one of these MS's Competent Bodies to apply). For imported products, the application 
has to be filed with one of the CBs where the product is imported. After a positive verification 
of the application, the CB concludes a contract with the company which entitles the applicant 
the  use  the  Ecolabel  for  marketing  purposes  for  the  remaining  period  of  validity  of  the 
ecological criteria. The Competent Body charges a harmonised fee for the application and the 
annual use of the Flower logo. 

The award of the Ecolabel means that successful applicants are permitted to use the official 
Flower logo on their approved product in a market of almost 500 million consumers. Thus a 
consumer in a supermarket who is faced with a line of different brands of laundry detergents 
for instance, will be able to pick out, by checking the Ecolabel logo, the ones which achieve a 
high standard of environmental performance compared with the rest of the field. 

Following  the  request  in  the  Ecolabel  Regulation  to  review  the  scheme  after  a  certain  time, 
the Commission launched an evaluation study which, in short, showed that after 15 years of 
existence the EU Ecolabel has not reached its potential. 

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SECTION 3: PROBLEM DEFINITION 

In  the  context  of  the  revision  of  the  EU  Ecolabel  we  have  to  start  our  analysis  with  two 
fundamental questions: 

1. Why an EU Ecolabel? 

2. Why is there a need for revising the Ecolabel Regulation? 

1. Why an EU Ecolabel? 

As  highlighted  in  different  reports  published  by  the  European  Environment  Agency  and 
others, the state of the environment gives raise to increasing concerns. Global warming is just 
one  –  and  currently  the  most  prominent  –  key  word  in  this  context  but  many  others  would 
need  to  be  mentioned  as  well  –  such  as  bio-diversity,  air  and  water  pollution  or  ozone 
depletion. 

There is a clear need to reduce the negative impacts of production and consumption patterns 
on  the  environment,  health  and  natural  resources.  Currently,  the  Commission  is  preparing  a 
Green Paper on an Action Plan on Sustainable Consumption and Production (SCP) which will 
constitute the framework for an integrated implementation of a mix of instruments aiming at 
reducing exactly this negative impact of modern life on the environment, health and natural 
resources. 

A multi-criteria, third party verified Ecolabel based on life-cycle thinking could constitute a 
very important element of such a mix of SCP policy instruments and the importance of such 
an  Ecolabel  scheme  has  already  been  emphasised  in  earlier  policy  documents  such  as  the 
Commission's  Communication  on  Integrated  Product  Policy11  and  the  6th  Environmental 
Action Programme12 Eco-labelling also has some unique benefits over other possible policy 
instruments  such  as  taxes  and  direct  regulation  –  for  example  the  direct  empowerment  of 
consumers  themselves  to  drive  environmental  change.  In  this  way,  eco-labels  can  provide 
information to consumers about what the key environmental issues are in relation to a product 
and what the differences between products are. Additionally, other instruments may make use 
of  the  EU  Ecolabel  scheme  in  the  future  in  terms  of  criteria  development  and  stakeholder 
involvement.  Examples  might  be  lower  taxes  for  Ecolabel  products  or  direct  regulation 
concerning non-Ecolabel products. 

Within a single market a single set of guidelines benchmarking the environmental credibility 
of  products  is  the  logical  way  forward,  as  opposed  to  having  different  benchmarks  in  each 
Member  State.  An  EU-wide  scheme  makes  it  easier  for  businesses  wishing  to  market  more 
"environmentally friendly" products within the EU and it means consumers can purchase so-
called "greener" products wherever they are, safe in the knowledge that these products share 
common  environmental  credentials.  The  EU  Ecolabel  is  the  only  such  label  for  the  entire 
internal market - existing national or regional eco-label schemes cover it only in part. 

If consumers, as well as private and public purchasers are to take environmental criteria into 
consideration when they choose their products and services in the market, it is important that 
they  can  find  easily  understandable  and  credible  guidance  to  enable  them  to  distinguish  the 
truly  "green"  products  from  their  competitors.  Eco-labels  can  play  a  very  important  role  in 
any  package  of  measures  aiming  at  promoting  development  and  sales  of  greener  products; 

11 
12 

(IPP) (COM (2003) 302 final) 
(Decision No 1600/2002/EC) 

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they  set  a  clear  benchmark  for  the  market  and,  for  example,  eco-label  criteria  can  also  be 
included in calls for tender in green public procurement. 

The  EU  Ecolabel  also  provides  a  useful  benchmark  of  environmental  performance  in  other 
ways: 

•  The EVER study confirms that the EU Ecolabel criteria are used even by non-participating 
companies, with more than half of such companies interviewed declaring that they use the 
Ecolabel to benchmark their environmental performance, even when they do not apply for 
the label. 

•  Under the Eco-design Directive for energy-using products13, any product which has been 
awarded  the  Ecolabel  is  automatically  considered  as  compliant  with  the  implementing 
measures. 

•  EU Ecolabel criteria have also been used in some cases by other eco-label schemes like the 
Austrian Ecolabel or the Nordic Swan. Both have chosen to directly adopt the EU criteria 
word-for-word for some of their own product groups. 

As a voluntary instrument, an eco-label can have net economic benefits for the EU economy, 
potentially  increasing  both  competition  and  competitiveness.  The  Ecolabel  will  reward 
innovation  with  increased  profits,  providing  market  incentives  for  greater  innovation  in  the 
EU economy. 

The  obligatory  life-cycle  approach  ensures  the  consideration  of  relevant  impacts  across  the 
different environmental problems and from cradle to grave therefore avoiding the mere shift 
of burdens. 

2. Why is there a need to revise the Ecolabel Regulation? 

The main problems identified with the current scheme are: 

Low awareness 

The EVER study mentions low awareness as the most significant barrier in using the Ecolabel 
for marketing purposes. According to a recent Eurobarometer Survey14, 48% of Europeans do 
not know what the logo means while only 11% correctly said that it is a label for ecological 
products  and  services.  In  comparison,  80%  of  Germans  know  the  Blue  Angel  and  67%  of 
people  in  the  Nordic  countries  understand  the  Swan.15  The  Eurobarometer  also  finds  that, 
apart from being widely unknown, the logo is also confusing to consumers. Many respondents 
think either it stands for organic food or just for high energy efficiency. 

13 
14 
15 

See http://ec.europa.eu/enterprise/eco_design/dir2005-32.htm 
http://ec.europa.eu/environment/ecolabel/pdf/studies/eurobarometer_survey.pdf 
Source: http://www.svanen.nu 

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Low uptake by industry 

Over the 15 years of its existence the EU Ecolabel has attracted some 470 companies (many 
of which are SMEs). Beginning of 2007, the Blue Angel had 560 companies16 and the Nordic 
Swan 680 (These being the biggest two national ecolabelling schemes). 

While  those  using  the  scheme  point  out  the  positive  environmental  benefits  they  have 
brought, and while the scheme continues to grow steadily with around € 800 million of sales 
of eco-labelled products, it still commands a very small EU market share in relative terms. 

What are the underlying drivers of these problems? 

a) 

Regulation too restrictive 

A general lack of flexibility of the scheme due to the restrictive way in which the Regulation 
is  written  is  also  seen  as  a  problem.  The  EU  Ecolabel  is  unable  to  respond  to  new 
environmental challenges for this reason. Some examples of this are: 

– 

– 

– 

It  is  difficult  to  develop  Ecolabel  criteria  alongside  criteria  for  other  Commission 
instruments  –  both  existing,  eg.  Eco-design  of  Energy  using  Products  Directive, 
ETAP  Performance  Targets  or  future  eg.  possible  proposals  coming  from  the  SCP 
Action Plan 

All food products and medical devices are currently excluded from the scope of the 
EU  Ecolabel.  However,  food  production  has  been  highlighted  as  having  one  of  the 
greatest environmental impacts17 in terms of production and consumption. A number 
of new schemes are being developed in the EU looking at the "carbon footprint" of 
food  products,  but  the  current  EU  Ecolabel  is  unable  to  offer  its  expertise  in  this 
field. 

Calls for an EU Ecolabel for sustainable fisheries are also impossible to respond to 
by the scheme. 

Insufficient  co-operation  and  harmonisation  with  other  ecolabel  schemes  at  national 

b) 
and regional level 

This issue has been discussed at length during the last revision of the Ecolabel Regulation and 
subsequently in the EUEB and its Co-operation and Co-ordination Management Group. It has 
always  been  seen  by  all  as  being  of  crucial  importance  to  give  the  Ecolabel  real  "added 
value", however up to now only occasional measures have been implemented on a voluntary 
cooperation basis. In a few cases other schemes have adopted EU criteria documents which 
gives  companies  the  opportunity  to  get  both  labels  through  one  application  and  also  save 
money  on  fees,  but  most  of  the  time  criteria  development  in  the  different  schemes  is  quite 
independent of what happening at EU level. This makes it necessary for companies willing to 
market  their  products  with  an  eco-label  to  adjust  to  different  requirements  and  to  apply  for 
different labels separately (given the still low level of awareness of the EU label, companies 
still have an interest in also using the well-known labels in some countries – see above "level 
of awareness"). 

c) 

The Ecolabel faces strong competition from green self-claims 

16 
17 

Source: www.blauer-engel.de 
See  EIPRO  study,  Environmental  Impacts  of  Products  –  Analysis  of  the  life  cycle  environmental 
impacts related to the final consumption of the EU-25 
(http://www.jrc.es/publications/pub.cfm?id=1429) 

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14 

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The  consumer  is  confronted  with  numerous  green  claims  on  products  without  knowing  on 
what criteria development process these claims are based. The number of these self-claims by 
industry  suggests  that  the  current  legal  framework  seems  inadequate  and  the  consumer  is 
often left in confusion or uncertainty. 

d) 

Insufficient stakeholder involvement in product group criteria development 

The  evaluation  study  on  the  Ecolabel  highlighted  the  fact  that  many  stakeholders,  such  as 
industry,  do  not  feel  fully  involved  in  the  scheme  because,  while  they  can  contribute  to  the 
working groups on the development of the criteria documents, their comments are often not 
responded to. 

e) 

Procedural and organisational problems – i.e. excessive bureaucracy 

The evaluation study highlights the complexity of the Ecolabel structures and procedures as a 
barrier for the development of the scheme. Within the current organisational framework of the 
EU  Ecolabel  it  is  possible  to  develop  one  or  possibly  two  new  product  groups  a  year. 
However, as the total number of product groups increases there are an increasing number of 
product  group  criteria  that  need  to  be  revised  leading  to  a  subsequent  reduction  in  the 
resources available for the development of new products groups. Simple revisions of criteria 
take years to complete and the final decision-making process on criteria is long and political. 
For fast-changing products such as electronic devices it is crucial to have a framework which 
allows  a  frequent  and  quick  up-date  otherwise  criteria  would,  in  a  short  space  of  time,  be 
unable to keep up with market developments. 

Low number of product group categories 

f) 
At  the  beginning  of  2007,  23  product  groups  were  in  force18.  A  rather  modest  number 
compared to 80 in the German Blue Angel system and the 60 in the Nordic Swan. 

g) 

Problems in using the Ecolabel in green public purchasing activity 

Currently, there are two problems: Firstly, criteria documents are not easily usable for public 
procurement purposes because they are often long and complicated which makes it difficult to 
extract  the  relevant  parts  for  calls  for  tender.  Secondly,  the  procurement  directives  do  not 
allow  those  involved  in  the  process  to  directly  ask  for  Ecolabelled  products  but  only  to  use 
Ecolabel criteria for the technical specifications. 

h) 

Fees and cost of getting the label 

The annual fee is currently a % of sales of the Ecolabelled product, this can scare off potential 
applicants, because the more they sell the higher the fee will be. This seems to go against the 
idea of the polluter pays principle, with those companies making the effort to produce more 
environmentally sound products, paying for the label. It also requires a bureaucratic process at 
the  end  of  each  year.  On  top  of  the  fees,  companies  have  to  bear  costs  for  testing  and 
verification which, for some product groups, can be considerable – in certain cases more than 
€10,000.  The  criteria  themselves  are  often  co mplex  and  difficult  to  work  though,  so  the 
application process can take some time. 

i) 

Lack of funding for marketing and running the scheme 

The EU Ecolabel budget for marketing in the whole of the EU directly from the Commission 
is  around  €460K  per  year  with   5  dedicated  staff  helping  to  run  the  scheme.  (with  around 
€150K per annum on product group development  and revision) Member States spending on 
marketing  of  the  Ecolabel  varies  year  on  year  around  an  average  figure  of  approximately 

18 

See list of product groups in Annex. 

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€1.5m. Within the Member States there is a total  of 36 staff, with an annual running cost of 
about  €2.3m.  Income  from  fees  was  around  €260K   in  2004.  This  is  clearly  insufficient  to 
make a brand – and from a marketing perspective the Ecolabel can be seen as a brand – well 
known in the market. 

As a comparison, the Nordic Swan's current annual budget in Norway, Sweden, Denmark and 
Finland  is  about  €7.5m  and  the  scheme  is  run  by  around  70  employees.  Additionally  they 
have a budget of €3m for marke ting, information and sales in 4 countries comprising about 25 
million people altogether. 

According to the EVER study "95% of the companies participating in the EU scheme use the 
Ecolabel in their marketing campaigns (TV and press advertising, promotion initiatives on the 
point-of-sale, etc.)". However, as long as the total number of companies is low, the impact of 
their individual marketing activities is limited. There is a clear need for money for an initial 
period  to  boost  knowledge  of  the label  to  a  point  where  companies  can  clearly  see  benefits 
from using it. 

j) 

Lack of transparency with regards to implementation of the regulation in MS 

Competent Bodies are responsible for the assessment and verification of the applications they 
get from companies wanting to use the label. Currently, there is no systematic information on 
the consistency in which the Regulation is applied by the different Competent Bodies. Usually 
three times a year there is a CB meeting in order to discuss issues of implementation, but only 
a  limited  number  of  CBs  participate  in  these  meetings  and,  in  general,  it  is  unclear  if  the 
Regulation is implemented in a consistent and harmonised way across the EU. 

The  harmful  environmental  impacts  over  the  life-cycle  some  products  can  be  much 
k) 
greater than other products on the market which serve the same function, yet there are often 
no reasons for manufacturers to improve the environmental performance of their products. 

As the market price does not reflect the environmental damage caused during the life-cycle, 
more  harmful  products  compete  at  an  advantage  against  similar  products  with  improved 
environmental performance – with two potential results: a) there is 'unfair' price competition 
to  the  disadvantage  of  products  which  are  more  expensive  because  they  have  improved 
environmental  performance,  which  limits  the  commercial  rewards  for  manufacturers  who 
improve  their  product's  performance  –  and  this  acts  as  a  break  to  innovation;  and  b) 
consumers  unknowingly  purchase  products  whose  additional  environmental  harm  to  society 
outweighs the cost savings to the consumer. 

Manufacturers  of  products  with  worse  life-cycle  impacts  have  few  or  no  reasons  to  try  to 
improve those products performance, which therefore may slow improvements in the product 
group  as  a  whole.  This  is  likely  to  limit  the  effectiveness  of  Ecolabel  as  an  instrument 
promoting gradual improvement of product environmental performance. 

The EuP Directive is designed to tackle these problems, but has a scope limited to products 
which  use  energy.  The  possibility  of  introducing  implementing  measures  for  removing  the 
worst  performing  products  from  the  market  in  terms  of  their  environmental  performance 
could  also  be  desirable  and  the  Ecolabel  scheme  could  act  as  a  benchmarking  tool  for  any 
such policy. Any of the current range of Ecolabel product groups could be used as an example 
such  as  using  the  Ecolabel  criteria  to  recommend  standards  on  the  environmental  impact  of 
cleaning  products  on  the  market,  helping  to  reduce  the  levels  of  toxic  compounds  found  in 
such products. 

EN 

16 

   EN 

Who is affected, in what ways, and to what extent?  

The Ecolabel has failed to provide the intended service to a number of stakeholders who could 
have benefited from using it: 

•  Consumers  who  would  like  to  have  clear  guidance  on  which  products  are  more 
environmentally friendly hardly find the EU Ecolabel on products. In many countries, they 
will also not find any other third-party label available. 

•  Companies wanting to use the Ecolabel as a benchmark for product development can only 

do so for a limited number of product groups. 

•  Those companies wanting to use the label as a credible marketing tool for promoting their 
green  products  are  restricted  to  the  same  small  number  of  product  groups  and  have  little 
added  value  from  the  label  due  to  the  fact  that  it  is  only  known  to  about  10  %  of  the 
European population. 

•  Public purchasers are also affected. They are looking for simple criteria which they can put 
into  their  calls  for  tender,  but  either  the  Ecolabel  criteria  do  not  exist  or  they  are  over-
complicated.  Instead  there  are  very  different  rules  and  guidelines,  in  different  stages  of 
development in different Member States. 

•  Policy  makers,  wishing  to  find  understandable  life-cycle  information  on  products  and 
looking  to  find  out  what  the  key  environmental  impacts  are  for  linking  to  other  policies 
(for  example  for  setting  mandatory  minimum  criteria  under  the  Energy-Using  Products 
directive) often have to start from the beginning because they cannot use the Ecolabel as a 
source of such information. 

How would the problem evolve, all things being equal? 

Basically, the above mentioned problems would persist and be aggravated. There would be no 
coherent  EU-wide  policy  setting  environmental  benchmarks  for  products.  The  different 
Member States would continue to develop their own very different labelling and green public 
procurement systems and this would mean additional confusion for consumers and additional 
bureaucracy for companies. In the end it would lead to less progress in terms of sustainable 
production and consumption that would, in turn, mean less economic growth. See also, Policy 
Option: "Leave the scheme as it is". 

Does  the  EU  have  the  right  to  act  -  Treaty  base,  "necessity  test"  (subsidiarity)  and 
fundamental rights limits? 

Yes. Most of the issues described in this section are fundamental problems that lie within the 
Ecolabel Regulation itself. To tackle these problems requires changes to the Regulation that 
cannot  be  dealt  with  by  Member  States  themselves.  Indeed,  the  right  to  act  is  already 
mentioned  in  Article  20  of  the  current  Regulation,  where  it  states:  "the  Commission  shall 
review  the  Scheme  in  light  of  the  experience  gained  during  it  operation…and  propose  any 
appropriate amendments to this Regulation". 

EN 

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SECTION 4: OBJECTIVES 

The overall objectives of the revision of the scheme are: 

1. 

2. 

3. 

To  encourage  the  sustainable  production  and  consumption  of  products,  and  the 
sustainable  provision  and  use  of  services,  by  setting  benchmarks  for  good 
environmental  performance.  By  guiding  consumers  towards  them,  the  Ecolabel 
should  promote  those  products  and  services  that  have  met  these  benchmarks 
compared to others in the same category. 

The revised Ecolabel scheme needs to be designed in a way to ensure that is usable 
as  an  integral  and  effective  part  of  the  wider  Sustainable  Consumption  and 
Production  policy  framework  of  the  European  Commission.  The  new  Regulation 
needs  flexibility  to  link  easily  with  other  instruments,  such  as  GPP,  EMAS,  Eco-
design, ETAP, etc. 

A  much  more  influential  Ecolabel  in  terms  of  supporting  other  SCP  policies  and 
setting  benchmarks  for  good  environmental  performance  for  policy  makers,  for 
companies or for educating the public. 

Operational objectives are: 

•  High  awareness,  understanding  and  respect  in  the  EU-27  and  around  the  world.  The 
medium-term  benchmark  for  success  should  be  that  the  Ecolabel  is  recognised  by 
consumers and by companies throughout the EU at a similar level to the recognition of the 
Blue Angel or Nordic Swan in their respective countries of operation. 

Indicators:  %  of  population  that  know  the  Ecolabel  and  its  meaning  within  ten  years  
% of companies that know the Ecolabel within ten years 

•  Building up trust in the label and maintaining its credibility is also vital. The label must be 

a highly respected benchmark of environmental performance. 

Indicator: Level of credibility when compared with other environmental labels 

•  Criteria are needed for all products and services where the Ecolabel can provide benefits, 
especially product groups with a substantial environmental impact and therefore with high 
potential for improvement. 

Indicators: Number of product groups; number of companies per product group; number of 
items sold per product group; sales volume per product group. 

•  Many more Ecolabel products on the shelves for consumers to choose from; 

Indicator: Ecolabel sales as a percentage of total retail sales in this product group. 

•  Criteria documents which can easily be used by public purchasers and policy makers. 

Indicator: Use and uptake of Ecolabel criteria by public purchasers monitored by questioning 
Member States, also hits on GPP website and on Ecolabel criteria documents. 

Indicator:  Number  of  policies  that  can  be  attributed  to  having  used  the  Ecolabel  product 
information work. 

•  An Ecolabel very well harmonised with other labels, globally and nationally. 

Indicator: Frequency of national labelling schemes directly taking on the Ecolabel criteria. 

EN 

18 

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•  An  Ecolabel  that  can  be  attained  by  companies  with  limited  costs  and  efforts  for  them 
while  still  maintaining  a  high  ambition  in  order  to  ensure  credibility  of  the  label  with 
consumers and environmental groups. 

Indicator: Number of licences 

Consistency of objectives with other EU policies 
The  Commission's  Communication  on  Integrated  Product  Policy19  analysed  the  need  for  a 
product dimension to environmental policy and acknowledges the role the EU Ecolabel has to 
play in a mix of product related instruments. 
One  of  the  overall  objectives  of  the  Sustainable  Development  Strategy  (SDS)20  is  the 
promotion  of  sustainable  consumption  and  production  patterns.  Being  an  important  tool  for 
improving  the  environmental  performance  for  products  and  processes  and  for  encouraging 
their  uptake  by  business  and  consumers,  a  well-designed  Ecolabel  scheme  is  directly 
contributing  to  this  SDS  objective.  The  aim  of  better  serving  the  needs  of  green  public 
procurement (GPP) will also contribute to reaching the relevant SDS objective. 

The  Ecolabel  provides  a  means  by  which  market  forces  can  reward  products  and  services 
which meet consumer demand in less environmentally damaging ways. This will typically be 
through  innovation  either  in  product  design  or  in  the  production  process.  The  Ecolabel 
therefore promotes and supports innovation, whilst at the same time increasing the efficiency 
of  resource  use  in  the  economy,  both  of  which  are  key  goals  of  the  "Lisbon"  Strategy  for 
Growth and Jobs. The majority of firms taking up ecolabels are typically SMEs, which shows 
the  potential  of  the  Ecolabel  to  support  SME  development  provided  that  the  issues  of 
implementation of the scheme by SMEs are addressed. Thus a strong and efficient Ecolabel 
would boost EU industrial policy.  

Furthermore, the life-cycle approach followed for the development of Ecolabel award criteria 
ensures  that  due  account  is  taken  of  the  impact  of  certain  a  product  or  service  on  themes 
which are high up on the political agenda, such as climate. At the same time, this approach 
avoids  that  concentration  on  just  one  environmental  theme  leads  to  solutions  which  would 
have a high impact on other environmental themes. 

The  objective  of  better  integrating  the  Ecolabel  with  other  environmental  product  policy 
instruments also contributes to "better regulation". 

19 
20 

(IPP) (COM (2003) 302 final) 
SDS reference to be included 

EN 

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SECTION 5: POLICY OPTIONS  

Possible options for meeting the objectives and tackling the problem. 

(Note:  The  following  options  have  been  broken down  to  two  levels:  macro-options,  such  as 
keeping, dropping or modifying the Ecolabel scheme are presented, and then micro-options, 
where  considerations  of  individual  areas  of  change  to  the  current  scheme  are  presented. 
These  micro-options  are  relevant  if  the  macro-option  of  "modifying  the  current  scheme"  is 
chosen  –  in  this  case  some  the  micro-options  may  be  accepted  or  rejected  to  make  up  a 
package of measures for the modification of the scheme. 

Macro-option 1 – Continue with the present approach = Business as usual 

Changes required: 

None – the current Regulation would remain in force and work would continue as now. 

Macro-option 2 – Phase-out the scheme 

Changes required: 

– 

– 

– 

– 

– 

Stop Commission funding for development of new product groups and marketing. 

Let the current criteria documents expire. 

Slow down and eventually stop having Ecolabel meetings. 

Stop taking on new Ecolabel customers. 

Finally, withdraw the Regulation. 

Macro-option 3 – Modify the scheme 

Changes required: 

A  number  of  micro-options  are  available  for  modifying  the  scheme  in  different  areas  of  its 
operation.  Modifications  range  from  the  administrative  to  the  political,  looking  at  how  the 
scheme  is  run  and  how  decisions  are  made,  as  well  as  considering  modifying  how  the 
Ecolabel  criteria  are  used  in  relation  to  other  ecolabelling  schemes  and  in  relation  to  other 
environmental tools. These micro-options are derived from a wide consultation exercise with 
all  stakeholders,  from  the  evaluation  study  (EVER),  and  from  the  attempt  to  respond  to  the 
problems  with  the  current  Ecolabel  scheme.  The  impacts  of  these  micro-options  need  to  be 
considered both individually and in synergy with each other. If macro-option 3 is chosen, then 
the best package of measures suitable for achieving the objectives of the Ecolabel would need 
to be selected. 

The following table gives an overview of the relationships between the micro-options and the 
problems  presented  in  section  3.  (For  the  sake  of  simplicity,  only  the  main  links  are 
highlighted  even  if  some  micro-options  are  linked  to  various  problems.  In  order  to  further 
readability,  at  each  heading  of  the  detailed  description  of  the  mirco-options  there  is  a 
reference to the problems presented in section 3.) 

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Micro-options 

Problems 

Introduce 
fiscal 
Ecolabelled products and services. 

incentives 

for 

the

Especially  low  uptake  by  industry  but  also 
problems  in  using  Ecolabel  in  green  public 
purchasing activity. 

Open up the scope of the label. 

Regulation too restrictive 

measures 

Introduce 
to 
harmonisation  with  other 
schemes. 

encourage 
eco-labelling 

Insufficient  co-operation  and  harmonisation 
with  other  eco-label  schemes  at  national  and 
regional level. 

Introduce  a  new  standard  for  making  green 
claims in Europe. 

More direct stakeholder involvement. 

More  product  groups;  quicker  criteria 
development; 
decision  making 
better 
procedures; better criteria documents. 

Insufficient  co-operation  and  harmonisation 
with  other  eco-label  schemes  at  national  and 
regional level. 

The  Ecolabel  faces  strong  competition  from 
green self-claims. 

Insufficient 
stakeholder 
decision making on product group criteria. 

involvement 

in 

stakeholder 

involvement 

in 
Insufficient 
decision  making  on  product  group  criteria; 
procedural and organisational problems – i.e. 
excessive  bureaucracy; 
low  number  of 
product group categories. 

Incorporate  guidance 
purchasing into criteria development. 

for  green  public 

Problems  in  using  Ecolabel  in  green  public 
purchasing activity. 

Change  of  rules  for  public  procurement  to 
favour products or services meeting Ecolabel 
criteria. 

Problems  in  using  Ecolabel  in  green  public 
purchasing activity. 

Simplification of the fee structure. 

Fees and cost of getting the label. 

Abolish third-party verification. 

Procedural and organisational problems. 

Accredit  bodies  outside  the  EU  to  deal  with 
Ecolabel applications. 

Procedural and organisational problems. 

Boost marketing. 

Lack of funding for marketing. 

Peer reviews for Competent Bodies. 

regards 
Lack  of 
implementation of the Regulation in MS. 

transparency  with 

to 

Provision  of  information  by  the  EUEB  on 
appropriate  future  minimum  environmental 
standards for products 

Often  no  reasons  for  manufacturers 
to 
improve  the  environmental  performance  of 
their products 

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Micro-options: 

micro-option i. 

Introduce fiscal incentives for the Ecolabelled products and services: 

(See Section 3.2 –"main problems identified with the current scheme") 

This  option  would  see  a  system  put  in  place  to  allow  the  possibility  for  Value  Added  Tax 
breaks to be introduced at the EU level for products bearing the Ecolabel, or that meet some 
or all of the criteria. These savings could boost the profits of participating companies either 
through increased sales of lower priced goods or by allowing them to add a premium to the 
price of the product without this being reflected "on the shelves" when compared with other 
products. 

micro-option ii. 

Open up the scope of the label 

(See Section 3.2.a) 

All  food  products  and  medical  devices  are  currently  excluded  from  the  scope  of  the  EU 
Ecolabel. This option will remove the restrictions on scope within the Ecolabel allowing for 
any product which can meet the aims of the label to have the potential to be labelled. 

micro-option iii. 

Introduce measures to encourage harmonisation with other eco-labelling schemes 

(See Section 3.2.b) 

There  are  a  number  of  other  ISO  type  I  (third-party-verified)  labelling  schemes  in  different 
Member  States  running  schemes  similar  to  the  EU  Ecolabel,  but  criteria  and  their 
development,  application  procedures  and  fees  are  not  harmonised.  This  option  sees  various 
possible sub-measures: 

a) 

EU Ecolabel criteria as a standard for other ecolabels: 

Specified Ecolabel criteria, agreed by Commission Decision, will have to be adopted by other 
schemes within a certain time if those schemes wish to cover the product group in question 
combined with a rule that if a national scheme wishes to develop a new product group that is 
already covered by the Ecolabel, they must take on the Ecolabel criteria. 

b) 

Accreditation of national/regional ISO type 1 schemes to use the Flower: 

By Commission Decision, other European ISO type 1 eco-label schemes can be "accredited", 
if that scheme can demonstrate fully its ability to meet the aims of the Ecolabel scheme. An 
accredited scheme then has the right to offer, to companies under its scheme, the use of the 
EU Flower logo, for any of its product groups not covered by the EU scheme at the time. For 
example,  if  the  Nordic  Swan  scheme  were  to  be  accredited,  then  any  companies  currently 
bearing the Swan logo for any product group not covered by the EU Ecolabel, could use the 
Ecolabel Flower logo for their marketing. 

c) 

Eventually ban national labels from operating when Ecolabel criteria exist 

At a fixed time after the adoption of Ecolabel criteria national labels would have to withdraw 
their  product  groups  altogether,  allowing  the  EU  Ecolabel  to  be the  only  label  available  for 
the product groups it covers. 

d) 

Fast track procedure to adopt criteria developed by national/regional ISO type schemes 

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In  order  to  increase  the  number  of  product  groups  for  the  EU  Ecolabel,  a  shortened  criteria 
development  process  for  criteria  that  have  already  been  developed  by  another  ISO  type  1 
labelling scheme can be established. 

micro-option iv. 

Introduce a new standard for making green claims in Europe 

(See Section 3.2.b+c) 

Companies wishing to write "bio" or "organic" on food in the EU must meet EU standards to 
do  so.  No  such  standard  exists  for  green  claims  like  "environmentally  friendly"  and  "eco". 
The new Ecolabel Regulation will use selected "core" Ecolabel criteria as a basis for setting 
minimum standards for general environmental claims on products. Commission Decision will 
determine the most relevant criteria per product group, that will then have to be met in order 
for a product to be allowed to make green claims about itself. Member States will be required 
to  ensure,  through  market  surveillance,  that  companies  making  general  green  claims  are  in 
line  with  these  criteria,  in  the  same  way  that  they  must  prevent  the  use  of  any  other  false 
claims on products. 

micro-option v. 

More direct stakeholders involvement 

(See Section 3.2.d) 

This option will see the final decision making on criteria pass from Regulatory Committee to 
a stakeholder body comprising balanced composition ensuring all the interests are represented 
in an appropriate way. 

micro-option vi. 

More product groups / quicker criteria development / better decision making procedures / 
better criteria documents 

(See Section 3.2.d+e+f) 

This  option  will  introduce  the  possibility  for  criteria  development  to  be  managed  by  any 
interested  stakeholder,  (eg.  industry  or  NGO  as  well  as  Member  States)  under  specified 
conditions  ensuring  full  open  consultation  and  appropriate  life-cycle  considerations.  The 
option will allow for the adoption of criteria from other schemes, if they can be shown to have 
been well developed. 

Specific  guidelines  for  criteria  development  will  be  included  in  the  Ecolabel  Regulation. 
These guidelines are a practical manual setting out each procedural step required to develop 
criteria (e.g. who is to be consulted and when, how the different actors and bodies have to be 
informed  and  when),  as  well  as  the  contents  of  the  background  report  and  the  final  criteria 
document.  Any  new  product  group  criteria  submitted  to  the  stakeholder  body  for  a  vote  is, 
therefore,  accompanied  by  a  standardised  report  showing  how  each  of  the  steps  had  been 
completed,  answering  specific  questions  and  indicating  how  the  criteria  were  derived. 
Sections shall include: 

– 

– 

21 

Reasoning for choice of product group / scope of product group21, 

Standardised market analysis;  

The Commissions Integrated Product Policy work on "Identifying products with the greatest potential 
for  environmental 
selection  product  groups: 
http://ec.europa.eu/environment/ipp/identifying.htm 

improvement"  can  give  guidance 

the 

for 

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23 

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– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

– 

Consideration of any possible trade issues; 

Analysis of criteria of other labels; 

Setting of ambition levels; 

Life-cycle  considerations  (including  results  of  consultation  with  EU  Platform  of 
Life- Cycle information); 

First draft criteria – reasoning/justification for each criteria; 

Expected environmental/economic/social impacts per criteria; 

Assessment and verification specifications; 

Estimated costs of tests; 

Table: who was consulted, what they said, why their input was accepted / rejected; 

Final criteria; 

User manual. 

This option will also introduce a standard template for criteria documents. The template will 
ensure that the presentation of Ecolabel criteria is standardised across product groups and that 
criteria are broken down into clear impact categories that are easy to understand for the first 
time reader. 

micro-option vii. 

Incorporate guidance for Green Public Purchasing into criteria development 

(See Section 3.2.g) 

The new Regulation will include new guidelines ensuring criteria documents contain specific 
simple "cut and paste" guidance and advice for public procurement officers and that key "best 
GPP criteria" are highlighted in Ecolabel criteria documents. 

micro-option viii. 

Change  of  rules  for  public  procurement  to  favour  products  or  services  meeting  Ecolabel 
criteria 

(See Section 3.2.g) 

This option sees the introduction of new EU-wide rules within the Ecolabel Regulation that 
state  that  when  public  procurement  tenders  are  made,  those  responding  who  meet  Ecolabel 
criteria should be favoured, all other factors being equal. 

micro-option ix. 

Simplification of the fee structure 

(See Section 3.2.h) 

The fee for using the Ecolabel is currently a percentage of sales of the eco-labelled product. 

Two sub-options are considered: 

a) 

A simplification of the fee structure. Under this option, only one fixed annual fee 
would  be  required  per  Ecolabel  licence,  unlike  the  current  system  where  the  fee  is 
linked to the volume of sales of the eco-labelled product. Three fees would exist: one 
considerably  reduced  fee  for  micro  enterprises,  one  reduced  fee  for  SMEs  and  one 
for all other companies. 

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24 

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b) 

No annual fees are charged at all. Companies will be able to use the Ecolabel for 
free, apart from the need for a small, limited application fee. 

micro-option x. 

Abolish third-party verification 

(See Section 3.2.e) 

This option would be a move towards self-declarations for the EU Ecolabel. Once criteria are 
set,  any  company  that  meets  those  criteria  will  be  able  to  use  the  logo  with  no  application 
process required. The Competent Bodies in Member States would then carry out spot checks 
on products and companies to ensure that the rules are being adhered to. 

micro-option xi. 

Accredit bodies outside the EU to deal with Ecolabel applications 

(See Section 3.2.e) 

Companies  from  outside  the  EU  can  already  apply  for  the  label,  but  must  do  so  via  a  EU 
Member  State  and  the  process  is  expensive  and  long.  This  option  would  allow,  under  strict 
conditions, for governmental bodies outside the EU to be authorised to deal with applications 
for the Ecolabel. 

micro-option xii. 

Boost Marketing 

(See Section 3.2.i) 

This option would see a big marketing push for the EU Ecolabel in the short-term to increase 
public  and  industry  awareness  of  the  scheme  to  levels  comparable  with  the  most  successful 
national schemes. The marketing push would be timed in line with the revision of the scheme 
if  other  micro-options  are  chosen.  The  initial  financial  input  would  be  in  the  order  of  €5 
million per year for five years for professional promoting of the Ecolabel brand. During this 
time  periodic  assessment  of  the  knowledge  of  the  label  would  be  made.  At  the  end  of  the 
period a re-assessment of the need for direct marketing input would be made. This marketing 
push will be combined with the development of the new or modified logo, designed to be self-
explanatory and to thus avoid confusion with other schemes. 

micro-option xiii. 

Peer review for Member States 

(See Section 3.2.j) 

In order to make the way the scheme is implemented in Member States more transparent, they 
should  carry  out  mutual  peer  review  visits  and  produce  follow-up  reports  and 
recommendations for any changes that could help with the harmonised implementation of the 
scheme. This system would be comparable to the current peer review amongst accreditation 
bodies under the EMAS Regulation. Representatives from two or three Member States would 
visit  another  in  order  to  get  an  understanding  of  the  way  applications  by  companies  are 
assessed and compliance is monitored by them. Results would be discussed at Member State 
meetings. 

micro-option xiv. 

Provision  of  information  by  the  EUEB  on  appropriate  future  minimum  environmental 
standards for products 

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(See Section 3.2.k) 

When  considering  Eco-label  criteria,  the  EUEB  gathers  considerable  information  about 
products' environmental performance and market trends. Under this option, the EUEB would 
also  use  that  information  to  provide  recommendations  on  future  mandatory  minimum 
environmental performance requirements, in the same format as core Ecolabel criteria. They 
would also provide a recommendation on the timetable to which these minimum requirements 
should be implemented. These recommendations would be public and the Commission would 
consider  these  recommendations  and  make  proposals  for  their  implementation  within  the 
framework of an appropriate existing legal instrument. 

EN 

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SECTION 6: ANALYSIS OF IMPACTS  

The Ecolabel will tend to produce two effects where used for any product group: 

an  increase  in  sales  of  products  that  have  better  environmental  performance  (as  a 

a) 
proportion of sales of that product group); and 

b) 
provide an incentive to some firms  to innovate in their product design or production 
processes, so that they can gain the Ecolabel award in future for their product, together with 
the economic benefits that this may bring. 

The  first  of  these  effects  leads  directly  to  environmental  benefit.  The  second,  through 
promoting innovation and dynamic improvement of resource use, brings both economic and 
environmental  benefits.  The  extent  of  both  effects  will  depend  on  the  number  of  products 
using the Ecolabel and the success of the Ecolabel in increasing either the sales or the price 
premium of the products it is awarded to. 

The  extent  of  these  effects  is  impossible  to  judge  from  the  Ecolabel  policy  itself  –  the 
Ecolabel is only one of several EU policies that provides incentives for the uptake and design 
of  environmentally  better  products.  Many  Member  States  also  have  national  policies  which 
promote greener products, whilst private policies, for example by large retailers or purchasers, 
will also have a great effect on the success of the Ecolabel. 

The  forthcoming  Commission's  Sustainable  Consumption  and  Production  Action  Plan  will 
examine  how  a  range  of  product  policy  instruments  can  work  together  to  more  effectively 
provide dynamic incentives for eco-innovation in products and to increase the sales of better 
environmentally performing products. This Action Plan will look at how arrangements can be 
put in place to apply the optimum mix of policy instruments to particular product groups – to 
maximise the complementarity of the instruments as a whole. Just as a hypothetical example, 
to  provide  incentives  for  development  of  better  environmentally  performing  [shampoos], 
policy  instruments  from  Ecolabel,  Green  Public  Procurement,  a  "top  runner"/performance 
standard  and  fiscal  incentives,  might  all  work  together  effectively.  The  Ecolabel  and  the 
information about product performance and future sales generated to inform development of 
Ecolabel criteria could be a crucial part of that product package, but it would be difficult to 
attribute the environmental and economic impacts that resulted to the Ecolabel alone. 

The costs of the Ecolabel scheme will also be dependent on the extent of its use and the co-
ordination of the scheme's activities with other policy instruments. Enforcement activities in 
Member States, for example, to check the market for unauthorised eco-labels, are likely to be 
less  expensive  if  co-ordinated  with  other  market  surveillance  activities.  The  costs  of  the 
administrative  activity,  including  information  gathering,  to  set  the  criteria  for  the  Ecolabel 
might also be shared with co-ordinated information and decision making in relation to the use 
of other product related policy instruments. 

Bearing  this  in  mind,  and  taking  into  account  the  need  for  proportionality  in  assessing  the 
impacts of a voluntary instrument, this impact assessment will look mainly at the impacts of 
options  on  the  potential  of  the  Ecolabel,  rather  than  try  to  estimate  certain  effects.  For 
instance,  a  policy  option  that  reduces  administrative  procedures  may  be  certain  to  make 
application for the Ecolabel more appealing – and therefore will increase the potential of the 
Ecolabel to perform effectively. This impact assessment examines that effect on potential, but 
does not try to  quantify the possible resulting  economic,  social  or environmental  effects for 
individual options. 

However, it is possible to provide information that gives a perspective of the potential benefits 
of the Ecolabel scheme as a whole, in various situations: 

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27 

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Potential Direct Environmental Benefits 
A  study  commissioned  by  DG  Environment22  calculated  the  potential  direct  benefits  that 
could  be  expected  if  the  current  product  groups  had  a  market  take-up  of  5%,  20%  or  50% 
respectively.  The  amount  saved  was  calculated  as  difference  between  the  environmental 
performance of an eco-label product and that of an average product on the market times the 
number of products sold in each scenario: 

Resource saved /avoided per year 

AMOUNT SAVED PER YEAR BY SCENARIO 
% 

5% Take-up 

20% Take-up 

50% Take-up 

Electricity, GWh 

14,700 

59,000 

147,600 

CO2 produced from energy use, tonnes 

9,318,000 

37,270,000

93,175,000 

Water Use23, Megalitres  

12,285,000 

49,138,000 

122,846,000 

Reduced  Hazardous  Substance  Use, 
tonnes 

Material Savings (other than Hazardous 
Substances), tonnes 

Reduced  discharges  to  water,  tonnes 
COD  

13,800 

55,400 

138,400 

530,700 

2,122,700 

5,306,700 

30,400 

121,700 

304,200 

Reduced Air Pollution, tonnes  

17,500 

70,100 

175,300 

Source: AEAT, "Final Report", November 2004, Report produced for DG Environment 

Starting from the fact that criteria are set at levels that promote the labelling of products that 
have  a  low  environmental  impact  and  that  the  aim  of  the  Ecolabel  is  to  encourage 
improvements  in  the  environmental  performance  of  products  during  the  whole  life-cycle  of 
the product it is assumed in the study that companies choosing to sign up to the Ecolabel may 
have  to  make  some  adjustments  to  their  production  behaviour,  resulting  in  environmental 
benefits in terms of restrictions on certain polluting chemicals, improvements in recyclability, 
introduction of waste management systems, limits on chemical emissions, etc. 

22 

23 

AEAT, "The Direct and Indirect Benefits of the European Ecolabel – Final Report", November 2004, A 
Final Report produced for DG Environment. It should be noted that this study was not peer reviewed. 
Water Use includes savings due to more efficient appliances and savings due to the reduced CDV value 
of ecolabelled detergents. 

EN 

28 

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Ecolabelled 
Product 
Footprint 

Standard 

Product 

Footprint 

Environmental  Improvement  attributable
to the 
ecolabelled product, (delta) 

Source AEAT, "The Direct and Indirect Benefits of the European Ecolabel – Final Report", 
November 2004, A Final Report produced for DG Environment 

Potential Indirect Benefits (Environmental and Economic) 

On top of these direct environmental benefits the Direct and Indirect Benefits study, based on 
consultation with EUEB members, identified nine indirect impacts from the Ecolabel, looked 
at  known  instances,  success  stories  and  calculated  their  potential  impact  which  could  be 
expected by taking measures which would lead to replication of these examples24. 

1. 

2. 

3. 

4. 

5. 

24 

The use of the Ecolabel criteria by another eco-label scheme. Criteria may be copied 
directly or used as a reference point before local adaptation. 

The use of the Ecolabel criteria in public procurement calls for tender. 

The use of the Ecolabel criteria in private procurement calls for tender. 

The use of the Ecolabel criteria by companies as a benchmark for their own products 
or as a target to improve their environmental performance. 

The  use  of  the  Ecolabel  criteria  to  generate  Type  III  labels  (environmental  product 
declarations), or recommendations on how to make green claims (Type II). 

For more detailed explanations of the assumption and methodology we have to refer to the study itself: 
http://ec.europa.eu/environment/ecolabel/pdf/market_study/benefitsfinalreport_1104.pdf  

EN 

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6. 

7. 

8. 

9. 

The  use  of  the  Ecolabel  criteria  and  procedures/structures  to  generate  minimum 
environmental  requirements  applicable  to  all  products  of  a  product  category  on  the 
market. 

The  use  of  the  Ecolabel  criteria  in  the  “new  approach”  as  a  basis  for  establishing 
whether companies have complied with “essential requirements”. 

The  use  of  the  Ecolabel  logo,  Ecolabel  criteria  and  related  discussion,  to  raise 
stakeholder  awareness  of  the  environmental  impact  of  products,  with  stakeholders 
including  manufacturers  retailers,  consumers,  environmental  NGOs  and  public 
administrations. 

The use of the Ecolabel and its criteria as a basis for establishing fiscal measures to 
promote green products, (e.g. criteria for energy rebate schemes) 

Indirect Environmental Benefits of the Ecolabel within the EU25 

Item 

Money  

Energy saved  

CO2 saved 

Water saved25 

Amount saved per year 

€763 million 

43 TWh 

27 million tonnes 

35 Tera litres 

Hazardous substances avoided 

39 thousand tonnes 

Materials saved 

1.5 million tonnes 

Reduced discharges to water 

85 thousand tonnes COD26 

Reduced air pollution 

49 thousand tonnes 

25 

26 

Water  Use  includes  savings  due  to  more  efficient  appliances  and  the  reduced  CDV  of  ecolabelled 
detergents. 
Chemical Oxygen Demand 

EN 

30 

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Indirect Environmental Benefits of the Ecolabel Outside the EU2527 

Item  

Energy saved 

CO2 saved 

Water saved 

Amount Saved per Year 

2.9 TWh 

1.9 million tonnes 

2.5 Tera litres 

Hazardous substances avoided 

2.8 thousand tonnes 

Materials saved 

106 thousand tonnes 

Reduced discharges to water 

6 thousand tonnes COD28 

Reduced air pollution 

3.5 thousand tonnes 

Economic Benefits 

The indirect benefits above indicate some of the economic benefits that should result from a 
successful Ecolabel scheme – improvements in resource use, reductions in economic damage 
and  reductions  in  damage  to  health  (and  therefore  productivity  and  treatment  costs)  from 
pollution. 

However, the greatest economic benefits are likely to come from the promotion of innovation 
in  both  process  design  and  production  techniques.  Such  innovation  is  very  likely  to  reduce 
both  resource  use  in  production  and  increase  efficiency  –  and  therefore  provide  both  direct 
and  indirect  benefits  to  the  EU  economy  as  successful  technologies  grow  in  niche  markets, 
then  spread  more  widely.  All  of  this  would  increase  international  competitiveness,  both  of 
individual  firms  and  the  EU  economy  as  a  whole.  The  Ecolabel  is  often  used  by  SMEs  to 
develop  their  market  share  –  one  of  the  important  breeding  grounds  for  entrepreneurial 
activity  and  innovation  that  is  particularly  important  to  encourage.  The  benefits  that  may 
result  from  a  successful  Ecolabel  are  hard  to  quantify,  either  beforehand,  or  afterwards,  but 
would be nevertheless real. 

Innovation  is  likely  where  market  demand  will  reward  that  innovation,  through  greater 
economic  returns  for  the  innovator.  Most  simply,  where  there  is  consumer  demand  for  a 
product that is "greener" than the others, there is a market there for greener products. It can be 
seen as a differentiated product market. For producers to get, or retain a share of that product 
market, they will need to innovate - because the Ecolabel criteria will be revised over time to 
ensure  that  only  the  best  products  are  awarded  eco-labels.  But  if  consumers  cannot  be  sure 
which the greener products are - if they have no reliable information on that, the demand that 
creates  that  differentiated  market  will  not  arise  and  there  will  be  no  benefits  from  the  eco-
innovation. 

27 

28 

Considers the EU Ecolabel to influence the national schemes of Australia, Canada, New Zealand and 
the United States. 
Chemical Oxygen Demand 

EN 

31 

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One  good  example  of  how  the  Ecolabel  can  drive  innovation  is  that  of  the  MicroPro 
Computer29  To  quote 
introduces  an 
environmentally-friendly  PC,  called  Iameco,  which  is  developed  as  a  zero-waste  personal 
computer.  The  company  is  striving  to  become  the  only  PC  maker  in  the  world  to  earn  the 
European  Union's  prestigious  Ecolabel  mark,  for  high-quality  consumer  products  that  meet 
the highest environmental standards". 

their  own  marketing:  "MicroPro  Computers 

There are also many examples of innovators seeking to use the Ecolabel as a reward for their 
innovation. One good example of this in practice is that of Boston Power batteries, who have 
just  been  awarded  the  Nordic  Swan  eco-label30.  The  Swan  was  able  to  rapidly  provide  a 
reward  for  the  company's  innovative  product.  The  company  website  says,  in  relation  to  the 
award: "It is an achievement that is well-deserved and also a testimony to their commitment 
to combine technical  knowledge  with environmental quality standards". It is  by  this type of 
link that the eco-labels can also help drive innovation. 

By working with the market, the Ecolabel is designed to be used where it offers net economic 
benefits  to  enterprises  –  and  it  stands  or  falls  on  that  criterion:  if  the  scheme  is  not 
economically beneficial to a particular enterprise, it will not be taken up. Maximising the total 
economic  benefit  from  the  scheme  is  therefore  one  of  its  goals,  and  one  of  the  goals  of  its 
revision. 

As a whole, the Ecolabel is one of the instruments aimed at achieving the goals of the revised 
Strategy for Jobs and Growth (Lisbon Strategy). The Ecolabel policy contributes to 6 of the 
10 Mirco-economic guidelines of the Integrated Guidelines.31 

(7) 

(8) 

To increase and improve investment in R&D, in particular by private business; 

To facilitate all forms of innovation; 

(10)  To strengthen the competitive advantages of its industrial base; 

(11)  To  encourage  the  sustainable  use  of  resources  and  strengthen  the  synergies  between 
environmental protection and growth; 

(14)  To  create  a  more  competitive  business  environment  and  encourage  private  initiative 
through better regulation; 

(15)  To  promote  a  more  entrepreneurial  culture  and  create  a  supportive  environment  for 
SMEs. 

Administrative Costs 

The  Ecolabel  scheme  requires  some  procedures  to  work  effectively  and  these  inevitably 
involve some administrative activity by both enterprises applying for, or using eco-labels, and 
for the Commission, national authorities and the organisations involved in decision making on 
Ecolabel criteria. 

For any enterprise applying to the scheme, the administrative costs of the application must be 
smaller than the economic benefit that enterprise expects to receive from applying for an eco-
label.  The  lower  these  administrative  costs  are,  the  more  attractive  the  scheme  becomes  for 
potential applications and the greater its success is likely to be. 

29 
30 
31 

http://greentechnolog.com/2006/11/zero_waste_computing.html 
http://www.boston-power.com/ 
Integrated Guidelines for Growth and Jobs (2005-2008) , European Commission, 2005 

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32 

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Whilst it is not possible, for the reasons stated above to quantify the total administrative costs 
associated  with  the  voluntary  scheme,  it  is  possible  to  look  at  the  impact  of  options  on  the 
administrative costs of individual procedures. 

Social impacts 

Given  that  criteria  also  include  aspects  related  to  human  health,  this  can  be  considered  as  a 
positive social impact, but apart from this, no other relevant social impacts are expected. The 
positive  impact  on  health  is  underlined  by  a  BEUC  (Bureau  Européen  des  Unions  de 
Consommateurs) study which concludes : "The Ecolabel was originally conceived to reward 
products  having  a  reduced  environmental  impact.  Studying  what  the  Ecolabel  criteria  say 
about the content of hazardous chemicals in the final products allows an additional important 
dimension to be included: health."32  

Assessment of the Impacts of Options 

The better the Ecolabel scheme is designed and implemented the higher the probability that 
these potential benefits become real and that the policy objectives described in section 4 are 
achieved. Keeping this in mind, the aim of the following assessment of the different options is 
to identify the impacts of different macro and micro options on the potential of the Ecolabel 
scheme.  

32 

See: http://ec.europa.eu/environment/ecolabel/pdf/studies/beucstudy2004_en.pdf 

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Macro-option 1 – Continue with the present approach. i.e. Business as usual 

The analysis of the impact of this option can be made by analysing the impact of the current 
scheme. Fundamentally, if no action is taken then the scheme can be expected to continue to 
operate as it has done up until now. It would continue to grow steadily but very modestly with 
some small environmental economic and social benefits, but with a number of barriers to its 
development. 
The EVER study33 outlines the main plus and minus points about the current scheme, that can 
be summarised as follows: 

On the one hand: 

•  Low awareness; 

•  Insufficient product group categories; 

•  Low up-take by industry; 

•  Procedural and organisational problems – i.e. bureaucracy; 

•  Costs for participating companies; 

•  Lack of perceived public purchasing benefits. 

On the other hand: 

•  Around three quarters of users think that the EU Ecolabel has contributed to setting targets 

for the improvement of product environmental performance; 

•  A  large  majority  also  say  that  the  Ecolabel  influenced  the  demand  on  their  suppliers 

concerning the environmental performance; 

•  Almost  all  of  the  companies  participating  in  the  EU  scheme  use  the  Ecolabel  in  their 

marketing campaigns; 

•  More  than  half  of  the  non-Ecolabel  participants  declare  they  use  the  Ecolabel  criteria  as 

benchmarks to for the environmental performance of their products; 

•  Neither users nor non-users of the Ecolabel want to see the label abolished; 

•  National labels are not preferred over the EU Ecolabel. 

Continuing  with  business  as  usual  would  mean  that  the  positive  effects  in  environmental, 
economic and social terms would remain. 

The EVER project questioned actual participants of the EU Flower as to their opinion of the 
label’s  influence  on  environmental  performance  and  found  that:  "  Nearly  2/3  of  the 
participants indicated that the objective to improve environmental performance was very or 
fairly  important  for  their  application  for  the  Flower.  (…)About  every  second  interviewee 
indicated that the Flower had some effect on the environmental performance of the product in 
the areas of air and water emissions, waster/recycling and water/material use; improvements 
with regard to accidents/spills were rare and for noise/smell observed by ¼ of interviewees".  

In  addition,  there  is  anecdotal  evidence  from  the  practice  of  Ecolabel  implementation  that 
companies – maybe not all – actually have to do some effort in improving the environmental 

33 

For more details see EVER study see: http://ec.europa.eu/environment/ecolabel/revision_en.htm 

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performance of their products or services. A statement from Hilton Hotel Malta can serve as 
an example: “The accomplishment of this task is by no means an easy exercise. It is, in fact, 
time consuming but certainly an interesting, interactive learning experience. To start with, we 
set a target date, and used a textbook approach to deal with the criteria. It is the continued 
implementation  and  refinement  that  is  most  challenging  for  the  company.  Investing  in  such 
ongoing actions creates short-term costs in setting up the systems but is rewarded with long–
term benefits".34 

Apart from improving the product or service itself, there is a second aspect which has to be 
considered  in  this  respect:  the  increased  sales  of  eco-labelled  products.  According  to  the 
EVER study, 53% of the interviewed companies experienced an increase in the market share 
or in the number of new customers thanks to the adoption of the EU Ecolabel35. 

However,  with  such  a  low  uptake  overall  of  the  scheme  such  environmental  benefits  are 
limited mainly because of the persistence of the problems described in section 3: consumers 
would  largely  remain  unaware  of  the  label,  business  interest  in  the  label  would  will  remain 
limited,  the  number  of  product  groups  would  grow  at  a  very  slow  pace,  if  at  all,  criteria 
documents often could not be revised in due time, development of new or revision of existing 
product groups would continue to take too long (some 3 to 4 years) wasting scarce resources 
of  all  the  parties  involved,  the  fee  would  remain  complicated  and  inflexible,  stakeholders 
would not feel to have real ownership of the scheme, purchasing officers would continue to 
show little interest in the label, the Ecolabel could not be considered for food products, etc. 

In  terms  of  the  objectives  of  success  outlined  in  Section  4,  we  might  therefore  expect  the 
following results by 2017 if we extrapolate from the last ten years: 

•  10-20 % of population that know the Ecolabel and its meaning within ten years. 

•  10-20 % of companies that know the Ecolabel within ten years. 

•  Reasonably rated in terms of credibility when compared with other environmental labels. 

•  30 product groups; 600 participating companies; €1.5 annua l sales volume of Ecolabelled 

goods. 

•  Ecolabel little used by public purchasers monitored. 

•  Few, if any, policies that can be attributed to having used the Ecolabel product information 

work. 

•  Limited number of Ecolabel criteria adopted by other labelling schemes. 

Macro-option 2 – Gradually phase out the scheme 

Phasing  out  the  scheme  could  lead  to  some  benefits  but  would  mean  losing  the  positive 
impacts analysed for the current scheme – see above – and the potential for further developing 
these  benefits.  The  EVER  study  highlights  the  main  motivations  for  shutting  down  the 
scheme as the lack of success of the current scheme and the fact that Member States already 
have their own national schemes. Phasing out the Ecolabel scheme would free up resources 
associated with the Ecolabel for use on other initiatives. 

At the same time the EVER study points out the potential impacts of the shutting down the 
scheme as a lost opportunity to improve it and to gain the potential benefits that it has to offer. 

34 
35 

Source: Flower News, July 2006: http://ec.europa.eu/environment/ecolabel/news/index_en.htm 
http://ec.europa.eu/environment/ecolabel/revision_en.htm : Report 2, p. 118 

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The study looks at the views of the industry, both participating in, and not participating in, the 
Ecolabel scheme, and their views as to the Ecolabel versus national labels36 – the study states: 
"when asked, over 70% of the interviewed stakeholders do not recommend a national rather 
than a European label. While some believe more in an EU Ecolabel in the long run, others 
see  them  as  supplementary".  Overall,  the  study  concludes:  "(…)  harmonisation  is  seen  as 
being the only effective solution to be pursued. There is very little support for the options of 
abolishing either the EU Eco-label or the national labels". 

Importantly, no Member States have expressed a desire to abolish the Ecolabel, but rather to 
improve  the  scheme,  which  suffers  from  some  very  obvious  problems.  In  those  Member 
States where there is no national scheme the potential of the EU Ecolabel is seen as important 
because,  without  it,  they  would  have  no  similar  third-party  labelling  scheme.  The  UK  for 
example  considers  the  existence  of  the  EU  Ecolabel  scheme  the  reason  that  they  have  not 
developed their own scheme. If the EU Ecolabel were phased out, it seems likely, therefore, 
that  in  time  national  labelling  schemes  would  evolve  in  most  Member  States.  What  is  clear 
from  looking  at  the  different  national  schemes  currently  in  place  is  that  the  schemes  in  the 
different  Member  States  would  be  very  different.  So  for  companies  marketing  their  "green" 
products  throughout  the  single  market  they  would  need  to  meet  the  different  criteria  and 
different  assessment  and  verification  procedures  for  all  schemes.  It  is  for  this  reason  that 
companies  who  support  the  idea  of  ISO  type  I  labelling  schemes,  support  the  idea  of 
harmonised EU criteria. 

The  only  cases  of  harmonised  criteria  so  far  are  those  cases  where  national  schemes  have 
voluntarily  taken  on  Ecolabel  criteria  word  for  word  –  some  examples  being  those  of  the 
Austrian  Ecolabel  which  has  taken  on  criteria  for  light  bulbs  and  cleaner  or  that37  of  the 
Nordic  Swan  which  has  taken  on  the  EU  criteria  for  Indoor  Paints  and  Varnishes  in  their 
entirety38. They then offer applicants a discount: 

"Since  the  criteria  are  identical  to  the  EU  ecolabelling  criteria,  a  producer  may,  if  he  so 
wishes, apply concurrently for both Swan and EU-Flower ecolabels and thus gain permission 
to use both labels." 

"Applications for both the Swan and EU Flower ecolabels for a single product are entitled to 
a discount. Please contact Nordic Ecolabelling in your country for further information." 

The potential to develop these types of synergies between national labelling schemes and give 
and level playing field for companies operating in Member States with and without national 
schemes would be lost if the Ecolabel were to be phased out. It is therefore one of the most 
important  features  of  the  EU  Ecolabel  in  comparison  to  other  labels  that  it  is  EU-wide.  It 
offers  companies  the  opportunity  to  have  one  single  label  for  all  of  the  Internal  Market, 
instead  of  having  to  apply  in  a  number  of  different  countries  for  different  labels  (with 
different procedures, different criteria, different logos, etc.). 

Equally, for consumers it is much easier in an Internal Market to be able to rely on one major 
label which is used everywhere. Moreover, there is the potential for considerable cost savings 
if one scheme is used instead of every country having to develop its own scheme. 

On top  of this, those  companies which have  already invested  in the Ecolabel would  not get 
any further benefit and would have to consider their investments as wasted to a large extent. 
There  are  also  a  number  of  product  group  specific  eco-labels  developed  by  industry 

36 
37 
38 

http://ec.europa.eu/environment/ecolabel/revision_en.htm - see report on research findings, p.100-104  
http://www.umweltzeichen.at/filemanager/list/15672/ 
http://www.svanen.nu/DocEng/096e.pdf 

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associations  or  groups  of  NGOs.  These  schemes vary  widely,  ranging  from  labels  based  on 
environmental  management  systems  (for  example  the  A.I.S.E.  Sustainable  Cleaning 
Scheme39)  to  single  issue  specific  labels  (like  the  Forest  Stewardship  Council  label40).  A 
balanced participation of different interest groups – crucial for the credibility of a scheme – 
seems to be difficult to guarantee without clear external rules. No other label currently serves 
the same purpose as the EU Ecolabel which aims to set the benchmarks across product groups 
and  throughout  the  life-cycle  of  those  products  across  the  EU.  Phasing  out  of  the  scheme 
would mean the potential benchmarking tool, setting out "what makes a good scheme" would 
be  lost.  It  is  likely  that,  due  to  increasing  consumer  demand  for  information,  many  more 
product  group  specific  labels  would  be  developed,  often  Member  State  by  Member  State. 
Consumer confusion at the basis for the different labels would increase. 

The  EU  Ecolabel  is  intended  to  add  value,  not  add  "another  label"  –  the  potential  of  the 
scheme  will  help  achieve  this,  with  better  measures  on  harmonisation  and  more  industry 
involvement. This is explored in the next Macro-option. 

Macro-option 3 – Modify the scheme 

A  number  of  micro-options  are  presented  in  Section  5,  each  of  which  may  have  its  own 
environmental,  economic  and  social  impacts.  The  impacts  of  each  of  these  micro-options  is 
considered in turn and then the overall impact of selecting the best package of modifications 
is considered for the purposes of going on to choose the best macro options in Section 7. 

Impacts of the micro-options: 

micro-option i. 

Introduce fiscal incentives for the eco-labelled products and services: 

Pros: Tax breaks (e.g. a reduced VAT rate) would enable producers to lower prices for eco-
labelled  products,  or  to  increase  their  profit  margins  with  the  price  kept  constant,  or  for 
retailers to apply a larger mark-up whilst keeping the price constant – which is likely to lead 
them to take steps to increase sales, which would offset the costs involved in getting the label 
(cost for adjustments of the product, for testing, for fees, etc.). Through such a comparative 
advantage,  the  Ecolabel  would  become  more  attractive  to  companies  which  would  lead  to 
more licence holders and labelled products on the market. 

Cons: The increased economic  advantage  from the tax  break  attaching  to the award of eco-
labels could also lead to much more difficult negotiations in the criteria development process. 
Intensified lobbying is to be expected which will slow the process and eventually could cause 
deadlocks  in  negotiations.  The  idea  of  a  tax  break  for  eco-labelled  products  was  already 
discussed  in  the  framework  of  the  Commission's  Communication  on  Integrated  Product 
Policy41 in 2003 where most Member States were not in favour. 

Option accepted/rejected: Rejected. Although enjoying such an impressive support amongst 
respondents to the internet consultation as well amongst interviewees in the EVER study (in 
the internet consultation, more than 67 % were in favour of fiscal measures and 76 % of the 
interviewees  in  the  EVER  study  considered  it  fairly  or  very  important),  fiscal  measures  are 
considered  beyond  the  scope  of  the  Ecolabel  Regulation  at  this  time.  Nevertheless,  the 
Regulation  could  encourage  Member  States  to  consider  fiscal  incentives  at  MS  level  where 

39 
40 
41 

http://www.sustainable-cleaning.com/ 
http://www.fsc.org/en/ 
Communication from the Commission to the Council and the European Parliament, COM (2003) 302 
final 

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appropriate and foresee collection and dissemination of best practice examples in this field. In 
cases  where  tax  differentials  are  granted  on  the  basis  of  environmental  considerations  this 
should be clearly communicated to the consumer. Fiscal incentives at Community level will 
be considered in the wider policy framework of the SCP Action Plan.  

micro-option ii. 

Open up the scope of the label 

Pros: This will allow developing criteria for product groups with the greatest environmental 
impact  (according  to  the  EIPRO  study)  such  as  food  where  "carbon  labelling"  schemes  for 
food products are now being developed by large retailers and other organisations but there is 
no  mechanism  in  place  to  offer  any  form  of  EU  standardisation.  Opening  the  scope  would 
allow  identifying  the  areas  with  the  greatest  environmental  foot  print  and  setting  criteria  in 
line with the aims of the scheme.  

Cons: None 

Option  accepted/rejected:  Accepted.  Making  good  decisions  on  which  product  groups  to 
develop  ecolabels  can  be  built  into  the  Regulation  without  having  to  specifically  rule  out 
certain groups directly in the Regulation   

micro-option iii. 

Introduce measures to encourage harmonisation with other ecolabelling schemes: 

(a) EU Ecolabel criteria as a standard for other ecolabels; 

(b) Accreditation of national/regional ISO type 1 schemes to use the Flower; 

(c) Eventually ban national labels from operating when Ecolabel criteria exist; 

(d) Fast track procedure to adopt criteria developed by national/regional ISO type schemes. 

Pros: The Ecolabel will set the standard for environmental product criteria in the EU, while at 
the same time giving companies a wider choice of product groups for which they could use 
the EU Ecolabel. With one procedure they can get the EU label and a national label if they 
wish  to  do  so  –  without  any  additional  cost.  They  can  use  the  national  label  where  this  is 
better known than the EU label (home market) and the EU label for exports to markets where 
the national label is not known. 

Cons:  Competition  between  labels  can  encourage  them  to  increase  their  environmental 
stringency to prove they are "the best", which can help keep standards high – this may be lost 
if the one label becomes the only label setting the standards on the market. 

Option accepted/rejected: (a + d) accepted, (b + c) rejected. These measures will be better 
for businesses, who can use the EU Ecolabel for EU marketing and better for consumers, who 
will  find  more  Ecolabel  products  on  the  shelves.  The  "fast  track"  adoption  of  criteria  from 
other schemes will allow other schemes to operate at the national level, while at the same time 
increasing the number of product groups for the EU label. 

Banning  other  ecolabelling  schemes  is  likely  to  reduce  the  total  benefits  from  eco-labelling 
schemes  in  Europe.  National  labelling  schemes  have,  in  some  cases,  been  much  more 
successful than the Ecolabel scheme, as they meet the specific needs of the Member States in 
which  they  operate.  Accreditation  of  national  schemes  as  a  whole  to  use  the  Flower  would 
involve  assessing  the  overall  credibility  of  these  schemes,  an  exercise  which  is  likely  to  be 
much more complex and politically sensitive than allowing a fast track adoption of individual 
criteria documents developed by other schemes. 

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The  accepted  options  were  the  most  strongly  supported  by  respondents  to  the  internet 
consultation. On the rejected options serious concerns were raised by representatives of some 
national labelling schemes. 

micro-option iv. 

Introduce a new standard for making green claims in Europe 

Pros: Consumers will be able to rely on green claims made on products. There will be a level 
playing field for industry, preventing misleading green claims and offering a clear benchmark 
for good environmental performance of products. This may avoid unwarranted green claims 
for products, which would damage the market for greener products as a whole. 

Cons: The standard will only be available for product groups for which core criteria have been 
adopted.  This  measure  could  discourage  some  companies,  not  wishing  to  see  a  standard  for 
green  claims  from  taking  part.  (Although  the  opposite  may  also  be  true  in  some  cases,  as 
companies want to be involved in the process to give their voice to the resulting criteria.) 

Option  accepted/rejected:  Rejected.  While  this  option  is  strongly  supported  by  internet 
consultation  respondents  and  would  ensure  that  green  claims  be  made  based  on  sound  and 
stringent environmental criteria which would help the Ecolabel reach its aim of providing the 
benchmark for the environmental performance of products, and would encourage companies 
already  meeting  the  core  criteria  to  improve  further  their  performance  to  apply  for  the 
Ecolabel,  it  is  considered  beyond  the  scope  of  the  Ecolabel  Regulation  as  it  would 
considerably change the voluntary nature of this instrument. It is suggested that the issue of 
green  claims  be  considered  in  the  wider  framework  of  sustainable  consumption  and 
production. 

micro-option v. 

More direct stakeholder involvement 

Pros: An option is strongly supported in the internet consultation that would see stakeholders 
better involved and perhaps more committed to the scheme. The process of decision making 
will be shortened compared to the current system by up to two years. The system will be able 
to adapt to change and the Ecolabel 'brand' will be able to operate in a more business-like way 
leading  to  increased  interest  in  the  scheme,  more  licences  and  bigger  environmental  and 
economic impacts. 

Cons:  The  challenge  will  be  to  find  a  well  balanced  composition  of  the  stakeholder  body. 
Additionally there is a risk that some Member States, with reduced direct power over Ecolabel 
criteria decisions, will lose interest in the scheme and will decrease the resources allocated to 
it. Furthermore, if the revised Ecolabel does not share the same decision making procedures 
as  other  SCP  policies  under  Ecodesign,  i.e.  Commission  Decision,  it  will  be  make 
harmonisation of criteria and test methods for different policies more difficult.  

Option accepted/rejected: Rejected. Bureaucracy is a problem for the Ecolabel and must be 
tackled but moving away from Commission Decision, while it might help the 'branding' of the 
label,  would  essentially  take  away  the  'EU'  aspect  of  the  label,  which  is  a  major  part  of  its 
unique  appeal  and  usefulness.  The  label  needs  to  be  integrated  with  other  policies,  and 
keeping Commission Decision, which is the same decision making procedure for Ecodesign, 
will  allow  this  to  happen  more  smoothly.  Stakeholder  involvement  should  be  enhanced  by 
ensuring  that  the  criteria  development  process  openly  and  transparently  takes  into  account 
their  views,  and  that  transparency  is  given  as  to  why  any  input  made  has  been  accepted  or 
rejected  during  the  process.  At  the  same  time  bureaucracy  surrounding  the  criteria 
development  process  should  be  focused  on,  along  with  other  aspects  of  the  way  the  label 

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operates, such as for assessment and verification procedures. These issues then are dealt with 
in other micro-options.  

micro-option vi. 

More product groups / quicker criteria development- 

Pros: The scheme will be much more efficient and flexible, therefore allowing to adapt easily 
to changing needs and to adopt changes to criteria which become necessary as a result of the 
experience  in  implementing  them  in  practice.  Synergies  with  other  instruments  as  well  as 
relevant  work  carried  out  elsewhere  can  be  used.  Improved  criteria  documents  following  a 
common structure will be easier to understand and implement for companies. Consumers and 
policy makers will also find criteria documents easier to digest, thus allowing the Ecolabel to 
better act as an education and information tool. 

Cons: Developing more product groups may bear the risk that some stakeholders or Member 
States  will  not  have  the  resources  to  follow  criteria  development  for  every  product  group, 
unless they increase their resources. 

Option accepted/rejected: Accepted. Linked to the previous micro-option, this option is about 
using  common  sense  to  ensure  the  scheme  is  run  efficiently  and  to  allow  interested 
stakeholders to help with the development of criteria. Quality control of criteria would need to 
be enshrined in the develop guidelines for them. This option was very strongly supported in 
the internet consultation. 

micro-option vii. 

Incorporate guidance for Green Public Purchasing into criteria development 

Pros:  The  Ecolabel  scheme  will  deliver  harmonised  environmental  criteria  for  public 
purchasing which can easily be introduced into technical specifications. The Ecolabel will be 
a  reliable  instrument  for  checking  a  product  against  specifications.  Environmental  benefits 
could  be  high  as  companies  move  to  meet  the  basic  GPP  criteria.  Again,  this  was  strongly 
supported by respondents to the internet consultation. 

Cons: None. 

Option accepted/rejected: Accepted. This should have been incorporated since the beginning 
of the operation of the Ecolabel scheme. 

micro-option viii. 

Change of rules for public procurement to favour the EU Ecolabel 

Pros:  Making  it  mandatory  to  include  Ecolabel  criteria  into  calls  for  tender  or  simply  to 
request  Ecolabelled  products  would  give  a  strong  boost  to  the  Ecolabel  and  would  reward 
companies with environmentally improved products. The number of Ecolabel licences could 
be  expected  to  increase  strongly,  as  would  the  associated  environmental  benefits  as  the 
incentive for going for the Ecolabel would be significantly increased. 

Cons: As with tax breaks, this strong incentive changes, to an extent, the nature of the scheme 
as "voluntary" and the idea of moving away from "command and control" type legislation. 

Option  accepted/rejected:  Rejected.  The  EVER  study  found  that  green  procurement  (both 
public and private) has been judged as crucial for stimulating eco-labelling performance and 
more than 61 % of the respondents to the internet consultation agreed or strongly agreed that 
it  should  be  mandatory  for  Member  States  to  use  Ecolabel  criteria  (or  equivalent)  where 
possible in calls for tenders. While it is clear that this revision of the Ecolabel Regulation has 
to ensure that the Ecolabel scheme is attractive for public purchasers and that Ecolabel criteria 

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are as easy to use for this purpose as possible, a change of the public procurement legislation 
is  beyond  the  scope  of  the  Ecolabel  Regulation.  The  issue  of  how  to  foster  green  public 
procurement  is  currently  being  addressed  by  the  Commission  in  the  framework  of  the 
preparation of a communication on green public procurement. 

micro-option ix. 

Simplification of the fee structure 

Sub-option a: Simplified fee structure. 

Sub-option b: No fees. 

Pros: According to the EVER study, cost is seen as the highest barrier for potential applicants. 
Therefore, an increase in applications can be expected. Sub-option b – no fees – would also 
mean reduced bureaucracy as no calculation and administration of fees are necessary. 

This sort of financial incentive for the using the Ecolabel is much easier to administer than a 
reduced VAT rate or any other kind fiscal incentive. 

Cons: This would mean a loss of income for competent bodies. 

Option accepted/rejected: Sub-option b accepted. No annual fee for the Ecolabel will send a 
clear  message  that  companies  meeting  the  Ecolabel  criteria  will  benefit  from  doing  so  and 
will not be penalised. It will be of biggest benefit to SMEs who find the fee as a significant 
barrier and will effectively offer a financial incentive for using the Ecolabel. A small fee, to 
deal with the direct costs of dealing with applications, will be maintained.  

micro-option x. 

Abolish third-party verification 

Pros: Companies would be able to use the Ecolabel immediately after the publication of the 
criteria  with  no  upfront  paperwork  or  bureaucracy  required.  Administrative  costs  would  be 
lower and uptake of the label would increase. This option would also mean that the Ecolabel 
verification system would be the same as for the Energy label and the planned Eco-design for 
Energy Using products directive. 

Cons: Companies would have to prepare the same documentation in order to prove that their 
products  meet  the  criteria  and  they  would  have  to  respond  to  spot  checks  by  Competent 
Bodies at any moment. Nevertheless, many say that the credibility of the scheme depends on a 
third-party verification and giving up this crucial element would mean losing support for the 
scheme by consumer and environmental groups.  

Option  accepted/rejected:  Partly  Accepted.  A  radical  simplification  of  the  assessment  and 
verification  of  the  scheme  is  proposed  which  would  move  away  from  full  third-party 
verification, but would maintain the requirement to sign an agreement with a competent body, 
declaring  accordance  with  the  criteria.  (As  is,  in  fact,  the  case  for  a  majority  of  individual 
Ecolabel  criteria  already.)  This  revised  system  will  be  linked  to  ensuring  that  the  criteria 
themselves are simpler, more focused, and easier in terms of on the spot verification. 

micro-option xi. 

Accredit bodies outside the EU to deal with Ecolabel applications 

Pros: Companies located outside the EU will have easier access to the Ecolabel which may be 
particularly  interesting  for  services  such  as  tourist  accommodation  or  campsites.  This  may 
lead  to  an  increase  in  numbers  of  licences  and  a  better  dissemination  of  the  scheme  at  the 
global level. The Ecolabel, already covering more countries than any other similar label, will 
become global. 

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Cons: Meticulous assessment of the suitability and reliability of external accreditation bodies 
will  be  required  to  ensure  the  credibility  of  the  Ecolabel  is  maintained  –  this  will  be  time 
consuming  and,  although  some  of  the  costs  will  have  to  be  met  by  the  body  wishing  to  be 
accredited, it will still mean the use of administrative resources by the Commission. 

Option accepted/rejected: Rejected. Ensuring credibility appears to be too resource intensive. 
Instead  of  fully  accrediting  bodies  outside  the  EU,  it  is  suggested  that  Member  States' 
Competent Bodies can cooperate with bodies outside the EU in order to facilitate applications 
from third countries. 

Micro-option xii. 

Boost marketing  

Pros: A considerably increased marketing budget would allow for professional promotion of 
the Ecolabel, thus increasing knowledge of it and what it stands for. In combination with the 
other measures described above the label will become more attractive for companies, which 
will  lead  to  more  Ecolabelled  products  on  the  market,  which,  in  turn,  will  lead  to  a  higher 
demand from consumers due to the increased knowledge. The more money that is invested, 
the  higher  the  value  of  the  brand  for  companies  will  become,  as  consumer  knowledge 
increases  –  this  will  in  turn  lead  to  more  applications  and  greater  environmental  benefits 
coming from the scheme. 

Cons:  Marketing  investment  is  a  risk.  If  the  scheme  is  not  successful,  then  the  money  will 
have been wasted. 

Option  accepted/rejected:  Accepted.  Without  marketing  investment  the  scheme  will  never 
take off. The key will be to monitor the indicators of success to ensure that any investment is 
achieving the required results. If it is not then the money should be withdrawn. 

micro-option xiii. 

Peer review for Member States 

Pros:  The  way  the  Regulation  is  implemented  in  MS,  especially  concerning  assessment  of 
applications and monitoring of compliance, would become more transparent and harmonised 
in order to ensure a level playing field for companies across the EU. 

Cons:  The  system  will  require  periodic  missions  between  Member  States  to  review  the 
operations of others and this will require resources. 

Option accepted/rejected: Accepted. Ensuring a level playing field is in the overall interest of 
the  Internal  Market  and  of  the  credibility  of  the  scheme.  The  micro-option  will  also  allow 
different  member  States  to  share  best  practices,  learning  from  each  other  to  improve  their 
operations – this will mean the scheme is better implemented and run overall. 

micro-option xiv. 

Provision  of  information  by  the  EUEB  on  appropriate  future  minimum  environmental 
standards for products  

Pros: 

•  This  key  impact  of  this  option  is  the  provision  of  additional  information  by  the  EUEB  – 

which provides the potential and stimulus for better policy outcomes. 

•  The  benefit  of  the  information  provided  by  the  EUEB  is  likely  to  be  high  as  the  criteria 
development  process  for  the  EU  Ecolabel  follows  clear  guidelines  including  rules  on 

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stakeholder  involvement  and  transparency.  The  expertise  of  the  ecolabel  community  and 
the studies carried out for the Ecolabel could be used for other policy instruments.  

•  The  provision  of  recommendations  for  minimum  standards  which  are  consistent  with 
Ecolabel is efficient as it makes use of existing work and avoids a confusion of standards 
for stakeholders – particularly manufacturers. 

•  By publicly providing indications of future standards in advance – and through discussions 
of  those  in  the  EUEB  stakeholder  process  –  manufacturers  have  a  clear  indication  of 
potential future requirements, giving both clarity and incentives to facilitate improvements 
in the environmental performance of their poorly performing products.  

•  This would lead to both reductions in environmental harm and reduced unfair competition 
for  Eco-label  products,  which  should  provide  greater  incentives  for  innovation  to  further 
reduce the impacts of products. 

•  The  decision  making  process  triggered  by  the  Eco-label  process  should  ensure  that 
standards are only in cases (or at levels, or to timescales) which lead to environmental gain 
that outweighs costs from changing product performance. 

Cons:  

•  The  extent  of  any  benefit  coming  from  this  measure  depends  to  a  large  extent  on  the 
resulting  policy  decision.  Minimum  standards  may  end  up  being  set  which  do  not 
significantly change manufacturers performance and therefore do not tackle the problem – 
which  would  continue  to  hinder  improvements  in  the  environmental  performance  of 
products, including those with Eco-labels. 

•  Through this approach development of mandatory performance standards would be limited 

to product groups for which Ecolabel criteria have been developed.  

Option  accepted/rejected:  Accepted.  The  option  should  allow  greater  effectiveness  of  the 
Eco-label at improving product performance, with a mechanism that should ensure action is 
taken only when beneficial. 

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SECTION 7: COMPARISON OF OPTIONS  

It is clear  from  Section 6 that macro-option 3 "Modify  the scheme" is  the only approach to 
ensure  that  the  objectives  from  Section  4  can  be  achieved.  For  the  sake  of  readability  the 
micro-options under macro-option 3 have been accepted or rejected in Section 6. In summary, 
the following package of measures is proposed: 

Accepted: 

•  Design  Regulation  to  better  fit  into  the  other  sustainable  production  and  consumption 

actions of the Commission; 

•  Open up the scope of the label; 

•  Introduce  measures  to  encourage  harmonisation  with  other  eco-labelling  schemes:  EU 
Ecolabel  criteria  as  a  standard  for  other  eco-labels,  fast  track  procedure  to  adopt  criteria 
developed by national/regional ISO type schemes; 

•  More  product  groups  /  quicker  criteria  development  /  Introduce  a  template  for  criteria 

documents to ensure they are more user friendly; 

•  Incorporate guidance for Green Public Purchasing into criteria development; 

•  Abolition of annual fees; 

•  Simplification of assessment and verification; 

•  Boost Marketing; 

•  Peer review for Competent Bodies; 

•  Make recommendations for mandatory environmental performance standards for products. 

Rejected: 

•  Introduce a new standard for making green claims in Europe; 

•  Change of rules for public procurement to favour the EU Ecolabel; 

•  Introduce  measures  to  encourage  harmonisation  with  other  ecolabelling  schemes: 
accreditation  of  national/regional  ISO  type  1  schemes  to  use  the  Flower;  eventually  ban 
national labels from operating when Ecolabel criteria exist;  

•  Introduce fiscal incentives for the ecolabelled products and services; 

•  Accredit bodies outside the EU to deal with Ecolabel Applications. 

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SECTION 8: ADMINISTRATIVE COSTS 

As  explained  in  Section  6,  it  is  not  possible  to  quantify  the  total  administrative  costs, 
including costs to public authorities of administering the scheme, because we are dealing with 
a voluntary instrument where costs to a large extent depend on the uptake by industry and the 
associated costs of market surveillance of the conformity of those using the label. 

It  is  also  possible  to  look  at  the  impact  of  the  selected  micro-options  on  the  administrative 
costs  of  individual  procedures.  It  also  needs  to  be  emphasised  that  according  to  the  strict 
Commission definition of administrative costs, the Ecolabel Regulation does not impose any 
administrative costs on companies because it is a voluntary scheme where companies are free 
or not to participate. 

Design Regulation to better fit into the other sustainable production and consumption actions 
of  the  Commission  will  mean  that  synergies  between  different  product  related  policy 
instruments  can  be  enhanced  and  therefore  mean  that  there  is  a  harmonisation  of  the 
framework  in  which  criteria  are  presented.  This  will  reduce  the  administrative  burden  on 
companies. Consider for example if we have mandatory minimum criteria (under the Energy 
using Products directive) for televisions and at the same time Ecolabel criteria for televisions. 
If  the  criteria  are  harmonised  between  the  two  policies  it  will  mean  fewer  assessment  and 
verification  requirements  for  a  company  wishing  to  comply  with  both  schemes.  So 
compliance with the requirements of the different instruments is made simpler for companies, 
therefore reducing the overall costs for them. The detailed costs per company of applying for 
the Ecolabel cannot be precisely specified as product groups vary significantly, as does how 
much  additional  work  a  given  company  has  to  undertake  to  meet  the  criteria.  However,  in 
very  general  terms  the  costs  of  tests  associated  with  applying  for  the  Ecolabel  might  range 
from  around  €1,000  -  €10,000.  To  calculate  what  th e  savings  might  be  from  having  better 
synergies  with  other  environmental  policies,  we  need  to  look  at  the  overlap  of  criteria  that 
these policies can have with the Ecolabel. For example, the Energy Using Products directive 
will  specify  between  one  and  three  criteria  on  the  environmental  performance  of  products, 
focusing on energy use, whereas the Ecolabel might look at five to ten criteria covering the 
life-cycle of the product in more detail. If at least the three EUP criteria, and their associated 
assessment and verification basis, are harmonised with the matching criteria in the Ecolabel 
then any testing requirements can be harmonised – thus reducing administrative burden. The 
same could be true for recommended best Green Public Purchasing requirements. Considering 
these likely overlaps in criteria might range from 20-30% savings from better synergies of the 
criteria might be expected to be similar. 

Introducing  measures  to  encourage  harmonisation  with  other  ecolabelling  schemes:  For 
companies  wishing  to  apply  for  more  than  one  ecolabel,  harmonising  measures  can  only 
reduce  their  administrative  burden.  Costs  of  tests  could  be  reduced  by  100%  if  one  label  is 
already held as no additional testing or verification would be required. This reduced financial 
burden may be particularly interesting for small and medium sized enterprises.  

More  product  groups  /  quicker  criteria  development:  Simplified  procedure  for  criteria 
development  would  reduce  costs  for  all  parties  involved  (less  meetings  to  attend)  but 
development of more product groups clearly has an associated cost. From the AEAT study an 
estimate for criteria development is as follows: 

•  Two people working full-time for 2.5 months each on developing criteria, i.e. 2 x 50 man-

days = 100 man-days (this effort may be spread over 18 months or so). 

•  Three AHWGs, each a day long, attended by 25 people on average, thus 75 man-days. 

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•  Therefore 175 man-days in total, or approximately half a man-year. 

•  It has been estimated that this half man-year equates to €25,000 on average to develop an 
eco-label  for  a  product  group  from  start  to  completion  (excludes  overheads,  travel,  and 
subsistence costs that may add 100% to this figure). 

•  Calculations for known examples of where EU criteria have been adopted or used as the 
basis  for  national  eco-labels  have  then  been  performed  by  multiplying  the  number  of 
product  groups  used  by  a  national  scheme  by  the  €25,000  saving,  similarly  for  the  time 
saving. 

•  For  the  technical  potential  the  calculation  was  performed  on  the  number  of  national 
labelling schemes in operation within the EU, assuming each one on average will use the 
Ecolabel criteria for one product group.42 

This estimate of €25,000 per product group is rou ghly in line with the budget the Commission 
currently  provides  for  Ecolabel  criteria  development,  although  it  should  be  noted  that  costs 
vary hugely depending on the scale, complexity and scope of the product group in question. 
The  work  that  has  previously  been  done  in  that  sector  and  the  availability  of  data  will  also 
change the costs of development. (The Life Cycle Analysis budget for Energy Using Products 
for  domestic  lighting,  for  example,  is  around  €300,000).  One  of  the  aspects  of  the  option 
"modify the scheme" will be allowing work that has already been done by others to be used 
more easily by the Ecolabel – for example by Member States' national labels, by the Global 
Ecolabelling Network or in the context of other Commission work such as that of the Energy 
Using Products Directive or new Sustainable Consumption and Production Action Plan. This 
will save time and money because developing Ecolabel criteria in isolation will be avoided. 

This  impact  assessment  cannot  state  exactly  which  product  groups  will  be  chosen  for 
development  over  the  coming  years,  however,  it  will  be  specified  that  priority  for  Ecolabel 
criteria  development  would  be  for  those  product  groups  with  the  highest  environmental 
impact. A basis of this could be the EIPRO study, which highlights some sixty product groups 
as  accounting  for  the  vast  majority  of  environmental  production  and  consumption  impacts. 
The  overall  cost  of  development  will  depend  on:  exactly  how  many  product  groups  are 
developed  each  year;  the  nature  of  each  product  group  in  question;  what  other  work  has 
already taken place and what on-going work is underway elsewhere. The more money that is 
allocated by the Commission and Member States, the more product groups can be developed. 
Currently  the  Commission  spends  around  €150,000  per  year  on  criteria  development  and 
revision, which gives one or two new product groups per year, and revisions for another two 
or  three.  With  more  efficient  development  and  revision  processes,  and  by  revising  the 
Regulation  to  allow  for  better  co-operation  with  other  instruments,  this  number  could  be 
doubled  at  no  extra  cost,  although  over  time,  with  more  product  groups,  the  administrative 
costs  may  increase.  (One  desk  officer  would  be  required  for  each  additional  ten  product 
groups.) 

Introduce  a  template  for  criteria  documents  to  ensure  they  are  more  user-friendly:  Making 
criteria  documents  standardised  and  more  user-friendly  will  mean  reduced  administrative 
burden for companies and purchasing bodies using criteria for technical specifications. 

Incorporate  guidance  for  Green  Public  Purchasing  into  criteria  development:  As  already 
indicated  in  the  previous  point,  procurement  officers  will  have  easier  access  to  EU-wide 
harmonised criteria and companies will have a level playing field if the same criteria are used 
across Europe in technical specifications for contracts. Member States will also save money 

42 

http://ec.europa.eu/environment/ecolabel/pdf/market_study/benefitsfinalreport_1104.pdf: page 54 

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because the same criteria can be used for eco-labelling and public purchasing (see above "fit 
into the upcoming SCP Action Plan"). 

Abolition of annual fees: The current direct income for competent bodies from fees is around 
€1million per year in EU 27. This direct income  will be lost if fees are abolished, however the 
administrative  burden  will  be  reduced  for  companies.  The  administrative  savings  could  be 
around half a man-day per year for a company per year, along with the benefit of not having 
to pay an annual fee. For Member States, the administrative burden of operating the scheme 
will  remain  the  same  as  the  work  required  to  undertake  assessment  and  verification  in  the 
current  scheme  will  be  equal  to  the  work  required  to  administer  and  undertake  market 
surveillance  under  the  new  proposals.  Simpler  criteria  should,  however,  help  to  reduce  the 
administration required. 

Peer review for Member States: Depending on the number of reviews per year (3 to 4) and 
assuming  4  to  5  working  days  for  the  team  per  visit,  with  3  team  members  and  one  person 
from the reviewed Member State this measure would mean on average approx. 3 or 4 working 
days per Member State per year. This work should be offset by better, harmonised working 
practices that result that will reduce the need for interventions to correct poor implementation 
of the scheme by the Commission at a later date. 

Boosting marketing: In this impact assessment a figure of up to €5 million per year for five 
years  for  professional  promoting  of  the  Ecolabel  brand  is  proposed.  For  companies  a 
marketing campaign of this magnitude paid for by the Commission and Member States would 
increase the value of the Ecolabel brand and help to improve  sales  of eco-labelled  products 
and might reduce the need for them to conduct their own marketing campaigns. Overall more 
companies would mean higher income from fees, so in the long term spending on a campaign 
could be recouped. To what extent would depend on the uptake of the label. 

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SECTION 9: MONITORING AND EVALUATION 

Several measures will allow the monitoring and implementation of the scheme and to evaluate 
the success of the Ecolabel Regulation: 

•  The  Commission  will  continue  using  the  Eurobarometer  surveys  to  get  data  on  public 

awareness of and trust in the Ecolabel. 

•  The  service  contract  for  the  collection  of  statistical  information  on  Green  Public 
Procurement  which  is  currently  being  prepared  by  the  Commission  includes  reference  to 
EU-wide Ecolabel criteria. This work will provide input on the use and uptake of Ecolabel 
criteria by public purchasers. 

•  The  annual  statistics  exercise  will  continue  as  before:  Competent  Bodies  are  asked  to 
provide information on the volume of sales of Eco-labelled products, the number of Eco-
labelled  products,  the  fees  received  from  licence  holders  and  the  resources  (staff  and 
money) dedicated to the scheme. 

•  On  a  continuous  basis,  the  Competent  Bodies  will  report  any  new  licences  to  the 
Commission,  which  will  continue  to  publish  them  on  the  internet  in  the  so-called  green 
store (www.eco-label.com). 

•  The  regular  meetings  with  Member  States  and  stakeholders  will  also  continue  to  be  a 

source of information on the implementation of the scheme. 

•  The  proposed  new  peer  review  mechanism  described  in  micro-option  xv  ,  aimed  at 
ensuring  and  monitoring  a  harmonised  implementation  of  the  Ecolabel  Regulation  will 
make the way the different Member States deal with issues of how licence holders are dealt 
with more transparent. 

Furthermore, the draft proposal will contain a review clause along the lines of the one in the 
existing Regulation: 

"Within  five  years  after  its  entry  into  force,  the  Commission  will  review  the  scheme  in  the 
light  of  the  experience  gained  during  its  operation.  The  Commission  shall  propose  any 
appropriate amendments to this Regulation." 

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SECTION 10: CONCLUSION 

The Ecolabel scheme has potential, particularly as part of a coherent package of measures, but 
is over-bureaucratic and isolated from other policies. Rather than giving up on it, it should be 
overhauled  and  given  another  chance.  It  is  very  important,  however,  to  continue  to  monitor 
the progress of the Ecolabel against those objectives. 

This  impact  assessment  builds  on  experience  from  operation  of  the  Ecolabel  scheme  and 
extensive  consultation  with  parties  involved  in  the  Ecolabel  scheme,  including  users.  It 
follows  a  detailed  external  evaluation  of  the  scheme  –  the  EVER  study  –  and  uses  the 
evidence  produced  by  that  study.  As  a  result  of  the  analysis,  we  recommend  a  number  of 
separate changes to the operation of the Ecolabel scheme that can be put into effect through 
changes to the Ecolabel Regulation. These changes will lead to an increase in the potential of 
the scheme to effectively achieve its objectives. 

It can be expected that this modification and simplification of the scheme will lead, on the one 
hand to a considerable increase in companies using the label, therefore also to an increase in 
Ecolabelled products on the market and, on the other hand, to an  increase in the number of 
consumers  that  know  about  and  are  prepared  to  buy  eco-labelled  products  as  well  as  to  an 
increase in the use of Ecolabel criteria in public procurement, specifically over and above the 
number  of  licences,  companies  involved  and  overall  environmental  benefits  that  would  be 
achieved if the scheme was left as it is. More details can be seen in the EVER study. 

Future sustainable production and consumption policy in the Commission will put in place a 
coherent  package  of  policy  instruments  that  provide  incentive  for  improvement  in  the 
environmental performance of products. It will build-on and reinforce various existing policy 
instruments  also  adding  a  number  of  new  environmental  policy  initiatives.  The  Ecolabel 
scheme  will  need  to  be  a  key  part  of  such  an  SCP  package,  linking  to  other  policies  and 
providing  a  backbone  of  good  quality  life-cycle  based  product  information  for  them  to  use. 
An overhaul of the way the Ecolabel Regulation is written will allow it to be not just a stand 
alone instrument, but a usable and integral part of the wider SCP framework. A Regulation, 
written in a more simple and open way is needed, giving it the flexibility to link easily with 
other instruments as and when the need arises and decision making structures and processes 
will be simplified so they can be speeded up removing unnecessary bureaucracy. 

The Ecolabel Regulation as it stands is overlong and spread across six additional Commission 
Decisions,  it  is  difficult  to  follow  and  implement  as  a  result  and  needs  to  be  tidied  up.  The 
Regulation  is  also  too  restrictive  meaning  that  when  new  innovative  ideas  are  put  forward, 
they cannot be reacted to. Improving the way the Regulation is written and how criteria can be 
developed  will  increase  the  chances  that  the  potential  environmental  and  economic  benefits 
are realised – key to this will be the ability of the scheme to respond to innovation. 

The  Ecolabel  will  be  better  tailored  to  policy  makers  and  will  be  a  useful  benchmark  and 
information tool on the environmental performance of products. In terms of the objectives set 
out  in  Section  4,  if  this  package  of  measures  is  adopted,  we  might  expect  success  rates 
comparable to those of the Blue Angel or Nordic Swan labelling schemes. 

The economic and  environmental  impacts of the  scheme  will  depend  on  its  success,  though 
indications of the potential environmental benefits at different levels of success can be found 
in the AEAT report referenced in this impact assessment. 

The success of the Ecolabel will depend, amongst other factors, on how well it co-ordinates 
with other policy instruments aiming at promoting innovation in the life-cycle environmental 
performance  of  products.  The  forthcoming  Commission  Sustainable  Consumption  and 

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Production Action Plan will examine ways to use a range of product policy instruments in a 
coherent and co-ordinated way to maximise their effect as a whole in driving both innovation 
and sales of better performing products. As the Ecolabel would be a part of that package of 
instruments, its impact will need to be judged as part of that package. 

The  Ecolabel  imposes  no  administrative  burden  on  companies  in  the  strict  definition  of  the 
administrative burden used by the Commission43 because costs only incur to companies that 
voluntarily  decide  to  apply  for  the  label.  However,  this  is  not  a  reason  to  reduce  any 
unnecessary  costs  from  the  scheme's  operation.  Reducing  these  costs  will  lead  to  a  more 
effective  achievement  of  the  scheme's  objectives,  making  the  Ecolabel  both  more  attractive 
and increasing its net benefits. Several of the micro-objectives recommended to be accepted 
will reduce unnecessary administrative burden. 

In  conclusion,  it  seems  fair  to  say  that,  as  a  voluntary  instrument,  a  modified  Ecolabel  can 
have  net  economic  benefits  for  the  EU  economy,  and  increase  both  competition  and 
competitiveness.  The  Ecolabel  therefore  works  with  the  market  and  –  with  its  simplified 
approach – is a model "better regulation" policy instrument. 

43 

Administrative  costs  are  defined  in  the  2007  Commission  Action  Plan  for  Reducing  Unnecessary 
Administrative Burden as "the costs incurred by enterprises…..in meeting legal obligations to provide 
information on their action or production". 

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Annex 

List of current product groups: 

Dishwashers 

Footwear 

Televisions 

Hard Floor Coverings 

Tissue paper 

Refrigerators 

Textile products 

Soil improvers 

Growing Media 

Paints and varnishes 

Copying and graphic paper 

Light bulbs 

Bed Mattresses 

Washing machines 

Dishwashing Detergents 

Laundry detergents 

Vacuum Cleaners 

Tourist Accommodation Service 

Personal Computers 

Portable Computers 

All-purpose & sanitary cleaners 

Hand dishwashing detergents 

Camp Site Services 

Lubricants 
Soaps, shampoos & hair conditioners 

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