Environmental Management Systems inadequate tools in environmental product policy - EEB

In a joint position paper, ANEC – the European consumer voice in standardisation and the European Environmental Bureau express their concerns with respect to Environmental Managements System standards such as EMAS and ISO 14000. These have so far been given an important role in the European Commission proposals on Eco design rules and Integrated Product Policy (IPP). ANEC and EEB urge the Commission to critically review EMS Standards with respect to their content and application, before using them to serve as instruments to implement eco-design schemes such as Integrated Product Policy or Energy using products (EuP).

EMS standards, like the ISO 14000 series and the EU's Eco-Management and Audit Scheme (EMAS), provide a set of management tools to determine the environmental aspects of an organisation's activities. But having an EMS does not guarantee that a company's environmental performance is superior to that of its competitors nor that their products have significantly reduced environmental impacts. Neither the ISO 14000 nor the EMAS provides specific environmental targets or describes ways of achieving them. Instead, they provide generic frameworks and general principles that can be applied to any organisation of any size, in any sector.

The ANEC–EEB position paper outlines concerns that all EMS standards are based on the idea that the setting of environmental performance levels is left to the discretion of industry rather than being based on a public debate and democratic decision making. Under no circumstances should the EMS approach be applied as a substitute for product specifications.The joint ANEC-EEB paper also warns that the demands currently set by EMSs are so undemanding that they can easily be abused by companies, who are under little obligation to radically alter their internal policies.

"It would be reckless for the Commission to try to apply these standards to products when they clearly have not proved their worth," said ANEC Secretary General Gottlobe Fabisch. "At the moment, the EMS standards are so weak, almost anyone can apply them and claim to be acting in an environmentally friendly way without actually changing much in their business practices."

EEB Secretary-General John Hontelez said the Commission needed to immediately suspend the process linking EMS standards and products. "The current requirements of EMS are feeble and contain no obligation to meet concrete targets in environmental improvements," he said. "Unless the Commission reviews the entire process, weak EMS standards will be used as a product policy alibi by many businesses."

ANEC and EEB conclude that a series of measures should be considered to make Environmental Management System Standards serving societal and environmental needs. They include:

- Continual improvement by measurable reduction of environmental burdens and resource consumption; obligation of key environmental indicators which allow comparisons between different organisations; minimum performance levels based of the state-of-the-art and detailed reporting requirements.

- Furthermore companies shall not be rewarded for the mere implementation of an EMS. Instead, incentives (e.g. tax reduction) should be linked exclusively to continuous, measurable improvement of the environmental performance and organisations which have obtained an EMS registration shall be subject to evaluation studies.

The European Environmental Bureau (EEB) is a federation of 135 environmental citizens' organisations based in all EU Member States and most Candidate Countries, as well as in some neighbouring countries. These organisations range from local and national, to European and international. The aim of the EEB is to protect and improve the environment of Europe and to enable the citizens of Europe to play their part in achieving that goal.