UNION EUROPEENNE DE L’ARTISANAT ET DES PETITES ET MOYENNES ENTREPRISES EUROPÄISCHE UNION DES HANDWERKS UND DER KLEIN- UND MITTELBETRIEBE EUROPEAN ASSOCIATON OF CRAFT, SMALL AND MEDIUM-SIZED ENTERPRISES UNIONE EUROPEA DELL’ ARTIGIANATO E DELLE PICCOLE E MEDIE IMPRESE
Paper Addressed to the Members of the Environment Committee of UEAPME:
Summary of the Commission’s Communication on
Integrated Product Policy (COM (2003) 302 final) and
its links with EMAS and the EU Eco-label
The purpose of this document is to highlight the growing importance of IPP and its links with a number of instruments, which UEAPME has closely monitored in the past years, and in some cases been closely involved in, such as the EU eco-label scheme or EMAS (Environmental Management and Audit Scheme). Considering the recent developments at EU level, UEAPME thought it would be useful to summarise the most important elements of the IPP strategy.
IPP aims at reducing the environmental impacts of products, by analysing all the phases of the life-cycle of a product, from the extraction of raw materials to the final disposal of the product, and taking action where it is most effective.
Objectives of IPP
The objective of IPP is to provide the framework and ensure coherence between all existing and future environment-related product policy instruments. This will help to fully exploit the potential synergies between the different instruments and to encourage their integrated development. IPP is primarily addressed to products, but services are not excluded.
Principles governing IPP
The underlying principles of the IPP approach from a technical point of view are the concepts of life-cycle thinking and continuous improvement.
; Life-cycle thinking
This consists in analysing the life cycle of a product, “from cradle to grave” and identifying and acting on the problem during the stages where the overall environmental impact and resource use can be best reduced and in the most cost-effective manner.
; Continuous improvement
It is assumed that it is always possible to reduce the overall environmental impact of a product, whether at the design, manufacture, use or disposal stage.
The other principles governing IPP are the market forces and the need to stimulate the supply and demand of greener products, the strong participation of stakeholders in the process and
the need to improve the IPP toolbox and the synergy among the different instruments (mostly voluntary instruments, but mandatory measures might also be required).
There are numerous tools in the framework of IPP. These tools can be divided into three main categories: the economic and legal tools; the tools to promote the application of life-cycle thinking and; tools for the consumers. However, only a mix of these different instruments will ensure that IPP is successful.
; Tools for creating the right economic and legal framework
In order to stimulate the production and buying of greener products, the appropriate economic and legal framework must be in place. The recent developments in the field of taxation of energy products should further encourage the use by Member States of energy taxation as a tool to achieve their environmental objectives. Meanwhile, the Commission intends promoting and encouraging the use of fiscal measures, such as environmentally-related taxes and incentives.
The wish to eliminate negative environmental subsidies is reinforced. The Commission has drafted guidelines on state aid for environmental purposes, such as to support technological change in favour of more environmentally friendly product and services.
There is also a keen interest to promote non-legislative solutions along the lines of environmental agreements and in the framework of the standardisation process.
There are also many possibilities of integrating IPP and environmental considerations in public procurement and the Commission will be promoting these.
Traditional legislation will also be used to promote IPP. The upcoming Directive establishing a framework for the eco-design of energy using products (EUP) will be the first concrete application of IPP.
; Promoting the application of life-cycle thinking
There is an increasing need for life-cycle data. Member States and industry have developed databases and the Commission intends setting up a platform in order to facilitate the exchange of information in this field. There will also be regular meetings and an on-line directory of Life-Cycle Analysis (LCA) databases accessible to all.
The Commission also wants to link its activities with the United Nations Environmental Programme Life-Cycle Initiative.
Other initiatives of the Commission include producing a handbook on best practices in the th Community Research Framework field of LCAs. Different programmes, like the 6
Programme or Life Programme, already address IPP related issues such as research in environmental processes etc.
Environmental Management Systems (EMS), and in particular EMAS are important IPP tools, since they are based on the concepts of life-cycle thinking and continuous improvement. The latest revision of EMAS also accentuated the product side of the scheme. The Commission will draw up guidelines for the product aspect of the scheme by the end of 2004.
UEAPME is closely involved in EMAS. UEAPME participates in the EMAS Article 14 committee, was actively involved in the last revision of the scheme to make it more SME friendly and collaborated with the Commission in the drafting of the EMAS guidelines, in particular the one on the verification of SMEs. Considering the importance of EMAS in the IPP strategy, UEAPME will continue to lobby to try and make EMAS more SME friendly, in particular during the upcoming discussions surrounding the next revision of the scheme.
Raising-awareness about EMAS, among SMEs, is another priority of UEAPME. In this framework, UEAPME won the tender for the organisation of two awareness-raising conferences aimed at SME local points. The first conference was organised in February 2004 in Rome in collaboration with Confartigianato. The second conference will take place in Manchester on 12 November 2004 and will be organised jointly with the Forum of Private Business (FPB).
In the coming years, there will be increasing obligations placed on the design aspect of products. In 2005, the Commission intends presenting a discussion document on how to promote the implementation of IPP in companies, including if appropriate general obligations for specific products. Among the issues that will be addressed are aspects related to the reporting to the public on environmental performances, the possibility of introducing minimum product standards, etc.
; Providing information to consumers
The Commission has made the greening of public procurement one of its priorities. It calls on Member States to draw up action plans to green their public procurement. It is also preparing a series of information tools, such as a “greening public procurement” website or a product group database. This database should provide information on existing product criteria, such as those used by eco-labelling and environmental product declaration schemes, so as to provide users with information on what criteria are relevant for a specific product.
A lot of effort will also be put into greening corporate purchasing. The objective is for businesses to request some sort of certification from their suppliers.
Environmental labelling is a well-developed instrument. Among the different existing schemes is the EU eco-label scheme. It is a voluntary instrument and products bearing an EU eco-label have demonstrated their superiority from an environmental point of view compared to most of the other products on the market. It is currently the best label from an IPP perspective since it takes into account the whole life-cycle of a product.
UEAPME is actively involved in the EU eco-label scheme. UEAPME lobbied strongly during the last revision of the scheme, and obtained a number of SME friendly provisions. Also, UEAPME is now one of the recognised partners of the European Union Eco-labelling Board and Consultation Forum (see Regulation 1980/2000). The role of UEAPME is to represent the interests of crafts, trades and SMEs in the scheme. In this framework, UEAPME has appointed experts in the different ad hoc working groups for product groups manufactured and services provided by SMEs, and contibutes to the development of criteria. UEAPME is also a member of the Marketing and Policy Management Groups.
The possibility to apply reduced VAT rates to products bearing the EU eco-label was discussed in the marketing management group but it was not retained.
The EU energy label is also a good label for products, which have energy consumption as main negative environmental impact.
The Commission has also to decide before the end of 2005 whether any actions will be undertaken to stimulate the development and uptake of Environmental Product Declarations.
IPP in the broader context
IPP must be seen as the link between all the different instruments and policy developed over the past decade. It plays a crucial role in the overall strategy on sustainable development and more specifically within the framework of sustainable production and consumption as agreed at the World Summit on Sustainable Development.
IPP will also be a core element of the upcoming thematic strategies on the sustainable use of natural resources and prevention and recycling of waste. Among the objectives of IPP is to reduce the resource use and the environmental impact of waste.
The latest developments at EU level regarding environmental technologies, and in particular the recently adopted action plan (COM (2004) 38 final) aimed at stimulating the uptake of environmental technologies, should also contribute to the further development of IPP.
Actions to implement IPP
The objectives of the Commission are to:
1. establish the framework conditions for the continuous environmental improvement of
all products throughout the production, use and disposal phases of their life-cycle;
2. to focus on products with the greatest potential for environmental improvement.
The Commission has started to organise “regular meetings”. These meetings will take place twice a year. Their purpose is for Member States and stakeholders to assist the Commission in its efforts to develop and implement IPP and monitor progress in the Member States. UEAPME has also been invited to attend.
In the framework of the regular meetings a number of working groups should be set up to address specific issues. The secretariat of UEAPME would like to propose a working group on SMEs. This working group should study the needs of SMEs in the field of IPP and provide the adequate tools to enable the application of IPP in SMEs.
The Commission wants to develop a series of indicators to measure the environmental improvements induced by the IPP approach.
The Commission also intends reporting on a regular basis. In 2006, it will produce a progress report on how IPP is being implemented in the Member States.
The Council has already given its opinion on the issue of IPP at the environment council of October 2003. In its conclusions, the Council asks to take account of the special needs of SMEs when developing IPP initiatives. It also asks to extend the application of IPP to services and especially for key areas such as tourism.
Brussels, March 2004