Report from the Commission to the Council, the European Parliament, the European Economic and Social Committee and the Committee of the Regions on the State of Implementation of Integrated Product Policy SEC(2009)1707
Date: 2009-12-21
Institutions: European Commission
Subjects: consumption, environmental policy, environmental protection, goods and services, product life, production, report

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EUROPEAN COMMISSION  

Brussels, 21.12.2009 
COM(2009)693 final 

REPORT FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN 
PARLIAMENT, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND 
THE COMMITTEE OF THE REGIONS 

On the State of Implementation of Integrated Product Policy 

SEC(2009)1707 

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REPORT FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN 
PARLIAMENT, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND 
THE COMMITTEE OF THE REGIONS 

On the State of Implementation of Integrated Product Policy 

1. 

INTRODUCTION 

On  18  June  2003  the  Commission  adopted  its  Communication  "Integrated  Product  Policy  – 
building on environmental Life-Cycle Thinking".1 The present report summarizes the state of 
implementation of this policy. A detailed analysis is given in the Commission Staff Working 
Paper accompanying this report. 

The  concept  of  Integrated  Product  Policy  (IPP)  aims  at  coherent  action,  using  the  most 
appropriate policy tools and involving stakeholders, towards "greener" products that combine 
lower  environmental  impacts  with  enhanced  service  to  consumers.  It  calls  for  continuous 
improvement  in  product  manufacturing  and  design,  and  for  promoting  their  uptake  by 
consumers. 

The IPP concept is based on following observations: 

•  The  production  and  use  of  goods  and  services  (i.e.  products)  are  causing  the  majority  of 
overall  negative  impacts  on  the  environment.  The  situation  is  worsening  due  to  ever 
increasing numbers of products being consumed in the EU and globally. 

•  The environmental pressures and impacts of products occur at various stages of their life-
cycle (along production chain, during use phase, disposal of end-life products). Remedial 
actions must be designed in a way to avoid that the environmental burden is simply shifted 
to other stages of the life-cycle, or to other geographical areas. 

•  Due  to  the  large  variety  of  products  and  impacts  there  is  no  one  single  policy  tool  to 
address  them  all.  On  a  case-by-case  basis,  the  appropriate  policy  instrument  or 
combination of instruments have to be chosen and deployed in a co-ordinated way, often 
across several  policy areas (for  example legislation on  product design, emission ceilings, 
labelling, fiscal measures, self-commitments of industry, etc.). To make best use of these 
instruments, a large variety of stakeholders needs to be involved, including policy makers, 
business and consumers. 

The Communication on IPP in 2003 was preceded by preparatory studies in 1998 and a Green 
Paper on IPP2 in 2001. The Communication elaborated the objective of IPP and established 
five  IPP  'principles':  (1)  Life-cycle  thinking;  (2)  Working  with  the  market;  (3)  Wide 
involvement of stakeholders; (4) Continuous improvement of products; (5) Co-ordinated use 
of policy instruments. IPP was to be implemented through three strategic actions: 

1 
2 

COM (2003) 302. 
COM (2001) 68. 

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•  Contributing  to  overarching  policy  actions,  notably  the  EU  Sustainable  Development 
Strategy3, the EU's 6th Environmental Action Programme4 and the Ten-year Framework of 
programmes on Sustainable Consumption and Production5. 

•  Supplementing  existing  product-related  policies  by  providing  a  framework  in  which 

environmental problems can be considered in view of the life-cycle of products. 

•  Strengthening  the  co-ordination  and  coherence  of  environment-related  product  policy 

instruments. 

Accordingly, IPP itself would generally refrain from concrete action on specific products6 but 
rather  provide  the  conceptual  framework,  guidance  and  tools  for  a  large  variety  of  policies 
and  actors.  The  Communication  highlighted  possible  areas  of  action  and  suggested 
responsibilities for the main groups of stakeholders. 

The  Council  of  Environment  Ministers7  welcomed  this  initiative  and  supported  "…  the 
intention  to  encourage  relevant  actors  to  include  in  their  policies  objectives  to  reduce 
environmental  impacts  of  all  products  aiming  at  continuous  improvement  of  products  and 
services …" 

Since then, the concept and IPP tools have been turned into practice at all policy levels, with 
the participation of industry and other stakeholders to varying degrees. 

2. 

STATE OF IMPLEMENTATION 

Today, the IPP principles are embedded in many initiatives, and the research done and tools 
developed  as  outlined  in  the  Communication  are  being  widely  used.  However,  explicit 
references  to  IPP  in  these  initiatives  are  not  common.  The  uptake  of  the  IPP  approach 
therefore needs to be assessed from the contents of policies rather than on the basis of explicit 
references. Also, ambitions towards better coherence of product-related policies have since its 
inception significantly increased, forming part of the "Better Regulation" agenda8. Indeed, the 
IPP  principles  have  been  successfully  subsumed  into  the  over-arching  Sustainable 
Consumption  and  Production/Sustainable  Industrial  Policy  (SCP/SIP)  framework  with 
the 2008 SCP/SIP Action Plan,9 effectively embracing and taking forward the process started 
with IPP Communication. 

Going forward, it seems appropriate to further integrate the two processes and consider IPP as 
a significant component of the SCP/SIP agenda. 

3 
4 
5 
6 

7 
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9 

Renewed Strategy on Sustainable Development of 9 June 2006 n° 10117/06. 
COM (2001) 31. 
See http://www.un.org/esa/dsd/dsd_aofw_scpp/scpp_tenyearframprog.shtml 
However, two pilot projects were carried out to test the validity of the approach and gain experience in 
its implementation. Mobile phones and garden chairs made from tropical wood were selected, without 
prejudice  to  the  significance  of  the  environmental  impacts  of  the  chosen  products  or  the  expected 
degrees of improvement. See http://ec.europa.eu/environment/ipp/pilot.htm. 
Council conclusions of 12 November 2003 on Integrated Product Policy. 
COM (2005) 97. 
COM (2008) 397 

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2.1. 

EXAMPLES OF IMPLEMENTING IPP AT COMMUNITY LEVEL 

Several  policy  initiatives  developed  subsequently  to  the  IPP  Communication  reflect  the  IPP 
approach towards "greener" products in view of the whole life-cycle. 

The  Action  Plan  on  Sustainable  Consumption  and  Production/Sustainable  Industrial 
Policy  (SCP/SIP)  combines  IPP  instruments  into  a  coherent  policy  package  towards 
"greener" products and smarter consumption patterns. It is therefore a major contribution to 
implementing  IPP  instruments  at  Community  level,  including  among  others:  legislation  for 
the continuous improvement of product design, combined with revised labelling schemes 
to  support  consumer  demand  for  environmentally  highly  performing  products,  a  framework 
for  Green  Public  Procurement  of  goods  and  services  and  the  possibility  of  financial 
incentives to stimulate uptake of such products.. Furthermore the "Retail Forum" established 
under  the  SCP/SIP  Action  Plan  implements  the  IPP  instrument  of  greener  corporate 
purchasing  and  ensures  cooperation  between  different  stakeholders  to  provide  consumers 
with better information on sustainability.10  

The  Eco-design  for  energy-using  products  Directive  was  a  direct  transposition  of  IPP 
principles into product design legislation. Its scope has been widened in 2009 to more product 
groups (energy related products) in the context of the SCP/SIP Action plan. 11 

The new Waste Framework Directive12 makes several IPP elements legally binding, notably 
the requirement for waste policy to consider the whole life-cycle of materials in waste policy 
development.  Life-cycle  thinking  also  guided  a  provision  of  the  Batteries  Directive13  that 
allows  disposal,  instead  of  recycling,  only  if  environmentally  advantageous  in  view  of  the 
whole life-cycle. 

The  Thematic  Strategies  on  the  Sustainable  Use  of  Natural  Resources14  and  on  the 
Prevention  and  Recycling  of  Waste15  have  endorsed  the  life-cycle  thinking  and  the  call  for 
continuous  improvement,  as  well  as  the  principle  of  working  with  the  market.  The  waste 
strategy's call for strong recycling markets in the EU is an example of this. 

Immediately after adoption of the IPP Communication, the Commission started to develop the 
European  Life  Cycle  Assessment  (LCA)  Platform,  a  quality-controlled  European 
Reference Life Cycle data base and an LCA handbook. Work is continuing towards specific 
guidance  for  the  application  of  life-cycle  thinking  in  specific  policy  areas,  as  well  as  fully 
embracing  the  international  dimension.  Furthermore,  two  voluntary  Pilot  Projects  have 
explored the practicalities of the IPP concept and notably life-cycle thinking16, and resulted in 
industry self-commitments in this respect. 

10 

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16 

Since they are the crucial intermediary between producers and consumers, the Retailers in cooperation 
with the producers will need to ensure adequate labeling and information on products so as to contribute 
to  a  shift  towards  more  sustainable  products.  The  presented  environmental  information  should  be 
understandable, not ambiguous and not likely to mislead or confuse the consumers.  
Directive  2009/125/EC  of  the  European  Parliament  and  the  Council  establishing  a  framework  for  the 
setting of ecodesign requirements for energy-related products 
Directive 2008/98/EC of the European Parliament and the Council on waste 
Directive 2008/12/EC of the European Parliament and the Council on batteries and accumulators and 
waste batteries and accumulators 
COM (2005) 670 
COM (2005) 666 
See http://ec.europa.eu/environment/ipp/pilot.htm.  

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To  help  focussing  policies,  the  Commission  has  assessed  which  products  cause  most 
environmental  impact  and  what  options  exist  for  improving  them17.  The  resulting  focus  on 
housing, transport and food products is taken forward, among others in the multi-stakeholder 
European  Food  SCP  Round  Table  that  has  been  set  up  recently  (2009)18  as  well  as  the 
BUILD-UP website.19 

The  Recycling  Lead  Market  initiative  aims  at  encouraging  demand  for  products  with 
recycled  materials  that  provide  a  life-cycle  environmental  benefit.  The Bio-based  Products 
Lead Market aims to promote the development of sustainable products from renewable raw 
materials, e.g. bio-based chemicals and plastic.20 

The  6th  and  7th  Research  Framework  Programmes  have  been  funding  a  number  of  research 
projects aiming at supporting the implementation of IPP policies, notably in the areas of Life 
Cycle  Assessment  methodology 
industrial  ecology,  waste 
prevention, recycling, bio-refineries and sustainable consumption. 

improvement,  eco-design, 

2.2. 

EXAMPLES OF IMPLEMENTING IPP AT MEMBER STATES' LEVEL 

The  IPP  concept  has  been  well  established  in  activities  of  Member  States,  often  in  close 
relation to Community level activities.  

Transposing  and  implementing  Community  legislation  with  IPP  elements  is  an  essential 
contribution  of Member States  to IPP. Some examples include product design and labelling 
legislation,  and  the  internalization  of  environmental  costs  through  producer  responsibility 
schemes. National initiatives to internalize environmental costs are certain eco-tax schemes in 
various Member States. 

Member States have taken action to strengthen the demand for better products notably in 
the  area  of  Green  Public  Procurement.  Action  by  the  seven  best  performing  Member  States 
has brought the EU average to 45% green public procurement in terms of value, resulting for 
example  in  25%  less  CO2  emissions  and  yet  lowering  the  life-time  costs  by  1%.  The 
Netherlands aim at 100% sustainable procurement of the national government by 2010.  

The objective of better information for consumers is pursued by many Member States. In 
addition to the European Ecolabel, around half of them have national ecolabel schemes – in 
the  most  successful  cases  reaching  10,000  licensed  products  in  a  single  country.  Policy  co-
ordination  and  integration  at  national  level  has  progressed  in  many  areas:  the  regular 
exchange  of  views  and  experience  provided  by  the  Commission-chaired  IPP  Regular 

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20 

See: http://ipts.jrc.ec.europa.eu/activities/sustainable_development/susproc.cfm 
The  European  Food  SCP  Round  Table  is  a  multi-stakeholder  process  aiming  at:  i)  identifying 
scientifically reliable and uniform environmental assessment methodologies for food and drink products 
across the entire products life-cycle; ii) identifying the suitable communication tools to consumers and 
other  stakeholders;  iii)  promoting  the  continuous  environmental  improvement  of  food  and  drink 
products along the supply chain. 
In the Build-up website building professionals, local authorities and building occupants can share their 
experience on how to cut energy consumption in buildings, see http://www.buildup.eu/. The European 
Commission  has  also  set  a  Concerted  Action  with  representatives  of  the  Member  States  to  exchange 
best practices on the implementation of the Directive on Energy Performance of Buildings (Directive 
2002/91/EC  of  the  European  parliament  and  of  the  Council  of  16  December  2002,  on  the  energy 
performance of buildings. O.J. L 1/65 of 4.1.2003). 
COM (2007) 860 

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Meetings  is  complemented  by  inter-ministerial  working  groups  for  example  in  the  Nordic 
countries,  national  IPP  co-ordination  bodies  and  dedicated  departments  for  sustainable 
products and consumption, for example in France and the UK, or the specific department in 
the state government of Bavaria (Germany). 

Member  States  have  also  carried  forward  product  specific  actions.  Denmark,  Finland, 
Sweden and the United Kingdom have arranged product panels involving stakeholders from 
the  whole  life  cycle.  Bavaria  has  supported  a  number  of  eco-design  projects  on  specific 
products. Notably Italy, Denmark, the Netherlands, Germany, Sweden and France have also 
actively pursued voluntary agreements with industry on specific targets and actions. 

These initiatives are often supported by active work on  life-cycle data and methodologies. 
At least one third of the Member States have been developing tools and promoting life-cycle 
thinking very actively; some of them have established LCA research centres. 

With  regards  to  integrating  life-cycle  thinking  within  the  operations  of  organisations,  all 
Member  States  have  measures  in  place  to  promote  the  EU  environmental  management 
scheme EMAS. 

2.3. 

EXAMPLES OF IMPLEMENTING IPP AT BUSINESS AND OTHER STAKEHOLDERS 

Industry associations, individual companies and NGOs have co-operated with authorities and 
researchers  at  Community,  national  and  local  levels.  Most  product-specific  activities, 
including  the  Commission's  own  pilot  projects,  were  only  possible  with  the  proactive 
involvement  of  industry  and  NGOs.  Industry  has  also  been,  and  is  being,  instrumental  in 
making life-cycle information available, notably by contributing to the European Life-Cycle 
Database. 

There  has  been  a  significant  increase  of  awareness  of  life-cycle  thinking.  Increasingly, 
industry sectors apply  life-cycle thinking to inform their approaches towards product policy 
and communication with customers and authorities. One typical example is the Eco-profiles 
initiative  of  the  plastics  industry  in  Europe.  Another  example  is  the  active  participation  of 
industry associations, through the Consultation Forum, in developing implementing measures 
of  the  Ecodesign  Directive.  There  is  also  increasing  participation  of  business  in  initiatives 
towards  life-cycle  based  policy  development,  for  example  in  the  Retailers  Forum,  the 
European Food SCP Round Table and the BUILD-UP initiative. 

3. 

ROOM FOR FURTHER ACTION 

Altogether  significant  progress  has  been  made  in  the  EU  towards  environmentally  driven 
product  policies.  Nevertheless,  with  IPP  being  a  process  rather  than  a  final  status  there 
continues to be ample room for further activities. Some evident options would include: 

Further  enhancing  the  role  of  IPP  in  national  policies.  Some  Member  States  have 
exemplary measures in place but many are still lagging behind. As IPP is an ongoing process, 
different degrees of progress can also be seen due to wider developments during the reporting 
period, such as the enlargement of the EU. However, several new Member States have made 
good progress while several of the EU-15 Member States could step up their efforts. 

For environmental NGOs, consumer organizations and SMEs participation in IPP processes 
and  application  of  its  instruments  could  be  further  encouraged  and  facilitated.  As  a  general 

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observation, it seems that more support and dialogue is needed to strengthen awareness of the 
environmental  benefits  that  life-cycle  thinking  can  bring  to  reducing  the  overall  negative 
impacts of products. Many product panels and the pilot projects have demonstrated that this 
can be achieved particularly well by co-operation on concrete cases.  

As  already  indicated  in  the  IPP  Communication,  the  concept  can  also  be  applied  to  the 
environmental  improvement  of  non-industrial  products  and  to  services.  Initiatives  in  this 
direction have been launched in the context of the SCP/SIP Action Plan, such as the already 
mentioned Retail Forum and European Food SCP Round Table. 

The 'IPP instruments' of taxation and subsidies have not yet been applied at Community 
level. 

4. 

POLICY INITIATIVES FROM IPP TO THE SCP/SIP ACTION PLAN 

The IPP concept has been elaborated by the Commission at a time of new major initiatives in 
environmental policy, marking a shift from end-of-pipe to preventive action. At Community 
level  the  6th  EAP  called  for  its  application  to  natural  resources  and  waste  policy.  On  the 
international  level,  the  Johannesburg  Summit  brought  action  on  sustainable  production  and 
consumption patterns to the attention of policy makers. 

Recognizing  that  many  environmental  problems  are  caused  by  the  ever  increasing  numbers 
and varieties of globally traded products and materials, IPP was seen to supplement sectoral 
environmental policies on waste, water, air or chemicals. 

Two years after the Council had endorsed the IPP Communication, the Commission presented 
the Thematic Strategies on natural resources and waste that built upon IPP principles in their 
respective  domains.  Yet  another  two  years  on,  the  Commission  issued  its  consultation 
document on a future SCP/SIP Action Plan and adopted the plan in the following year. 

The  SCP/SIP  Action  Plan  foresees  a  review  of  some  of  its  elements,  as  well  as  of  the  plan 
itself,  by  2012,  thereby  keeping  the  call  for  concrete  measures  for  implementing  IPP 
instruments high on the political agenda. 

5. 

CONCLUSIONS 

IPP  aims  at  using  the  most  suitable  policy  instruments  for  the  continuous  improvement  of 
products.  It  is  an  ongoing  process  rather  than  a  finite  state.  It  requires  a  high  level  of 
awareness  among  policy  makers  and  other  stakeholders,  and  the  will  to  translate  awareness 
into concrete action on a daily basis. 

The IPP approach has contributed significantly to the development of several environmental 
policies  in  the  areas  of  product  design,  use  of  natural  resources  and  management  of  waste. 
Member States, industry and other stakeholders have actively advanced its implementation by 
direct involvement at Community level, transposition of Community legislation, economically 
motivated actions and other own initiatives. 

The  implementation  of  IPP  in  terms  of  policy  integration  is  difficult  to  document  as  new 
policies  seldom  make  explicit  reference  to  IPP.  However,  overall  significant  progress  has 
been made in the uptake of life-cycle thinking by key industries and policy makers, and the 

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availability  of  life-cycle  data  and  consensus  on  methodology  have  greatly  advanced.  Good 
progress  has  also  been  made  in  identifying  products  with  the  greatest  potential  for 
improvement and possible measures for improvement. 

information,  eco-design 

legislation,  clean  production  and  "green"  public 
Consumer 
procurement/purchasing are now at the core of the SCP/SIP Action Plan. The SCP/SIP Action 
Plan  is  carrying  forward  the  process  initiated  with  the  IPP  Communication  with  the  aim  of 
further  unlocking  market  potentials  for  more  sustainable  products  and  promoting  smarter 
consumption.  The  review  of  the  Action  Plan  foreseen  in  2012  will  provide  an  excellent 
opportunity to further assess the development of IPP.  

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