Letter from Lord Geddes, Chairman of Sub-Committee
B, to Richard Page, MP, Parliamentary Under-Secretary of State
for Small Businesses, Industry and Energy
12345/96 - Draft Directive on marking of packaging
and on the establishment of a conformity assessment procedure
for packaging The above proposal was considered today
by Sub-Committee B, to whom it was sifted for scrutiny.
The Sub-Committee noted that the Commission's proposal involved
the establishment of new symbols to designate reusable and recyclable
packaging. While use of these symbols would be voluntary, Member
States would be required to prohibit the use of existing symbols,
including those that are widely used and recognised at present
such as the "Mobius loop" symbol described in your EM.
We would be interested to know whether serious consideration
was given to the possibility of harmonising the use of existing
symbols rather than introducing new ones. The Commission says
that existing symbols are often privately owned and that "it
is uncertain whether the EC would obtain the possibility to introduce
them generally" (page 5, paragraph 5), but we would welcome
clarification of whether there was found to be a serious problem
of ownership in relation to the "Mobius loop" symbol.
We would urge the Government to pursue this point with the Commission,
whose proposal risks undermining public awareness of and interest
in reuse and recycling, contrary to its stated aim.
The Sub-Committee was also struck by the wide variation in
the expected costs to industry of the proposed conformity assessment
procedure, depending on whether this is to be applied to individual
items or on a generic basis. We would be most interested to know
whether you have obtained clarification on this point from the
Commission.
We shall maintain the scrutiny reserve for the time being,
pending your reply.
20 February 1997
Letter from Richard Page MP Parliamentary Under Secretary
of State for Small Business, Industry and Energy, Department
of Trade and Industry, to Lord Geddes, Chairman of Sub-Committee
B
Thank you for your letter of 20 February concerning the
above proposal. I note the questions which the scrutiny committee
have raised and hope that my response will clarify the situation.
The two new symbols which are contained within this proposed
Directive would, if adopted, represent the introduction of an
entirely new system of marking. The Commission, in consultation
with Member States, considered harmonising existing symbols in
the early drafting stages, but were concerned about the large
number of existing markings in the Member States, and the degree
of consumer confusion as to their meaning. In consideration of
this, the Commission proposed to opt for the introduction of an
entirely new system of marking which would enable conformity
to be established on a neutral basis.
As part of the formulation of this proposal, discussions
were held between the current owners of the "mobius loop",
the European Portable Battery Association, and DGXI over the possibility
of using this symbol. The main issue does not appear to be related
to ownership of the symbol, but a lack of understanding, on behalf
of the consumers, as to the meaning of the loop, where it is
applied in different applications meaning either recycled or
recyclable. This has been highlighted as a problem area in the
current International Standards Organisation (ISO) discussions.
In response to your question on the proposed conformity assessment
procedure, I can confirm that my Department has been in contact
with the Commission to try to obtain clarification as to whether
it is proposed to apply the assessment at individual item or
generic product level. The Commission recognise that further
clarification is needed on this point, and have indicated that
this will be included in the negotiations on the proposed Directive
once they begin.
3 March 1997
Letter from Lord Geddes, Chairman of Sub-Committee
to Richard Page, MP, Parliamentary Under-Secretary of State for
Small Businesses, Industry and Energy, Department of Trade and
Industry
Thank you for your letter of 3 March in reply to mine of
20 February.
The Sub-Committee which considered your letter at its meeting
this morning, was grateful for the clarification you were able
to provide of the background to the Commission's proposals.
You say that the obstacle to employing the "Mobius
loop" symbol as a standard is more to do with public confusion
as to its meaning than to problems of legal ownership, but you
do not say what prospects there are for agreement on the use
of this symbol as a world standard for either recycled or recyclable
material. We would be interested to know what the Government's
position in the ISO discussions is and whether they would prefer
the Community to await the outcome of those ISO discussions before
adopting its own, possibly incompatible, scheme.
You also say you have sought clarification of whether the
proposed conformity assessment procedure is intended to be applied
on a generic or on an individual basis. We would urge you to press
the Commission on this point, to ensure that the very much higher
costs to industry of individual assessment can be avoided.
This letter lifts the scrutiny reserve. I would be grateful
if you could let me know in due course the outcome of negotiations,
both in the Community and in the ISO.
20 March 1997
Letter from Richard Page, MP, Parliamentary Under Secretary
of State for Small Business, Industry and Energy, Department
of Trade and Industry to Lord Geddes, Chairman of Sub-Committee
B
Thank you for your letter of 20 March concerning the above
proposal. I am pleased to hear that my response of the 3 March
has clarified the background to the Commissions's proposals, and
that the scrutiny reserve has been lifted.
The group within the International Standards Organisation
(ISO) who are discussing Environmental Labelling, is made up
of over 40 international technical experts, who represent industry
interests. Whilst there is no direct Government involvement in
the discussions, UK industry representatives are members of the
group. At the last meeting, which was held in San Francisco in
January, it was clear that there were still outstanding differences
in approach to the use of the Mobius Loop. The discussion has
polarised between the North Americans and the Europeans, with
the North Americans (USA and Canada) wanting the Mobius Loop to
indicate that the product or packaging contains recycled material,
and the Europeans (heavily influenced by the packaging industry)
wanting the loop to indicate that a product or packaging is recyclable.
Since the January meeting I am advised that there have been
further consultations with aim of producing draft documents for
discussion at the next ISO meeting in Japan at the end of April.
It is impossible to foresee the outcome of these discussions
at this point in time. It remains a possibility that the debate
within ISO may continue for some considerable time in the future.
7 April 1997
