COMMISSION STAFF WORKING PAPER SUMMARY OF THE IMPACT ASSESSMENT
Date: 2011-12-15
Institutions: European Commission
Subjects: clean technology, innovation, international market, research and development, sustainable development

EUROPEAN COMMISSION 

Brussels, 15.12.2011 
SEC(2011) 1598 final 

COMMISSION STAFF WORKING PAPER 

SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

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

Innovation for a sustainable Future - The Eco-innovation Action Plan (Eco-AP) 

{COM(2011) 899 final} 
{SEC(2011) 1599 final} 
{SEC(2011) 1600 final} 

EN 

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Disclaimer: This executive summary commits only the Commission's services involved in its 
preparation  and  does  not  prejudge  the  final  form  of  any  decision  to  be  taken  by  the 
Commission. 

EN 

   EN 

 
 
 
 
BACKGROUND 

The Europe 2020 Flagship Initiative "Innovation Union"1 (IU) announces an Eco-innovation 
Action  Plan  (EcoAP)  to  focus  on  specific  bottlenecks,  challenges  and  opportunities  for 
achieving  environmental  objectives  through  eco-innovation.  The  IU  also  announced  that 
EcoAP  will  promote  eco-innovation  in  technologies,  business  processes  and  organizational 
change  to  address  the  challenges  of  resource2  scarcity,  air,  water  and  soil  pollution,  water 
efficiency and also provide growth and jobs. Its role is where general innovation policies are 
insufficient to promote eco-innovation. It will take forward existing experiences in promoting 
the development and uptake of eco-innovation, in particular the Environmental Technologies 
Action Plan3 (ETAP).  

EcoAP will also help to deliver the objectives set out in the Europe 2020 Flagship Initiative 
on "A resource-efficient Europe"4, that established resource efficiency as the guiding principle 
for  EU  policies  on  energy,  transport,  climate  change,  industry,  commodities,  agriculture, 
fisheries, biodiversity and regional development. Eco-innovation is one way of improving the 
resource efficiency of the economy. 

PROBLEM DEFINITION 

Eco-innovation  is  one  way  of  improving  environmental  protection  and  of  improving  the 
resource efficiency of the economy and so contributing to competitiveness.  

This can be achieved by developing new technological and non-technological solutions, new 
approaches to the way we run business or the way we consume and use goods and services. 
However,  the  current  rate  of  eco-innovation  is  sub-optimal,  and  there  is  the  potential  to 
increase eco-innovation to boost resource productivity, competitiveness and help to safeguard 
the environment.  

Achieving a safe and healthy global natural environment necessitates significant involvement 
of  partners  outside  the  EU.  However,  eco-innovations  and  environmental  technologies  are 
currently developed, for the most part, in developed countries, and they are not being diffused 
in the world economy at sufficient speed and scale.  

ANALYSIS OF SUBSIDIARITY 

Eco-innovation  is  at  the  crossroads  of  articles  173  and  191  of  the  Lisbon  Treaty,  and  is  a 
shared  responsibility  between  MS  and  EU.  In  the  field  of  innovation  the  EU  coordinates, 
supports  and  supplements  the  innovation  policies  of  the  Member  States,  but  cannot  replace 
them.  The  need  for  a  coordinated  policy  approach  able  to  address  eco-innovation  failures 
requires intervention at the EU level and cannot be achieved by individual EU Member States 
alone.  

EU  level  action  is  also  necessary  to  respond  to  the  increasing  geographic  complexity  of 
innovation  that  requires  increasing  cooperation  with  actors  outside  the  territory  of  an 
individual Member State. Therefore the European added value of an eco-innovation initiative 
is evident.  

1  COM (2010) 546 final, Europe 2020 Flagship Initiative "Innovation Union" 
2 Resources include raw materials such as fuels, minerals and metals but also food, soil, water, air, biomass and ecosystems. 
3  COM  (2004)  38  final,  Communication  from  the  Commission  to  the  Council  and  the  European  Parliament,  Stimulating  technologies  for 
sustainable development: An Environmental Technologies Acton Plan for the European Union 
4 COM(2011) 21, "A resource-efficient Europe" 

1 

 
 
 
 
 
 
 
 
 
 
 
 
                                                 
OBJECTIVES OF EU INITIATIVE 

The  problem  analysis  has  underlined  that  improving  Europe’s  eco-innovation  performance 
must  be  tackled  from  both  the  supply  and  the  demand  side  in  an  integrated  approach.  The 
EcoAP  will  accelerate  the  development  and  uptake  of  eco-innovation  by  tackling  eco-
innovation specific barriers, with an overall objective of: 

• 

Increasing the rate of eco-innovation and its uptake in Europe and in so doing deliver 
efficient  solutions  for  environmental  problems,  and  boost  the  resource  efficiency  of 
Europe and its competitiveness. 

Specific  objective  1:  to  apply  the  principles  of  the  Innovation  Union  Initiative  to  eco-
innovation. This will be done through the following operational objectives: 

-  Putting in place an eco-innovation friendly environmental regulatory framework  
- 

Integrate eco-innovation concerns into relevant policies and initiative, in particular in 
the innovation policy field  

-  The  European  Commission  will  in  2012  make  proposals  for  better  targeting  of  EU 

funds on eco-innovation as part of the next EU financial perspectives  

Specific  objective  2:  to  promote  eco-innovation  in  Europe.  This  will  be  done  through  the 
following operational objectives: 

-  Strengthen eco-innovation capacities of SMEs through increased networking and the 

- 

spread of best practice  (2011 onwards) 
Increase the market credibility and investment readiness of emerging eco-innovations 
(2011 onwards) 

Specific objective 3: to improve global markets for eco-innovation. This will be done through 
the following operational objectives: 

-  Open up global markets to eco-innovation 
- 

Improve global capacities for eco-innovation, in particular in developing countries 

POLICY OPTIONS  

Option 1 is a baseline option whereby EU policies that already exist or are under development 
are  implemented  but  there  are  no  additional  policies  on  eco-innovation.  It  provides  the 
baseline against which the other options are compared. Option 2 is the simple continuation of 
ETAP.  Option  3  looks  at  a  basket  of  actions  to  take  forward  the  Europe  2020  Flagships. 
Option 4 looks at a number of SME eco-innovation specific actions, while Option 5 sets out 
more wide ranging regulatory intervention in support of eco-innovation.  

Option 1: Discontinuation of ETAP 

Under  this  option,  several  instruments  and  policy  directions  will  continue,  at  least  for  a 
limited period – but the focus on eco-innovation may be limited or abandoned. In particular, 
eco-innovation would be taken forward through: 

- 

the  Europe  2020  flagships,  including  the  Innovation  Union,  Industrial  Policy  for  a 
Globalized Era, A Resource-Efficient Europe and the Agenda for New Skills and Jobs, 
-  environment  policy  will  continue  to  create  markets  and  set  incentives  for  eco-

innovation, 
funding for innovation from CIP and LIFE+. 

- 

2 

 
 
 
 
 
 
 
 
 
 
 
 
 
Option 2 Continuation of ETAP 

The current Action Plan consists of 29 actions, including 9 priority actions (PA) (see Figure 
1). The option would see a continuation of the current four main domains. Firstly, promoting 
"green"  research  while  attracting  private  and  public  investment.  Secondly,  tackling  the 
unfavourable  conditions  faced  by  eco-innovators  in  the  market.  Thirdly,  promotion  of 
environmental  technologies  abroad  and  lastly,  governance  and  networking  of  stakeholders 
(public institutions, enterprises, researchers, financial institutions, etc.).  

Continuation  of  ETAP  would  have  a  strong  focus  on  technology  (excluding  social  and 
organisational eco-innovation), and a "light" governance (through the HLWG).  

Figure 1: Actions under the ETAP option 
A1 

Increasing and focusing research, demonstration and dissemination. Improving co-ordination of relevant programmes 

A2 

A3 

A4 

A5 

A6 

A7 

A8 

A9 

Establishing technology platforms 

Establishing European Networks for technology testing, performance verification and standardisation  

Developing and agreeing on performance targets for key products, processes and services  

Mobilising financial instruments to share the risk of investing in environmental technologies  

Encouraging systematic internalisation of costs through market-based instruments 

Encouraging procurement of environmental technologies 

Raising business and consumer awareness 

Supporting eco-technologies in developing countries, and promoting foreign investment 

Option 3: Taking forward the Europe 2020 Flagships 

Option 3 would involve doing what is promised in the context of the Europe 2020 for the area 
of  eco-innovation,  in  particular  the  review  of  environmental  legislation,  inclusion  of  eco-
innovation  aspects  in  the  Innovation  Partnerships  or  supporting  the  development  of  green 
skills. Whilst there is a commitment to these actions already, this option would provide firm 
ownership for them. 

Option  3  builds  on  ETAP  lessons  learnt,  by  expanding  from  green  technologies  to  eco-
innovation, and providing a more efficient structure for the Action Plan.  

Option 4: SME-targeted actions 

In order to seize the emerging opportunities SMEs must become active developers and users 
of  eco-innovation5.  Option  5  focuses  on  SME  eco-innovation  needs,  expands  the  scope  of 
intervention  to  also  include  non-technical  eco-innovation,  emphasizes  the  global  dimension 
and  networking.  The  actions  are  in  two  broad  areas:  additional  actions  specific  to  eco-
innovation and going beyond the Europe 2020 flagships and global actions.  

Option 5: Wide EU eco-innovation policy 

This option consists of actions that can be implemented in addition to (and not only instead 
of)  the  other  options.  It  is  characterised  by  a  higher  level  of  ambition,  more  regulatory 
approach  and  a  more  long-term  view.  However,  it  is  also  of  a  'general  principles'  nature, 
rather than of the operational bent of options 3 and 4. Reflecting this, the measures involved 
would be the responsibility of a wide range of levels of government and actors.  

5 The 8th ETAP Forum Declaration, June 2010, "Fostering eco-innovation in SMEs" 

3 

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
ANALYSIS OF IMPACTS  

A comparison of the options was carried out according to their adequacy in delivering the 
objectives, their expected impacts and their feasibility.  

Option 1: No ETAP  

This option assumes the termination of ETAP. Ongoing policies in innovation, environment 
and other areas continue without specific inputs from the eco-innovation point of view.  

Additionally  with  the  suspension  of  ETAP  current  activities  on  the  definition  of  an  EU 
framework  for  the  verification  of  environmental  technologies,  developed  under  the  ETV 
pilot programme and associated research and pilot activities, would no longer be supported at 
EU level. National programmes would probably be developed and tested, potentially resulting 
in  divergent  programmes  without  mutual  recognition  and  with  practically  no  impact  on  the 
promotion  of  green  technologies  outside  national  markets.  International  co-operation  would 
likely  lead  to  an  international  standard  on  ETV  procedures,  but  without  involvement  at  EU 
level.  There  is  a  risk  that  EU  policy  and  industry  characteristics  would  not  be  taken  into 
account.  The  overall  impact  would  be  missed  opportunities  for  the  marketing  of  EU 
environmental technologies. 

Also in terms of financial support to eco-innovation, although it is expected to continue in the 
next financial perspective, the discontinuation of ETAP would probably result in less focussed 
financial  support  due  to  a  lack  of  a  deep  understanding  of  the  European  eco-innovation 
system, which is one of the priorities of ETAP.  

Overall,  the  rate  of  eco-innovation  and  the  degree  of  policy  integration  of  eco-innovation 
would  fall  as  compared  to  the  existing  situation.  This  option  is  the  baseline  against  which 
other options are compared. 

Option 2: Continuation of ETAP  

The impacts of ETAP are indirect: ETAP is not a distinct programme with a budget. It is an 
umbrella pulling together different intervention instruments and influencing the direction and 
size of other, often broader and non-environment specific programmes and schemes.  

The continuation of ETAP would lead to continued attention for environmental technologies 
and  will  have  positive  effects  on  innovation  in  the  area  of  environmental  technologies, 
competitiveness  of  the  eco-industry  (and  related  employment)  and  positive  impacts  on  the 
environment and on health. Direct administrative burden, as ETAP actions are voluntary and 
reporting requirements minimal, would be limited and mainly consists of human resources to 
carry out the actions.  
Option  2  covers  most  of  the  specific  objectives,  however,  the  adequacy  of  response  is 
relatively  low  notably  due  to  the  scope  being  limited  to  environmental  technologies, 
failure to refocus action in line with the lessons learnt and not corresponding to the new 
political objectives. 

Option 3: Taking forward the Europe 2020 flagships  

The shift from environmental technologies to eco-innovation will contribute to a competitive 
advantage  for  industrial  sectors  and  can  lead  to  positive  environmental,  economic  and 
employment impacts. Improving resource efficiency will also help combat climate change and 

4 

 
 
 
 
 
 
 
 
 
 
 
 
 
boost  economic  growth.  Furthermore  an  EcoAP  with  a  strong  focus  on  resource  efficiency 
would  be  consistent  with  the  strategy  set  out  by  the  Europe  2020  initiative.  As  for  social 
impacts,  in  addition  to  the  expected  positive  impacts  on  health  (i.e.:  less  environmental 
impacts  generated  by  more  sustainable  solutions)  positive  impacts  are  expected  in  terms  of 
employment.  

Administrative  burden  may  increase  marginally,  for  example  if  voluntary  Roadmaps  are 
provided.  

Option  3  provides  a  comprehensive  policy  response  to  specific  objectives  and 
complements well the Innovation Union initiative. The adequacy of response is high. 

Option 4: SME-targeted actions 

The  Option  will  adequately  target  the  needs  of  eco-innovative  SMEs  by  highlighting 
networking  and  better  preparing  them  for  exploiting  the  available  market  opportunities  (by, 
for instance, increasing their market readiness).  

Option 4 provides a policy response targeting well the needs of eco-innovative SMEs. 
The adequacy of response is high. 

Option 5: Wide EU eco-innovation policy 

Systemic  eco-innovation  requires  coordinated  action  by  research  actors,  economic 
stakeholders and political decision-makers. This option strives for establishing prices, which 
reflect environmental impacts and so improve market conditions for eco-innovations. Option 
5 addresses underlying drivers for high consumption of resources and energy and high levels 
of emissions and waste. It takes a radical approach directed at root causes expanding beyond 
traditional  environmental  policy.  The  necessity  of  the  described  actions  have  neither  been 
contested  in  literature  nor  during  the  stakeholder  consultation  connected  to  this  Impact 
Assessment.  

The  Option  will  carry  significant  long-term  effects.  Social  impacts  will  be  considerable: 
industry structure may change with related shifts in employment; effects on competitiveness 
may be large (when EU is not taking possible trade effects into account). 

COMPARISON OF OPTIONS 

The figure below presents an overview of overall scores for policy options taking into account 
their expected wider impacts and the feasibility of their implementation. 

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Figure 2. Comparison of policy options against Option 1 
Overall table and ranking criteria

Option 1*

Option 2

Option 3

Option 4

Option 5

Adequacy

Impact

Feasibility

Adequacy in terms of 
meeting specific 
objectives
Impact on innovation 
system
Impact on environment
Impact on 
competitiveness
EU value added

Contribution to the 
achievement of wider 
impacts

N/A

N/A
N/A

N/A
N/A

N/a

medium

+
+

+
++

++

high

+++
++

++
+++

medium/ high high**

++
++

+++
+++

++
+++

-/++ ***
+++

+++

++

+

Timing of actions (mean) N/A

< 2 years

< 2-5 years

< 2-5 years

> 5 years

* The exact degree of negative impacts of discontinuation of ETAP depends on other EU interventions that may subsititute ETAPactions
** Option 5 is assessed as highly adequate notably in the field of improving market conditions in a long term
*** Effects on competitiveness may be negative in the short term (e.g. resource taxes may hamper competitive position of resource-
intensive industries)

Summing  up  the  different  elements,  when  considering  the  urgency  for  a  focussed  and 
improved eco-innovation policy initiative, as well as the feasibility of its implementation in a 
reasonable range of time, Option 3 appears to respond better to the new political environment. 
Option 4 on the other hand targets directly SME-specific problem drivers. Option 5 represents 
a  longer  term  vision  to  achieve  a  radical  transition  to  a  resource-efficient,  competitive  and 
sustainable  economy.  Thus  a  combination  of  Option  3  &  4  is  deemed  to  be  most 
appropriate  by  shaping  the  policy  agenda  for  eco-innovation  in  the  medium  term  and 
responding  directly  to  the  eco-innovation  needs  of  the  SMEs.  Options  3  and  4  also 
combine well, complementing each other and there are no negative trade-offs between them. 
The combined actions respond best to the identified objectives and problem drivers.  

In addition, combining Option 3 & 4 responds well to the arguments raised during the broad 
public  consultation,  for  instance  by  focusing  on  SME  needs,  in  terms  of  financing,  training 
and networking (Option 4). The business sector and the Member States called for action on 
the  framework  conditions  for  eco-innovation  (Option  3).  A  reinforced  governance  structure 
(Option  3)  with  greater  emphasis  on  policy  learning,  coordination,  and  agenda  setting  has 
received  broad  support  both  during  the  HLWG  meetings  and  stakeholder  consultations.  
Stakeholders  have  endorsed  a  targeted  approach  in  relation  to  foreign  partners  for  eco-
innovation (Option 4) and acting through established networks and channels to avoid overlap.  

MONITORING AND EVALUATION 

EcoAP,  being  a  broad  “policy  framework”,  presents  a  challenge  for  monitoring  and 
evaluation. Furthermore, the selection of indicators will need to recognise its enlarged scope. 
Therefore,  especially  evaluation  of  wider  effects  will  rely  on  proxy  indicators  (due  to  the 
limited access or lack of suitable data) or qualitative assessments.  

The monitoring activity can be performed on two levels: 
–  reporting  on  activities  performed  by  EcoAP,  such  as  Eco-innovation  fora,  the  HLWG, 

participation in inter-service consultations, specific studies (“internal reporting”), and 

–  collection  of  key  monitoring  indictors  on  the  implementation  of  all  EcoAP  actions  in 

collaboration with implanting bodies (“external reporting”). 

The evaluation activity will encompass: 

6 

 
 
 
 
 
 
 
 
 
•  collection  of  quantitative  and  qualitative  evidence  of  the  progress  towards  achieving 
goals of all individual actions of Eco-AP (whenever possible, the evaluation of Eco-
AP will rely on dedicated evaluations performed for individual actions); 

•  analysis  results  and  effects  of  activities  performed  by  Eco-AP  team  (attribution 

analysis of the value added of Eco-AP in achieving the goals). 

In order to improve the quality of evaluation it is proposed that the EcoAP will be evaluated 
both  internally  and  externally.  In  this  regard  the  Eco-innovation  Observatory  will  be  highly 
useful,  by  gathering  data  on  markets  and  trends.  The  previous  experience  of  ETAP  showed 
difficulties in attributing effects to ETAP actions. An ongoing internal evaluation will gather 
useful evidence 

7