Eco-design proposals leading Product Policy astray? - EEB

This proposal, the first Commission initiative of its kind on Integrated Product Policy, is currently in a vacuum, with no clearly defined and quantified environmental objectives. Indeed, similarly to previous versions of Commission proposals on this material, the essential ingredients for success appear to be missing - most notably what environmental objectives the proposal aims to achieve for which equipment and with what stakeholder involvement.

The current EuE proposal, an attempt to move forward the much-criticised Commission efforts for a directive on EEE (impact on the environment of Electrical and Electronic Equipment), merges the previous EEE proposals with ongoing work on Energy Efficiency Requirements for End-use Equipment. Whilst this proposal brings some positive elements to the table for discussion - such as mechanisms that could forsee minimum performance requirements (aka standards) for some products - the global setting of these mechanisms is undermined by the lack of concrete objectives and the failure to define robust stakeholder procedures.

"The way the current proposal reads the objectives are explicitly and only based on the free movement of goods, with no mention of achieving a higher degree of environmental protection. The complete absence of any concrete environmental objectives in the legal text, coupled with a lack of clearly defined and credible mechanisms to allow an appropriate participation of stakeholders - means that, as it stands, this new package does not represent much of a step foward " says Roberto Ferrigno, EU Policy Director at the EEB. "In an effort to provide a concrete example of what objectives we are talking about we have provided the Commission with a worked example of our recommendations for a framework of environmental objectives."

In addition to these concerns, the EEB has identified several other essential ingredients that make this proposal unworkable. Among these is the ambiguous, double-track procedure whereby the setting of product requirements could be done through harmonised standards or through the use of environmental management systems or other mechanisms of 'internal design control'. This implies that each producer has free rein to decide on which aspects and to which degree it wishes to eco-design. "Not only does this appear to be incompatible with a legal basis of harmonisation, but furthermore, with a verification system essentially based on self-declaration, we do not feel that this will provide sufficient drive to achieve environmentally relevant changes in product design OR enable any kind of co-ordination of data and therefore evaluation of progress" commented Melissa Shinn, EEB Ecological Product Policy officer.

The European Environmental Bureau is a federation of more than 130 environmental citizens' organisations based in all EU Member States and most Accession Countries, as well as in a few neighbouring countries.