20 Information on environmental performance
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8310/13
COM(13) 196
| Commission Communication: Building the Single Market for Green Products — Facilitating better information on the environmental performance of products and organisations
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| Legal base | —
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| Document originated | 9 April 2013
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| Deposited in Parliament | 12 April 2013
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| Department | Environment, Food and Rural Affairs
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| Basis of consideration | EM of 22 April 2013
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| Previous Committee Report | None
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| Discussion in Council | No date set
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| Committee's assessment | Politically important
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| Committee's decision | Cleared
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Background
20.1 The Commission says that, although the Resource Efficiency
Roadmap[38] set ambitious
milestones for providing incentives to choose the most resource-efficient
products through appropriate price signals and clear environmental
information, the market uptake of such products is currently low,
despite the capacity available to produce them and increasing
demand from consumers. It adds that many of the barriers stem
from ambiguity as to what constitutes a truly "green"
product or organisation, and it has therefore put forward this
Communication in order to remove this ambiguity by introducing
two methods for measurement and a set of principles for communicating
environmental performance.
The current document
20.2 After recalling the international background (including
the United Nations Conference on Sustainable Development (Rio+20)),
and the environmental and economic benefits of green products
and organisations, the Commission describes the main problems
which it is seeking to tackle as being:
- The number of different methods for measuring and benchmarking
environmental performance, where it says that the lack of comparability
between them is hindering competition on environmental performance.
In particular, it highlights lack of completeness as the biggest
failing of existing methods, saying that these can give misleading
results if they do not look at the whole product lifecycle and
at all environmental impacts, and it also identifies problems
with "burden shifting" between lifecycle stages (for
example, a product may be very efficient in use, but have significant
waste impacts at end of life) or in the use of environmental indicators
(for example, an energy efficient product may also contain hazardous
materials).
- The costs for businesses in assessing products
against a number of different footprint methods for different
countries and sectors, which it says may also be an obstacle to
free trade of products across national borders.
- Europeans consumer attitudes, where a survey
suggests that 75% are ready to buy green products, but only 17%
had done so in the preceding month, for reasons which include
a lack of trust in environmental information, limited availability
at affordable products, and difficulties in comparing products
and making informed choices.
EU POLICY RESPONSE
20.3 The Commission says that the general objective
of EU action in this area should be to reduce uncertainty by improving
the availability of clear, reliable and comparable information
on the environmental performance of products and organisations,
and it proposes a number of steps.
New footprinting methods
20.4 The Commission introduces two new environmental
footprinting methods — the
Product Environmental Footprint (PEF) and Organisational Environmental
Footprint (OEF) —
which it describes as science-based and comprehensive. It says
that these will eventually support comparability between products
and organisations, and that they will introduce several important
improvements on existing methods, including a clear identification
of potential environmental impact categories which need to be
looked at in performing a life cycle assessment; a requirement
to quantify data quality; setting minimum data quality requirements;
and clearer technical instructions for addressing critical aspects
of life cycle assessment.
20.5 The Commission says that methods will be
further tested and improved by the development of simplified rules
for specific product groups and sectors, and assessed to define
whether they can be readily applied by companies, including small
businesses, and by policy makers. This will be accompanied by
the development of a benchmark product for each category, which
will have to be continuously adapted and reviewed in line with
technological developments, and used to compare the performance
of other products on the market, with the comparison being communicated
to consumers.
Testing the methods
20.6 The Commission proposes to organise a three-year
testing phase to:
- set up and validate the process
of developing the simplified rules for specific product groups
and sectors, including the development of benchmarks;
- simplify the footprinting process, especially
for small and medium sized businesses;
- test different compliance and verification systems;
and
- test different approaches for business-to-consumer
and business-to-business communication.
20.7 It says that it is also open to evaluating
alternative footprinting methods and approaches.
Green claims
20.8 The Commission will produce further guidance
to promote the use of clear, accurate and relevant environmental
claims in marketing and advertising, where it recommends six principles
— transparency, availability and accessibility, reliability,
completeness, comparability and clarity — to be applied
when communicating environmental performance of products and organisations.
Evaluation and future policy
20.9 The Commission proposes to evaluate the
pilot before deciding on the next steps, including whether the
methods and benchmarks can be applied in policy tools. However,
it is looking to incorporate these methods into existing policy
tools, including the Eco-Management and Audit Scheme, Green Public
Procurement and the EU Ecolabel.
Global context
20.10 The Communication identifies the range
of environmental footprinting activity in many other countries
outside the EU. It suggests that there will probably be further
international activity to develop methods and that the Commission
will work with key trading partners to encourage a more co-ordinated
approach.
Commission Recommendation
20.11 The Communication also includes a Commission
Recommendation encouraging Member States and the private sector
to use these new environmental footprinting methods.
20.12 It suggests that Member States should
use them for products and organisations in voluntary policies,
and in relevant national schemes involving measurement or communication
of environmental performance of products or organisations; make
efforts to increase the availability of high quality lifecycle
data; provide assistance and tools for small and medium sized
enterprises; and encourage use of the organisational footprinting
method for measuring and communicating performance of organisations.
20.13 The Recommendation suggests that companies
should use the methods to measure and communicate performance
of their products and organisations; contribute to the review
of public databases and populate them with data; and consider
providing support to small businesses in their supply chains.
Trade associations are asked to promote the methods amongst
their membership; contribute to the review of databases; and provide
tools and expertise to help small business members. The financial
community is asked to promote the use of environmental performance
information based on these methods in its assessment of financial
risk, and in its assessment of sustainability indices.
20.14 The Recommendation also suggests that schemes
for measuring and communicating environmental performance (for
example environmental certification and labelling schemes) should
use the Commission's footprinting methods as a reference method,
and that footprinting studies which are to be used for communication
purposes should be verified to check they meet the necessary requirements,
so as to ensure the results are credible, and are conducted in
a proportionate way.
20.15 Finally, Member States are invited to inform
the Commission annually of actions taken in the light of this
recommendation, but there is no obligation to do so.
The Government's view
20.16 In his Explanatory Memorandum of 22 April
2013, the Parliamentary Under-Secretary at the Department for
Environment, Food and Rural Affairs (Lord de Mauley) says that,
in general, the UK supports the Commission's objective of encouraging
a greater uptake of resource-efficient products and greener business
practices, but that both the Government and businesses have a
number of concerns, relating mainly to the over-complex nature
of the proposed methods (although he points out that there is
scope to address these during the proposed testing phase, which
he sees as an essential part of the process).
20.17 In particular:
- Although the Government agrees
that it is important to consider all life cycle stages and environmental
impacts initially, it does not believe that it is necessary to
carry out detailed whole life cycle analyses of all environmental
impacts for all products and organisations, and is seeking through
its Product Sustainability Forum to identify a shortlist of priority
products and impacts, towards which action can be targeted;
- Assessing products against a number of different
methods will give rise to costs, but the Commission has not given
any indication of what these might be;
- The Government hopes that further testing and
improvement will reduce the complexity of the new footprinting
methods, and make them more accessible to business;
- The Government is not convinced of the need for
benchmark products, and observes that there is no discussion of
how these would be developed, or how this work would be funded.
20.18 The Minister also says that, although the
Government is supportive of the principles in the Commission Recommendation
as it affects Member States, further consideration needs to be
given to the various aspects addressed to companies and private
organisations.
Conclusion
20.19 Although the underlying aim of improving
information on environmental performance is clear enough, the
methods which the Commission has suggested should be used to achieve
this are complex and detailed, and, as the Government has pointed
out, much will depend upon the proposed three-year testing phase.
Having said that, the Commission Recommendation is non-binding,
and participation by companies and others will be voluntary.
Consequently, whilst it will be interesting to see how the thinking
outlined in this document develops in the light of experience,
we do not think it raises any issues which need to be considered
further at this stage. We are therefore clearing it.
38 (33173) 14632/11: see HC 428-xlii (2010-12), chapter
17 (22 November 2011). Back
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