Examination of Witnesses (Question Numbers
300-319)
JOAN RUDDOCK
MP, MR BOB
RYDER AND
MR DOMINIC
PATTINSON
23 JANUARY 2008
Q300 Chairman: Finally, from me,
I wonder to what extent the visibility of labels is an issue.
When the Government was rightly tackling tobacco the health warnings
got bigger and bigger and bigger until I wondered eventually whether
they would be the entire advert, if you like. Should some of the
approaches that we have made be more visible and be made more
of a feature in that sense?
Joan Ruddock: I think that is something
that can only be worked through, I am sorry to say, on an individual
product or service because some things physically are just too
small to carry the whole impact of all of the many messages that
we would like to put. It would be impossible to design all the
protection labels on to some very, very small product. It has
got to depend on what we are dealing with in terms of the product
itself. Having said that, if the product could carry a label of
a decent size with decent sized print on it then there is no excuse
whatever for putting that information on the back of the product
in very small type where you cannot actually see it until you
acquire the product. We would want to see the best practice with
labels that are meaningful.
Q301 Jo Swinson: To touch on the
example you mentioned of A-G, which I think we are all familiar
with, that is an example of a label where the environmentally
good decision is the same as what is financially the smart thing
for people to do. It is the same with vehicles as well when it
says how much it costs to run. Would you say that environmental
labelling will only be successful where those two different motivations
are in sync with each other?
Joan Ruddock: Not necessarily, but you
are absolutely right to observe that they are in sync and that
is why it has probably been hugely successful. Where people are
making a decision about purchasing a product then price is clearly
a factor, so if it is just at that moment that they have to make
a choice, "Is this better for the environment or not",
then price may be the deciding factor for them if they are not
from this very committed group that I spoke of earlier. However,
if they know it is going to be better long-term and, therefore,
they are likely to get their money back then the price factor
aligns with the environmental interest. It is not universal but
clearly you point to something which is of some significance and
everyone acknowledges that.
Q302 Jo Swinson: What do you think
that means for the types of products where there is not that alignment?
You used the example of buying organic food, which is typically
more expensive, or furniture with ethnically sourced timber and
so on. When it is going to cost a customer more and, as you say,
there is this committed group of 18% who may well make that decision,
how can these labels reach out to the wider mass of the other
50-plus per cent who might be waiting to be convinced but this
price issue might mean that those labels never really get mass
appeal?
Joan Ruddock: We need to acknowledge
first of all that some people do not have enough money to be able
to make a choice other than they must spend as little as possible,
and there is nothing to be said against that, that is a situation
in which many people find themselves. But if people do have choices
then there are other factors and the other factors that are also
at the top of the table of behaviour change and influence are
those which are concerned with personal health and a degree of
self-interest. It is putting labels in context again. For example,
if they receive many messages about their personal health and
how it could be adversely affected by whatever then they are more
likely to make choices on the basis of using that information
and they will do that, in many cases even if the product costs
more, and that is why we have seen a shift to organics by people
who are paying a premium in order to make choices for organic
food. We have also seen this—I was surprised to learn this,
I have to say—in areas like paint where I would have thought
that telling people about volatile organic compounds was not a
message that had been conveyed to the population at large, but
the evidence suggests that there has been a shift in behaviour
and once people see a label that indicates something which they
believe to have a degree of danger in it then they are making
choices in areas like paints. All we can deduce from so much of
this work is that this is a very complicated field and it is not
a case of one-size-fits-all.
Q303 Jo Swinson: Given that, what
role do you think Defra has in managing and co-ordinating the
environmental labelling? Would you see it characterised as taking
a leadership role or more behind the scenes?
Joan Ruddock: Again, I think it is both.
In terms of our public facing work, our websites, the directgov
website that will lead people into an examination of environmental
standards, behaviours and so on, clearly we have got a leadership
role. One of the things that we have been doing with our Act on
CO2 campaign has demonstrated to us is that people say, "I
will if you will. Government ought to lead". In some of these
areas leadership by government is seen to be necessary. Equally,
there are areas where people are more than happy to trust a third
party organisation, and I mentioned before the Forest Stewardship
Council. It is not always that government has to lead, there are
other trusted bodies out there that can equally lead in other
cases. Where that is the case the role of Defra is often to endorse
third party and voluntary efforts and sometimes often to encourage
them behind the scenes.
Q304 Jo Swinson: We took some evidence
from Marks & Spencer who suggested that the Government should
set up a stakeholder advisory group to identify where there are
gaps in sustainability labelling and where labels that currently
exist could be made better. Do you think that is a good idea?
Does the Government do any of that analysis to find the gaps already?
Joan Ruddock: I think, if I may, I will
ask either of my officials if they are aware of any work on gap
finding going on.
Mr Ryder: There has been work done in
the past through the Committee on Consumer Products in the Environment
which had a five or six year remit to go into this area. Its emphasis
was more on finding some key priority areas where perhaps the
Government should push for more co-ordination, for example taking
the energy label principles and applying them in big areas like
motor vehicles and home energy ratings. There is a priority that
we have given to that kind of analysis, the opportunities for
pushing home a big message about certain kinds of rating. We have
not done any finer analysis of labelling detailed environmental
impacts spread across the board.
Q305 Jo Swinson: You say that there
was a committee that identified the key priority areas, which
a few years ago would have been the big ones that you outlined,
but there has not been any follow-up to say, "Now we have
done those areas, which are the next priority areas?"
Mr Ryder: The link is with the way that
our product policy work has moved on and what we are doing now
in terms of product roadmaps. As part of the product materials
work within Defra we have identified 10 pilot areas where we are
trying to take a comprehensive look at the impact of some big
hitting product areas and then to try and map the most likely
effective interventions that could bring about improvement. It
could be that labelling options are a part of that picture but
not necessarily so, it will vary between the categories.
Q306 Jo Swinson: Minister, you mentioned
earlier that consumers have said in various studies that they
want more information and welcome this. Are you confident that
the Government is doing enough to drive the labelling agenda where
it would be helpful?
Joan Ruddock: Yes, I think so. We have
also got to remember that in some fields it is the European Union
which is the lead on this, so we constantly work with them, and
on the ecolabelling scheme, for example, which is currently under
revision we have been asking for that to be made a better scheme
more closely aligned with the market. What we know about that
particular scheme from our own experience is that it is probably
not all that well-known in this country, but the work that goes
on and the fact that it has got to be independently accredited
is tremendously important in driving forward environmental standards
in products. As I see it, we are working on so many different
fronts that relate to labelling that I am satisfied we are doing
a lot of very, very important work and we are not completely focused
on labelling because we do notsee labelling as being the only
answer, it is only a small part of the answer to driving forward
environmental standards.
Q307 Jo Swinson: Does Defra put pressure
on retailers and producers to use environmental labelling, or
do you see that as perhaps something that happens within the market
driven by competition?
Joan Ruddock: It is both. The important
thing is that we have very good relationships on a huge variety
of fronts with manufacturers and retailers. If you think about
the lighting initiative and the move to low-energy light bulbs,
that is a classic example of where retailers are pushing the boat
out all the time, they have a voluntary agreement with us, but
the Government has always been in there, we are dealing with the
EU but at the same time saying let us get ahead of the EU, and
that is the way it works across many, many fronts simultaneously.
Q308 Jo Swinson: Could you tell us
what role Defra takes in setting standards and regulating the
various labelling schemes that do exist?
Joan Ruddock: In terms of our actual
responsibilities in setting standards and advising business, for
example, first of all we have got direct responsibilities which
are for the EU energy label and the EU ecolabel, and there we
have formal responsibilities and those are obviously carried out,
but we also advise business in terms of the Code of Practice for
Green Claims. As I indicated earlier, we do a great deal of work
advising consumers. We get involved in the development of new
standards and frameworks which could support better product information.
As I have indicated already, we have got a lot of material available
on the web to explain to people and so on and so forth. We are
engaged in a very wide range of activity already but we are constantly
alive to the need to move forward. As I said earlier again, sorry
to repeat myself but in answering you comprehensively I have to
say that the major new work is the work that I spoke about in
trying to find some generic standards in relation to food production.
Q309 Jo Swinson: On the green claims
code are you happy that producers and retailers are actually abiding
by the green claims code? What sanctions do you have if they are
not and consumers are effectively being misled?
Joan Ruddock: You will probably appreciate
that I have been in this job for six months so I have not got
a perspective on that particular question and again I will ask
whether Bob or Dominic have something to say on that?
Mr Ryder: The code was introduced at
a time when poor environment claims were more common and in fact
by the time the code came out the worst had actually peaked. In
the late Nineties the code was a first attempt to produce the
baseline standards to the market, and it actually seemed to have
quite a quick effect. By the time we reissued the code in early
2000 our survey showed that the quality of claims had improved
on average, poor claims were disappearing and the standard was
generally improving. It identified some hotspots, some particular
sector and product areas, where problems were still persisting,
and the way we tried to respond to that was to develop some guidance
on those particular product areas and the kind of information
that could be conveyed without giving any misleading impressions.
That seems to have worked to quite a considerable extent; it is
very rare that we actually receive directly any complaints on
`on-pack' product claims; there is an on-going problem at a fairly
low level on media advertising relating to products, which the
Advertising Standards Authority picks up, but they use really
quite similar principles to those in the green claims code.
Q310 Jo Swinson: You mentioned that
there was a range in quality of the labels; are you satisfied
that Defra does have adequate powers to deal with it where there
is low quality and the standards of transparency and the label
doing what it says it does are not being met?
Joan Ruddock: Again, I do not think this
is a question of Defra having the powers because the claims either
meet international standards and have third party accreditation
or they are claims which the manufacturers are making themselves.
Bob Ryder has just explained what the history of this is and how
we think this has been improved actually over a period of time,
and of course there is the Advertising Standards Authority who
police a certain amount of this as well. I do not think I can
really add anything more to that.
Q311 Jo Swinson: There is just one
final question from me which may be before your time so it might
be that your officials will know the answer. The shopper's guide
that was produced, which I do not have my copy of here today,
obviously has a wide range of labels in it. How did you decide
which labels to include in the shoppers' guide; what were the
criteria for that?
Joan Ruddock: I was simply advised on
that and the advice I was given was that these were the biggest
and most popular ones and because they were appearing most they
became the most significant labels and therefore to explain what
each one meant was the whole purpose of that very nice and handy
little leaflet. As I said earlier, there is a great deal more
detailed information available through websites and that will
constantly increase.
Mr Ryder: Perhaps I could add to what
the Minister has said. The majority of those commonly seen labels,
described in that little leaflet and on-line are also ones where
there are fairly well-established ground rules or forms of accreditation
backing the label up, so in a sense we were both informing about
what the label stood for but also promoting to a certain extent
the fact that they were reliable and could be trusted. There is
a very small section of the shoppers' guide which is a health
warning about claims that are not backed up or verifiable, or
some claims which look like environmental symbols but are not
in fact.
Q312 Martin Horwood: Can I quickly
ask before I get on to my main question, is your personal support
for organics going to be reflected in the environmental standards
you are setting for farmers?
Joan Ruddock: My personal support for
organics is indeed personal and was a reply to a personal question,
and therefore must not be taken as in any way influencing government
policy.
Q313 Martin Horwood: I am very surprised
about that; I think you should press the point. If I may say,
I think you are absolutely right to support organics and you are
in a unique position to do so.
Joan Ruddock: When it comes to working
with the farmers it is one of my colleagues who has that very
pleasant duty and not myself.
Q314 Martin Horwood: You should press
the point. M&S gave evidence to us which was very interesting.
They said they considered very complicated labelling within their
store to try and emphasise their environmental credentials, but
in the end they said the message from that main stream of consumers
was "Too complex, guys. Ten minutes in your store. Please
do it for me." The Sustainable Development Commission and
the National Consumer Council have come to more or less the same
conclusion for consumers as a whole, that what M&S call "choice
editing" might be a useful goal for government to do. M&S
have taken non-energy efficient light bulbs off the shelves, battery
eggs, non-Fairtrade coffee; could you not be a bit more brutal
in regulating out the environmentally and ethically unfriendly
products?
Joan Ruddock: First of all can I just
say that we very much share the sentiments that were expressed
by Marks & Spencer and we equally know that because of the
many, many factors involved in driving up energy efficiency or
driving down carbon emissions it would be very difficult to reflect
all of the things we want to do, aiming for our environmental
goals all the time, aiming for outcomes all the time, it would
be very difficult to reflect all of that in a single, simple label.
We agree, and that is why I have prefaced my remarks so often
this afternoon by saying it is just one part of a solution. We
believe that choice editing is a very significant way forward
and we ourselves are working on that a great deal. We have mentioned
the lighting initiative already, but we have many other product
streams where Defra is working with manufacturers, with retailers,
to see how we can ensure that the market does offer better choices
to the public. All the work I described earlier, how we work with
the supply chain, how the work is done with the supply chain and
the analysis that is done to see what the carbon footprint is,
as that work goes on we are able then to inform ourselves, all
of us together, that, for example, if you take set-top boxes—a
very, very important commodity today—it is possible to very
significantly reduce the energy consumption of set-top boxes,
so we have an initiative on set-top boxes, on standby buttons.
Q315 Martin Horwood: The point made
by the Sustainable Development Commission and the National Consumer
Council was that most consumers would just hope that all the products
they have to choose from will meet good environmental and ethical
standards, so it is not just promoting the best, which is what
you seem to be talking about.
Joan Ruddock: I have not quite finished.
I want to try and give you some concrete examples, so you look
at issues like those two and what you say is because there is
a complete spectrum in terms of energy consumption how can we
come to an agreement that, for example, those at the lower end
are no longer produced? At the moment we are working with voluntary
initiatives and agreements and so on and so forth; it is possible
to legislate but with legislation you would be talking about European-wide
legislation, so if we can get voluntary agreements on products
we can make more progress. The industry is up for it and is working
well with us, and the end result of that is not that there will
not still be a range, because you have got competition issues
and people will want, to a degree, to keep a range of prices,
but the average of the fleet of whatever products you are talking
about will be at a better level in terms of energy efficiency,
and that is what this detailed work that is being done by Defra
at the moment is leading to, and where we are getting extremely
good co-operation. There are other initiatives which are European-wide,
proposals such as keeping standby down to one watt, which again
are being worked on internationally, so there is a huge amount
of this work that can be done, with the aim that you have described.
Q316 Martin Horwood: Just on the
EU, as long as you are delivering a level playing field for all
products and saying whoever the manufacturer is and whatever the
source of the product, this is the standard below which no product
on the shelves should fall, you do not need an EU-wide agreement
for that, do you? As long as it is a level playing field, surely
that is right.
Joan Ruddock: We will have a quick think
about that; I thought we did, but maybe I am wrong.[20]
What I would say to you is of course you have to remember that
your manufacturers and your retailers are now increasingly European-wide,
so they do not particularly want to work and certainly they do
not want to face legislation in a single country because that
is obviously problematic, but they are happy enough to progress
these voluntary agreements.
Q317 Martin Horwood: It is great
that you are pursuing this voluntary line and working with the
industries involved, but would it not actually be a bigger incentive
to them if you just looked like a bit of a scarier regulator,
or even if you were trying to encourage scarier regulation at
European level to try and shift them to more environmentally friendly
products faster?
Joan Ruddock: Not necessarily.
They know and we know that legislation, whether it is European-wide
or whether it can be done on a national basis, is always an option
and to a degree things are often pursued in parallel which is
what is happening with light bulbs, that will be legislated for
at a European level, but we have got our own initiative which
is actually progressing faster, so it is not necessarily that
the regulatory path produces a faster result, but we never rule
that out. We are the first country to set ourselves this absolute
limit on emissions; once we have got that in place clearly we
have got to consider all the possible tools to drive down energy
consumption.
Q318 Martin Horwood: Another area
where you seem pretty reluctant to regulate is with the labels
themselves where you have almost taken a market-led approach.
You said in your memo, "As with brands generally the promotion
of different schemes is a matter for label owners". I have
a background in brand marketing and brands are about competitive
advantage and positioning, but surely allowing labels to compete
actually defeats the object in this case because the whole point
of having good consumer power in this area is that the labels
are consistent across all products and therefore consumers can
make a choice based on consistent labelling. If you allow competition
between labels, surely that defeats the object, does it not?
Joan Ruddock: Again I would say not necessarily
because some of the labelling is produced by people who have the
expertise for their own particular stores and operations and have
their own following in terms of customers, so it is not always
the case that if we as government had to think up something we
would end up in a better place than some of the initiatives that
have been taken. Some of you might have heard this this morning
in relation to food labelling for health reasons; there we have
seen three major systems developed over the period of time and
the government has now become very clear that what we think would
be the best way forward, and we are actually saying we need to
have one system and everybody adopting it, and that will be better
for consumers. We are certainly nowhere near such a point; in
fact at the moment it is not obvious that we could ever come to
such a point if we wanted to take all environmental factors into
account.
Q319 Martin Horwood: Would you at
least go as far as endorsing certain labels and not others? There
is an increasing proliferation now of Fairtrade labels, or at
least two mainstream schemes and possibly others that look as
though they might be something to do with Fairtrade. Would you
consider endorsing some labels and refusing endorsement for others?
Would that not increase consumer trust?
Joan Ruddock: That is a moot point, but
I have already described the extent to which we feel we can give
the information which does amount to saying, for example, with
the Energy Saving Trust, that is becoming or probably has become
a trusted labeller and we very much promote that energy saving
label, so there is a degree of promotion, there is a degree of
support and encouragement that we give, and we will do that where
we think we are getting the best outcomes.
20 Note by witness: The legal position on applying
mandatory environmental standards on products at a national level
is complex, particularly in relation to international regimes
on barriers to trade. In the context of the kind of energy-using
products being discussed here, the fact that there is now frameworklegislation
in place at EU level, with formal processes already under way
for determining new standards in many of the product areas, means
there would indeed be constraints on the scope for regulation
at a national level, as well as the issues of practicality. Back
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