The Informal European IPP Network Workshop · product life cycle covered The NOKIA product information system covers the entire life-cycle (cradle to grave) of the mobile phone although

The Informal European IPP Network Workshop on Product Information Workshop Report Bern, 17-18 January 2005

Informal European IPP Network

The Informal European IPP Network Workshop on Product Information

Bern, 17-18 January 2005

Workshop Report

February 2005

Prepared by: Robert Nuij (ERM), Christoph Rentsch (SAEFL) and Bob Ryder (DEFRA)

EUROPEAN INFORMAL IPP NETWORK WORKSHOP ON PRODUCT INFORMATION

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CONTENTS

1 INTRODUCTION 4

1.1 CONTEXT 4 1.2 SETTING THE SCENE 5 1.3 THE BERN IPP WORKSHOP 5

2 EXISTING INFORMATION SYSTEMS USED IN THE PRODUCT SUPPLY CHAIN 7

2.1 MOBILE PHONES 7 2.2 TEXTILES 8 2.3 METAL INDUSTRIES 10 2.4 SOME INITIAL OBSERVATIONS 11

3 ANALYSIS, SYNTHESIS AND CONCLUSIONS 13

3.1 DISCUSSION 14 3.2 CONCLUSIONS 18

ANNEX A: WORKSHOP AGENDA 18

ANNEX B: LIST OF PARTICIPANTS 21


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1 INTRODUCTION

1.1 CONTEXT

In the second half of the 1990s, the European Commission started the development of an environmental policy framework focused on products; its so-called Integrated Product Policy (IPP). Although some Member States, e.g. Denmark, the Netherlands and Sweden, and other European countries such as Norway and Switzerland had already been focusing on products within their environmental policy developments, this was the first time products were given centre stage at EU level. The European Commission further developed the IPP framework in a Green Paper1 and a subsequent Communication2, which outlined a number of key principles underlying the IPP approach, including:

• Life cycle thinking • Working with the market • Stakeholder involvement • Continuous improvement • A variety of policy instruments Currently, the Commission is undertaking two pilot projects with the aim to demonstrate how IPP could work in practice. Next to this, at the end of 2004 the Commission established two working groups to discuss and find solutions to specific subjects important to the development of IPP. In 2000, the EU Member States (including Norway and Switzerland) established an informal IPP network to discuss and provide input to the ongoing developments at EU level, and to have a platform for exchanging experiences with product policies at national level. In Switzerland, the government decided in 2002 to introduce IPP as an official policy in the context of its Strategy for Sustainable Development3. An implementation plan was established which includes the development of a range of measures to extend the joint responsibility of manufacturers from the use and disposal phases (Extended Producer Responsibility) to the upstream phases in the supply chain (Supply Chain Responsibility).

1 European Commission, Green Paper on Integrated Product Policy (COM(2001) 68 final. Brussels

2 European Commission, Communication from the Commission to the Council and the European Parliament. Integrated Product Policy: Building on Environmental Life-Cycle Thinking (COM(2003) 302 final. Brussels

3 Swiss Federal Council, Sustainable Development Strategy 2002, Bern (downloadable from http://www.are.admin.ch/are/en/nachhaltig/strategie/index.html)


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1.2 SETTING THE SCENE

From the start of the discussions about an EU products policy, it was clear that the availability of good information about the environmental performance of products would be essential for a successful implementation of the IPP framework. Many policy instruments can only be properly developed and applied on the basis of good information about the environmental impacts of products (e.g. eco-labels, energy labels, product standards, etc.). Moreover, many actors can only act on the basis of such information (e.g. product designers, purchasers, consumers, etc.). The Commission has recognised the importance of environmental product information and, as a result, established towards the end of 2004 a working group on ‘product information needs’, with the objective to identify:

1) What information is needed by which stakeholders throughout the supply chain; 2) Which tools exist to fulfil these needs and where there are gaps; and 3) How these gaps could be filled and the demand for environmental information

about products increased. Also the informal IPP network has been discussing, ever since its inception, how an effective framework for environmental product information could be developed at EU level. These efforts have so far resulted in a draft strategy paper entitled: ‘Environmental Product Information: A Framework for Action under Integrated Product Policy in Europe’ which is intended as an input to the new Commission working group mentioned above (please see Annex C for the most recent version of this paper).

1.3 THE BERN IPP WORKSHOP

To inform the further development of this strategy, the Swiss Agency for the Environment, Forests and Landscape decided to organise a workshop, focusing on a specific area of the strategy, i.e. how businesses generate and transmit environmental product information. This workshop, which was held on 17 and 18 January 2005 in Bern, Switzerland aimed at:

• Obtaining a better understanding of what data is generated and how it is transmitted within or between different parts of the supply chain; and

• Identifying what wider lessons could be drawn from this knowledge. These objectives were to be achieved by drawing from examples of existing product information systems in three different sectors (mobile phones, textiles and metal industries) and by analysing the following ‘parameters’:

• Which steps of the product life cycle are covered by the generated information? • What kind of information is generated, by and for whom? • How is information transmitted between the various parts of the product chain? • Where are the boundaries of the product information system? • What is the approach for addressing information gaps? How successful is this? • What improvements could be made to the existing system? Are any next steps

foreseen?


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• What is the most important thing to do in the near future to improve or complete the environmental product information flow?

The workshop was jointly chaired by Christoph Rentsch from the Swiss Agency for the Environment, Forests and Landscape and Bob Ryder from the UK Department for Environment, Food and Rural Affairs. Robert Nuij from Environmental Resources Management Ltd. acted as rapporteur. The agenda and full list of participants can be found in Annexes A and B. The following sections provide an overview of the product sector examples, subsequent discussion and final conclusions.


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2 EXISTING INFORMATION SYSTEMS USED IN THE PRODUCT SUPPLY CHAIN

The first part of the workshop was dedicated to obtaining more insight into existing examples of product-related environmental information systems. This was achieved by having two representatives from each selected product sector present a specific case study. The presentations were followed by a short question and answer session to obtain further clarification or more detailed knowledge of the presented system. The following paragraphs provide an overview of these presentations, in accordance with the parameters identified in section 1.3. The presentation slides can be found on the Commission’s ‘Circa’ web-site1.

2.1 MOBILE PHONES

Presenter and title of presentation

Salla Ahonen, NOKIA Environmental Information in the Mobile Phone Life Cycle

Steps of the product life cycle covered

The NOKIA product information system covers the entire life-cycle (cradle to grave) of the mobile phone although Nokia itself only undertakes assembly.

Kind of information generated and for whom

The system generates a wide range of product-related environmental information, including: • Site-related information on energy use, CO2 emissions, water consumption,

discharges to water, waste and use of Ozone Depleting Substances for final consumers.

• Product eco-declarations based on the ECMA standard for final consumers. • Recycling maps to facilitate recycling for final consumers (where can I get rid of

my old phone?). • Information related to content and location of hazardous substances to

recycling and treatment centres. • Some of this information is also used for Design for Environment purposes.

How is information transmitted

• The information to final consumers is mainly transmitted via the internet. • Sales packages contain references to further information on the web.

Boundaries of the system

There are a number of issues within the current system: • It is still difficult to obtain information from the supply chain, which so far

lacks a standardised approach for gathering information. • The focus on dissemination information via the internet results in lack of access

for many elderly people and those without internet access. • There are issues with the reliability of data coming from the supply chain. • Missing LCA data; e.g. impact data is not available for many substances. • Little feedback from consumers on what kind of information they would like to

obtain. Approach for filling information gaps

• Standardisation for supply chain information is underway via RosettaNet. • Reliability of supply chain information can partly be addressed via product

testing to verify supplier declarations. Possible improvements and next steps

• Information for elderly people and people without internet access could also be disseminated on paper.

• A pilot project has started to use the internet as a database hub for supplier

1 http://forum.europa.eu.int/Public/irc/env/ipp_regmeeting/library


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information (via Rosettanet) which will tie into the existing databases (e.g. Agile, SAP).

Most important improvement step

Ensure the generation and dissemination of environmental product information become part of the standard business procedures.


Grégoire Dumoulin, Fonebak Workshop on Product Information


Fonebak manages the end-of-life phases of mobile phones and infrastructure equipment in the telecommunications industry.


The information system includes; • Environmental reporting (including EMAS verified reports) for authorities • Client reporting (e.g. on return rates) • Re-use and recycling rates to clients and authorities • Information from Fonebak to manufacturers on what not to do in terms of

specifying materials (e.g. no mixed plastics) • Manufacturers discuss with recyclers on technologies and possibilities for

recycling How is information transmitted

Fonebak operates a software-based reporting system covering the entire end-of-life stage from in-store collection boxes to client reporting. This includes reports to manufacturers, retailers, authorities, etc.


• It is sometimes difficult to obtain substance information from manufacturers (depending on the manufacturer).

• Reporting formats are different across the EU which makes reporting a costly and time-consuming affair.

Approach for filling information gaps

The upcoming WEEE Directive might drive better substance disclosure as well as harmonisation of reporting formats

Possible improvements and next steps

As old phones are considered hazardous waste, shipping them takes a lot of time (e.g. waiting for authorisation). It would be far better if they could be shipped as products instead of as waste.


Most important step would be to achieve harmonisation of reporting formats across the EU

2.2 TEXTILES


Conor Andrews, Almedahl-Kinna AB and representing the Swedish Textile and Clothing Industries Association IPP Presentation of Textile Material Produced in Sweden


The system focuses on the production of textiles for sun blinds. This does not cover the raw material production, nor the production of the final product.


Information is mainly generated for authorities and customers and includes: • Integrated Pollution Prevention Control permitting linked reporting to

regulator • Chemicals use for authorisation purposes (KEMI) • Emissions to air and water • Energy use • Environmental Declaration to customers • Advice on recycling technology, i.e. combustion with energy recovery, to

customers How is information transmitted

The following main information formats are used: • Material Safety Data Sheets from the chemical industry • Environmental declaration


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• Environmental reporting to authorities and available on request to customers • Ökotex label for certain products


• For many chemical substances there is no inventory data available • Information gathering will be costly • Safety data sheets are often not complete and it is difficult to obtain this

information from chemical suppliers • Raw material production: no information on chemicals used, energy used,

transport, pollution, waste (most likely not available) • Grey good production: there is information on which chemicals are used

(needed for further production steps) but not on energy used, emissions and waste.


The Swedish textile industry might not be in the position to obtain much of the missing information since it would require many resources and leverage over the supply chain which they currently do not have.


• Create more interest in the environmental declaration among customers • Try to create more interest with final consumers in the environmental

performance of the sun blinds. However, this would have to be achieved via customers.

• Simplify the environmental declaration • Policy guidance would be very useful but only if it would apply across the EU

(even global if possible) • The new REACH policy (Registration, Evaluation and Authorisation of

Chemicals) could provide key incentive for more information Most important improvement step

• Sell environmental ‘image’ of the Swedish textile industry to customers (e.g. public purchasers, private purchasers)


Brigitte Zogg, COOP Switzerland Coop Naturaline. Presentation at the Informal European Network on IPP


Focused on the entire production chain for organic cotton (for the COOP Naturaline product range), from cotton production, to dying and printing.


The system is based on COOP setting strict ecological (and social) criteria for the entire textile chain, including on: • Water consumption and water loads • Use of chemical crop protection agents and fertilisers (organic cultivation) • Use of dyes without toxic heavy metals • Chlorine free bleaching • No formaldehyde finishing (except in exceptional cases) For consumers the information is strongly linked to the Naturaline logo and focused on explaining the underlying system of requirements and controls. This also elaborates on the link with personal health issues.

How is information transmitted

• The supply chain information is verified via independent organisations that check the organic cotton production and the processing plants for ecological and social criteria (e.g. SA8000)

• Communication to final consumers is undertaken via articles, advertisements and public-reportages in magazines, newspapers and on TV. There are also presentations in sales outlets and most information is available online.

• Internally, information is provided via newsletters, the intranet, training and specific events.


COOP guarantees sales for growers and thus has significant leverage over the supply chain. Partners (e.g. growers, dyers) are selected on the basis of their willingness and ability to meet the strict COOP criteria.


There are no major gaps, as the system was build from scratch based on direct partnerships with growers, dyers, etc.

Possible • The aim is to have all Naturaline processing facilities certified to SA 8000.


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improvements and next steps

• Social requirements in agriculture (SA 8000 and the textile codex refer to production)


Improve the offer in the department stores.

2.3 METAL INDUSTRIES


Anna-Sofia Kumlin, IVL Swedish Environmental Research Institute and representing the Swedish Steel Producers Association. Structured Environmental Data within the Swedish Iron and Steel Industry


The system is limited to gate-to-gate information for the Swedish iron and steel industry, and focuses on streamlining information within the individual companies. No information is transmitted between different actors in the chain and the system is not primarily focused on external stakeholders, although it facilitates external reporting.


The following data is covered, mainly for environmental reporting purposes: • Emissions to air • Emissions to water • Energy use • Waste • Raw material and chemical use are not covered by this system but by other

existing systems How is information transmitted

The information is collected within a web-based database which manages the manual input of data, analysis and presentation of data, export of data and the creation of reports.


• So far no efforts have been made to establish harmonisation rules and standard format for reporting

• It has been difficult to obtain management buy-in for the system Approach for filling information gaps

No existing gaps


• Add benchmarking options to document environmental benefits but, more importantly, economic benefits

• Possibly integrate the system with existing business systems (e.g. technical, financial)

• Dissemination of system to other sectors Most important improvement step

•


Curt Henricson, ABB IPP Workshop January 18, Bern Switzerland


ABB is a manufacturer of power and automation technologies including for example motors, drivers, control systems, transformers and instrumentation.


ABB relies heavily on LCA information for: • Environmental assessments from cradle to grave • Comparative studies • To obtain a ‘helicopter view’ on the total environmental impact of products Such information is subsequently used in product development and for generic information to customers (in a marketing context). Moreover, some of this data is also used for sustainability report which has generated significant interest from investors.

How is information

• Suppliers are requested to provide site-specific LCA/LCI data, as well as information related to their environmental and social performance.


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transmitted • Environmental Product Declarations are used to communicate environmental information on ‘commodity’ products.

• LCA data is not used for authority reporting but the underlying data can be used for that purpose.

• The marketing and sales departments use some of this data in a customer specific context, e.g. for comparison between system solutions.


As most of ABB’s products have 99% of their environmental impact in the use phase, for ABB the use of LCA (according to the ISO standards) results in too much focus (e.g. in terms of data gathering) on the manufacturing stage.


Not applicable.


Create an even stronger demand for environmental information from the marketing and sales department. Note that there has been a strong increase in demands from customers for such information on the back of the EU Emission Trading Scheme.


• Governments should ‘practice what they preach’ in that there is still too much focus on price in public purchasing.

• More effort should be put into internalising the cost of environmental impacts • The new Energy-using Products Directive could help drive environmental

performance, not only through product criteria but also via reporting requirements.

2.4 SOME INITIAL OBSERVATIONS

Looking at the six examples outlined above, one can see large differences between the various systems; the scope of the system, the type of information generated, how it is transmitted and possible improvements vary significantly. This is no surprise, as all these systems were set up to address specific concerns, even if they operate in the same product sector. While these differences make it somewhat difficult to come up with an extensive ‘lessons learnt’ list, it is nevertheless possible to make some initial observations based on the presented examples. A first, and obvious, conclusion that can be drawn, is that there is no ‘one size fits all’ solution to the problem of how product-related environmental information should be generated and transmitted within a specific product value chain. The nature of the sector, the market structure, geographical spread, type of environmental impacts, relationships between actors and many other elements, conspire against a blanket approach. Secondly, the position of an actor in the product value chain seems to be a key determinant for the scope for action that actor has in this context. The COOP case study shows that their guaranteeing a market for organic cotton, creates significant leverage over the supply chain, and allows them to set strict performance criteria and information requirements. On the contrary, the Almedahl-Kinna example shows that a small player finds it difficult to exert any pressure on other actors in the chain to provide certain information. Thirdly, while no single solution can apply to all product chains, within a chain there is a clear need for harmonisation or standardisation of information requirements. This is not only necessary for the ability to add and compare information from different actors in the chain, but also to minimise the cost impact any information system will


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have. The Fonebak example shows that different reporting requirements in different European countries create significant additional cost for a player operating across the EU. The same would apply to an electronic component manufacturer who sells its products to different customers, all requesting different information from him. Fourthly, it seems that there is little demand from potential users for environmental product information. This is not only the case for final consumers but also for customers in the product supply chain. Next to this, the various actors in the supply chain seem to have little knowledge about what their customers (business-to-business and final consumers) would like to receive in terms of such information. Finally, the establishment of any product-related environmental information system should ideally be linked to a clear business benefit, for example by in leading to more cost efficient regulatory reporting or resulting in increased sales. When such benefits are missing it becomes difficult to obtain management buy-in for the necessary investments to establish the system in the first place. The ABB example shows that when the marketing and sales department start seeing the benefit of showing potential customers how certain solutions reduce the impact on the environment (as well as the cost for the customer), the demand for environmental information becomes self-sustaining. Of course, regulatory demands for environmental information are strong drivers for business and being in compliance with such requirements will usually benefit a business (e.g. in terms of license to operate, reputation, no fines, etc.).


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3 ANALYSIS, SYNTHESIS AND CONCLUSIONS

3.1 INTRODUCTION

The second part of the workshop was dedicated to further discussions about the presented examples and product information systems in general, with the aim to come to conclusions that could be presented to the formal EC IPP working group on Product Information Needs. This section was kicked off with two, more generic, presentations related to the use of product information systems. Preben Kristensen (Danish Toxicology Centre) presented the results of a study for the Danish EPA, analysing the characteristics of five different product information systems (the EU Eco-label, EPDs, EMAS, MSDS and IPPC reporting) and the barriers and possibilities for a coordinated information system in the EU. This research shows that, since all these systems have been developed, and are managed, separately, there is no, or little, coherence between the demands they put on companies being affected, either voluntarily or obligatory, by these instruments. In itself, this lack of co-ordination stands in the way of establishing efficient information systems with product sectors. The study subsequently makes a number of recommendations for addressing this issue, including:

• The development of an integrated environmental and health information system in the EU;

• The use of EMAS as the underlying management system for all relevant instruments;

• The preparation of an EPD Regulation based on the existing EMAS and Eco-label Regulations;

• The establishment of a common EU LCA framework; • The establishment of a common framework for the verification of information

systems; • The dissemination of relevant guidelines and other documents to all stakeholders

in the product value chain. Robert Nuij (Environmental Resources Management) presented the results of a study for the Alliance for Beverage Cartons and the Environment, evaluating the use of environmental management systems for generating, managing and verifying product-related environmental information related to the beverage carton. This research included a limited stakeholder consultation which showed that information needs tend to follow political priorities and that the format of information needs to be adapted to suit specific target groups. Moreover, stakeholders do see EMS as an acceptable tool to manage product information, provided that key data and information to final consumers would be subject to third party involvement. Furthermore, an EMS review was conducted at six sites which highlighted the fact that environmental data management at each site differs significantly in scope and depth, the EMSs are typically not designed to deliver product-related or LCI data, and that any corporate environmental data management systems exist mainly outside the scope of the certified EMS. The study concluded that, while such systems could be used in a ‘cradle-to-gate’ context and only after significant changes, they would not be


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suitable to address the entire product chain or specific information demands such as those related to the use phase or recycling efforts.

3.2 DISCUSSION

The ensuing discussion tried to identify possible roles for government in driving transparent information flows within product chains. This centred around a number of main themes, including; Creating efficiencies (and avoiding inefficiencies)

As the Danish study shows, various government-driven information requirements on business (whether regulatory or voluntary) are poorly coordinated and this places a significant burden on companies needing to manage different types of information for different purposes. Although this is sometimes unavoidable, there seems to be considerable scope for a more harmonised approach in setting information requirements for business. Moreover, achieving a totally transparent, verifiable information flow in all product chains is impossible to achieve due to inherent complexities of constantly changing global supply chains. However, this is also not really necessary as the focus should be on the main environmental impacts and on the type and level of information stakeholders would like to receive. In this context, it might be necessary to put more effort into understanding the information needs of the various users of information within the product value chain. Linked to this is the observation that governments do not always understand, or take into account, the implications of certain requirements on companies. An illustration of this is provided by the EU Eco-label criteria for textiles. A clothing manufacturer wanting to apply for the label will only be able to show compliance with 6 out of the 27 criteria (i.e. with those criteria directly applicable to his activities). Proof of compliance with the other 21 criteria will have to be obtained from the supply chain, including from polymer producers, spinners, knitters, dyers and fabric traders. Often, the clothing manufacturer is only in contact with one or more fabric traders and does not have any insight into, nor leverage over, the rest of the supply chain. This makes information gathering a time-consuming and onerous exercise. A similar argument can be made in relation to the RoHS Directive, which requires manufacturers of electronic equipment to verify whether their products contain any of the six substances that are restricted by the Directive. This results in an enormous effort along the supply chain to obtain and verify substance information from a potentially large number of suppliers. While this applies to all manufacturers covered by the Directive, thus ensuring a level playing field for regulation (unlike the Eco-label criteria which are voluntary), this ‘hidden’ effort could well constitute one of the biggest impacts of the Directive.


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Mandating and promoting information

Governments can play a very direct role in the promotion of product information via public purchasing. Ongoing developments in Europe show that this could have significant impact, for example through the use of eco-label criteria in procurement. Experience in the United States could also serve as a good example on how public procurement has stimulated demand for information, such as in the building sector. Another way of driving information systems is obliging companies to provide certain information about their products. It might for example be possible to establish legislation that give consumers the right to product-related environmental information. For example, Norway has such legislation whereby consumers can obtain information on request from companies. Ideally, such legislation would have to be enacted at EU level to ensure a level playing field. Moreover, care should be taken to allay industry fears related to confidentiality and interpretation issues. Governments can also indirectly stimulate the provision of environmental information related to products by educating the financial sector on the importance of environmental issues and pressing it to ask for such information, for example related to investment decisions, the granting of loans, etc. However, for this to take place, environmental considerations would have to be linked to economic performance. While some research has shown tentative links between the environmental performance of companies and their stock market value, there is by no means a clear cause-and-effect relationship. Nevertheless, investors and stock exchanges are beginning to recognise the relevance of environmental compliance and performance as a liability and risk management issue, which has led to a number of sustainability indexes such as the FTSE4Good and the Dow Jones Sustainability Index (DJSI). Next to this, the European Union adopted in 2003 a Directive on the rules for annual and consolidate accounts1 which requires the inclusion of “…..where appropriate, non-financial key performance indicators relevant to the particular business, including information relating to environmental and employee matters”. These provisions might also be used to promote environmental and social reporting in business. Another way of promoting information provision by companies is benchmarking of sustainability reporting. The Dutch Ministry of Economic Affairs undertook such an exercise – the Transparency Benchmark – in 2004, which lists the frontrunners and laggards by name. A further initiative was undertaken by the Global Reporting Initiative, which towards the end of 2004 published sustainable reporting guidelines for SMEs, entitled “High 5!”. Setting priorities

One of the often heard comments by business is that government should focus on setting priorities for action. Dutch research shows that this is even more relevant for

1 DIRECTIVE 2003/51/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 18 June 2003 amending Directives 78/660/EEC, 83/349/EEC, 86/635/EEC and 91/674/EEC on the annual and consolidated accounts of certain types of companies, banks and other financial institutions and insurance undertakings (Text with EEA relevance)


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SMEs, as they typically have no time or resources to establish these priorities themselves (e.g. via doing an LCA). This result has made the Dutch Government reconsider the orientation of its national eco-label scheme (the Milieukeur) from a type I eco-label to a ‘parameter platform’ that would provide directions to SMEs and others on what the key issues in a specific product sector are. In this context, it was noted that NGOs might have a role in driving product information and setting priorities, although final responsibility should lie with governments. Moreover, for most product sectors, such priorities would have to be established at EU level to ensure a level playing field. Next to setting priorities, governments might need to give more attention to clear communication to industry about which priorities it should address, as well as being more disciplined about following its own priorities (e.g. in public purchasing or legislative developments). Also important is the need to ensure longer term predictability of priorities and avoid changing the political focus too often. In this context, it should be understood that from a business perspective priorities cannot only reflect the situation in the market where products are sold but also the impacts in other parts of the product chain. As an example, focusing on energy use for a washing machine sold and used in Europe might be good priority for the EU, but other issues in the supply chain might warrant equal attention, as they reflect specific environmental concerns in other parts of the world (e.g. the use of water during manufacturing in a factory in India). The international dimension

Ideally, the demands on European businesses for information should be reciprocated by developing countries, for example via discussions at the WTO. However, one has to bear in mind that there is still limited jurisprudence at WTO level for how to deal with environmental issues. Despite this there are already rules in place within the EU for products being produced outside of the single market that have to fulfil certain requirements (e.g. on quality and labelling). These are however still limited (for the time being) to product-related and not to process-related issues. The role of consumers

Although consumers were for a long time believed to be the key actor in driving the demand for environmental information, this has (so far) not become a reality. Recent research in Belgium by consumer organisations showed that only around 20% of consumers was interested and aware of such information, and that the majority expects governments to ensure that the worse performing products (from an environmental perspective) should not be allowed onto the market. Next to this, most consumers will always find it hard to deal with too much information or with the need to prioritise between a wide range of different issues (e.g. energy use, water use, hazardous substances, etc.). In this context, retailers might have an important role to play in assisting consumers by focusing on the key messages. As example of a good tool to help this focus is the EU Energy label (which is mandatory), as it is simple and, on top of that, drives real change in the market.


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The role of industry

Next to the fact that public demand for environmental information is weak, the sector examples also showed that business-to-business customers are not necessarily strongly interested in obtaining such information. Therefore, it might be more successful to focus on a limited number of the bigger companies and assist them in their efforts to drive information requests through the supply chain. In this context, economic instruments, including tax exemptions, subsidies, rebates, etc., could be used to stimulate companies to take the lead in this area, although care has to be taken that front-runners are not given undue preference over other players, as this could significantly distort competition. In addition, it will be important to ensure companies have influence over any system that might be envisaged for a given product sector. Participatory processes will be needed to obtain business commitment to providing the necessary expertise and to implement the final results. Such a process is currently being piloted by the European Commission in its efforts to implement a practical IPP framework. The EU Eco-label model of stakeholder participation could also serve as an example of how such a process might be organised. A unified system?

The fact that many product-related instruments rely on efficient flows of information through product chains has led to a proposal for a single method for generating and communicating this information; Environmental Product Declarations (or EPDs). Such a unified approach would have a number of clear benefits, including:

• The use of a standardised methodology for generating the data, i.e. LCA; • The use of product specific requirements (or maybe product sector requirements)

to ensure the harmonisation of information flows throughout the product chain; • The use of LCA for establishing priorities at sector level; • The use of the generated information for informing a variety of product

information tools including green claims, eco-labels, minimum energy-efficiency requirements, etc.

Despite these benefits, there are also a number of disadvantages, including:

• The complexity of doing an LCA will make the use of EPDs difficult for SMEs; • LCA data is often not available for specific processes or substances; • Other relevant information, including recycling quota, market data or toxicity

data, is not part of a typical LCA and would need to be obtained from outside the system;

Whether or not a unified system might be established, it seems clear that a situation whereby each instrument requires a separate system for generating the underlying information is far from ideal and much could be done to improve the current lack of coordination in this area. Some improvements might be achieved by, for example, encouraging further cooperation with product sectors, stimulating research projects and disseminating best practice.


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3.3 CONCLUSIONS AND RECOMMENDATIONS

The above described examples and the discussion during the workshop has shown that product-related environmental information is a complex and diverse area. Not only does it encompass potentially all product sectors and players within those, but it also relates to a large number of possible instruments and actors involved in implementing them. Any conclusions and recommendations that can be drawn from this workshop will have to be seen in the context of this complexity. As this workshop was mainly focused on providing input into the further development of a strategy for Environmental Product Information under the IPP framework in Europe, the conclusions and recommendations are aimed mainly at policymakers in the European Commission and EU Member States, including countries part of the Informal IPP Network such as Norway and Switzerland. Framework conditions and drivers

• Governments should understand that there is no ‘one size fits all’ solution to the problem of how product-related environmental information should be generated and transmitted within a specific product value chain.

• As a result, governments should take care to use the range of information instruments at their disposal in a targeted way, bearing in mind the characteristics of a specific product sector.

• In trying to stimulate the provision of environmental information related to products, governments should take into account the fact that the position and relative importance of an actor in the product value chain often determines the leverage this actor has on demanding information from other actors in the chain.

• Governments should be aware that legislation mandating directly (e.g. the EU Energy label) or indirectly (e.g. the RoHS Directive) the generating and communication of product-related environmental information tends to be a strong driver for information provision through the supply chain.

• Governments, however, need to take care not to overburden business with too many information requirements as this will increase the cost of compliance and might also diminish the quality of the information provided.

• Governments need to ensure, as much as possible, a level playing field for business.

Adding value

• Governments could make much better use of their procurement power, not only to reward higher environmental performance in the goods and services they procure, but also to raise the quality, consistency and availability of information about environmental performance.

• Governments could explore in more detail the effectiveness of using incentives to stimulate the provision of information including for example through tax rebates, subsidies, research funds, awards, etc.


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• Governments could stimulate the financial markets to request more product-related information for example via sustainable reporting guidelines, sustainability indexes,

• Governments could promote voluntary initiatives by business for example via endorsements, environmental agreements (e.g. the Washright campaign), recognition for frontrunners, etc.

Improving efficiencies

• Governments should make more efforts to improve the harmonisation of existing and future information requirements for business

• Governments should, as a rule, focus any information requirements only on the main environmental impacts related to products

• Governments should try to ensure that the effort needed to obtain the required information is proportional to the environmental benefit of obtaining such information

• Governments should consider undertaking further research into how a more streamlined information system underlying a number of policy tools (e.g. based on LCA) could be established.

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Annex A

Workshop Agenda


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AGENDA INFORMAL EUROPEAN IPP NETWORK

Workshop on Product Information Bern, Switzerland, January 17 - 18, 2005

CHAIRS Existing information systems: Christoph Rentsch, BUWAL, CH Analysis, synthesis, conclusions: Bob Ryder, DEFRA, UK RAPPORTEUR Robert Nuij, Environmental Resources Management, I

DAY 1: Monday, 17 January 2005 1.30 pm Registration 2.00 pm Welcome address and introduction to the programme

Christoph Rentsch

Existing information systems used in the product supply chain Chair: Christoph Rentsch

2.15 – 4.00 pm Mobile phones - the experience of a producer and a refurbisher

Salla Ahonen, Nokia, SF and Grégoire Dumoulin, fonebak, B

Discussion 4.00 – 4.30 pm Break 4.30 – 6.15 pm Textiles – the commitments of industry and of a retailer

Conor Andrews, Swedish Textile and Clothing Industries’ Association, S Brigitte Zogg, COOP Switzerland, CH

Discussion

6.15 pm Closing of the first day 7.00 pm Short walk through old Bern; meeting point: Zytglogge 7.30 – 10.30 pm Official dinner

Restaurant Zunft zu Webern, Gerechtigkeitsgasse 68, Bern


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DAY 2: Tuesday, 18 January 2005

Existing information systems used in the product supply chain (Continuation of Day 1) Chair: Christoph Rentsch

9.00 – 10.45 am Metal Industries – the practice of steel producers and a motor

manufacturer Ansie Kumlin, Swedish steel producer association/ Swedish environmental research institute, S Curt Henricson, ABB, S

Discussion

10.45 – 11.15 am Break

Analysis, synthesis and conclusions Chair: Bob Ryder

11.15 – 11.35 am Integrated supply chain information, short report on a Danish study

Preben Kristensen, Danish toxicology centre, DK 11.35 – 11.55 am Product information in the supply chain for beverage containers,

report on the ACE work Robert Nuij, Environmental Resources Management, I

11.55 – 12.30 am Analysis and synthesis of the examples

Bob Ryder

Discussion 12.30 – 2.00 pm Lunch 2.00 – 3.45 pm Conclusions and input to the formal EC working group on Product

Information Needs Bob Ryder

Discussion 3.45 – 4.00 pm Closing of the meeting

Christoph Rentsch

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Annex B

List of Participants


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AHONEN Salla Nokia P.O. Box 226 FIN-45 Nokia Group Finland

Telephone work: +358 7180 37229 E-Mail: [email protected]

ANDREWS Conor TEKOindustriema

Almedahl-Kinna AB Box 265 SE 51123 Kinna Sweden

Telephone work: +46 707 45 43 49 E-Mail: [email protected]

BULETTI Marco Bundesamt für Umwelt,

Wald und Landschaft Abteilung Abfall und Rohstoffe CH-3003 Bern Schweiz

Telephone work: +41 31 322 68 37 Fax: + 41 31 323 03 69 E-Mail: [email protected]

CSABA Eszter Ministry for Environment

and Water CH-1011 Budapest Ungarn

Telephone work: 36 1 457 33 00 ext 224Fax: 36 1 201 24 91 E-Mail: [email protected]

DUMOULIN Grégoire Fonebak/Shields Environmental

47 boulevard Saint Michel B-1040 Brussels Belgium

Telephone work: +32 2 737 76 44 Fax: +32 2 737 76 32 E-Mail: [email protected]

ENGLAND Inger Grethe Norwegian Pollution Control

Authority P.O. Box 8100 Dep N-32 Oslo Norway

Telephone work: +47 22 57 34 41 Fax: +47 67 67 06 E-Mail: [email protected]

ERLANDSSON Johan Chalmers

Environmental Systems Analysis P.O. Box S-41296 Göteborg Sweden

Telephone work: +46 31 7721962 Fax: +46 31 7722172 E-Mail: [email protected]

GJESTRUM Anne Sofie Norwegian Pollution Control

Authority P.O. Box 8100 Dep N-32 Oslo Norway


HENRICSON Curt ABB

S-191 85 Sollentuna Sweden

Telephone work: +46705855373 E-Mail: [email protected]

JANSEN-DE JONG Mirjam Ministry of environment,

the Netherlands 124 Chemin de la Dangereuse F-1210 Versonnex France

Telephone work: +31 70 3394657 E-Mail: [email protected]


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KRISTENSEN Preben Danish Toxicology Centre

2 Kogle Alle DK-2970 Horsholm Denmark


KUMLIN Anna-Sofia

IVL Swedish Environmental Research Institute Ltd. S-100 31 Stockholm Sweden


LINGARD James UK Department of Trade

and Industry Bay 431 151 Buckingham Palace Road UK- London SW1W 9SS United Kingdom

Telephone work: 0207 215 4156 Fax: 0207 215 5835 E-Mail: [email protected]

MEYER-RUTZ Eckart Federal Ministry for the

Environment Alexanderplatz 6 D-10 178 Berlin Deutschland

Telephone work: +49 30 28550 2260 Fax: +49 30 28550 3339 E-Mail: [email protected]

MÜLLER Walter Swissmem

Kirchenweg 4 Postfach CH-8032 Zürich Schweiz


NAESS Bente Ministry of the Environment

P.O. Box 8013 Dep N-30 Oslo Norway


NISSINEN Ari Finnish Environment Institute

(SYKE) P.O. Box 140 FIN-251 Helsinki Finland

Telephone work: +358 (0)9 403 00 346 Fax: +358 (0)9 403 00 391 E-Mail: [email protected]

NUIJ Robert Environmental Resources

Management Via Eredi Farina 16 I-27100 Pavia Italy

Telephone work: +39 0382 537506 Fax: +39 0382 537506 E-Mail: robert.nuij2erm.com

OUDSHOFF Bianca Ministry of Economic Affairs

P.O. Box 20101 NL-2500 EC The Hague The Netherlands



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POHL Denis SPF Santé Publique, Protection

de la Chaîne alimentaire et Environnement/DG Environnemet 20, RueMontagne de l'Oratoire Boîte 3 B-1010 Bruxelles Belgique


REINHARD Ylva Swedish EPA

SE-106 48 Stockholm Sweden


RENTSCH Christoph

Bundesamt für Umwelt, Wald und Landschaft Sektion Produkte CH-3003 Bern Schweiz


RYDER Bob UK Environment Ministry

Department for Environment, Food and Rural Affairs Ashdown House Victoria Street UK- London SW1E 6DE United Kingdom


SAUR Konrad Five Winds International

Danziger Strasse 8 D-73072 Donzdorf Deutschland

Telephone work: +49 (0)7162 941905 Fax: +49 (0)7162 941906 E-Mail: [email protected]

VENANZONI Eveline Bundesamt für Umwelt,

Wald und Landschaft Sektion Produkte CH-3003 Bern Schweiz


WÄLTY Anna Bundesamt für Umwelt,

Wald und Landschaft Sektion Produkte CH-3003 Bern Schweiz


ZOGG Brigitte Coop

Postfach 2550 CH-4002 Basel Schweiz


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Annex C

Draft Strategy Paper on Environmental Product Information

1

ENVIRONMENTAL PRODUCT INFORMATION

A FRAMEWORK FOR ACTION UNDER INTEGRATED PRODUCT POLICY (IPP) IN EUROPE

A. RATIONALE 1. A traditional policy view (going back 10-20 years) is that the main driver for achieving ‘greener

products’ is consumer choice, supported by consumer education and awareness campaigns. For example, this was the rationale behind traditional ecolabelling voluntary award schemes, which have aimed to promote products of a higher environmental standard. However, this has turned out to be an over-simple view: it does not take account of the many complex factors operating in the market and in the minds and actions of producers and consumers. It is true that some positive changes have been achieved in the market as a result of consumer action and voluntary labels, but this is a relatively small part of the picture. The aim of IPP is to take the whole picture and to use the tools and drivers that can have greatest effect.

2. The rationale behind the present document is that: • technical knowledge about product impacts and product performance needs to be made more

accessible to a whole range of decision-makers who are able to act within the supply chain; • a more efficient system for generating and communicating this information will itself be driver

for the environmental improvement of products, by making environmental performance a normal part of progress in the market.

The significance for environmental policy 3. In the context of IPP, information about the impacts of products and their environmental performance

is fundamental to the success of the EU policy as a whole. Other IPP tools - for example, economic instruments, product standards and voluntary agreements - cannot be attempted unless good information about the product sector is available.

4. More widely, in the context of sustainable consumption and production (SCP) the availability of good quality information, for actors at all points in the supply chain, is the starting point for understanding and influencing the market towards SCP. It allows: • everyone to see and compare the relative performance of different products, so that environmental

quality becomes a factor for competition; • producers to design and innovate, bringing forward better product solutions; • purchasers (whether professional or household) to exercise greener choice; and • consumers of products to reduce their impacts in using and disposing of them.

The significance for policy on enterprise and trade 5. Product information is an important market issue for the EU, as well as an environmental one.

Because it is essentially about the performance of traded goods and services, it needs to be approached in the context of the EU Single Market (and indeed in the context of wider international trade).

6. Unfortunately, from the perspective of an efficient market, there are some significant barriers which currently prevent good product information being available along the supply chain.

BARRIERS TO THE SUPPLY OF GOOD INFORMATION ON PRODUCTS

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• Gaps in knowledge or the public availability of information - for example, about certain phases of the life-cycle for certain products; or and about the risk of various hazardous substances found in products.

• Insufficient understanding about the value and the need for product information, on the part of many potential providers and users of information.

• Incompatibility between different systems or measures of information, making it difficult to compare performance or to pass information along the supply chain.

• The burden which assembling and interpreting data may place on the resources and skills available to business, particularly in the SME sector.

7. At present, therefore, the market drivers for improvement are weak. This is a problem not only for

environmental performance. Sustainable production is also about finding new approaches which use resources more efficiently and which create market advantage. So the market weaknesses mentioned above are also affecting the EU’s capacity for innovation and competitiveness - and therefore its economic performance. This is a further reason for developing policy solutions which have some coordination at EU level.

B. BROAD AIMS OF AN EU FRAMEWORK FOR PRODUCT INFORMATION 1. Taking the rationale above, the necessary framework must be designed in a way that helps the market

to operate efficiently to deliver improvements in the environmental performance of products.

2. The principal aim could be expressed on the following lines. “To support a well-informed market 1. where environmental performance is seen as a major issue for competition; and 2. where a supply of good information (from data generation through to communication) operates

smoothly across the single market and does not create barriers to trade.”

3. More specifically, the objectives might be to achieve: • A much greater coverage of information than at present

More information is needed about the types of product which are most problematic for the environment. It is also needed across the breadth of the life-cycle of those products. And it needs to be available at all points in the supply chain where influence and choice are possible.

• A good level of information quality

Information should be relevant (relating to key impacts) and accurate (able to be justified and, where appropriate, able to be verified).

• Benefits for the providers of the information

Information tools should be designed so that the information generated by the provider is cost-effective - by being suitable for a range of downstream uses and by allowing the environmental performance of the provider to be recognised easily by all the downstream users of the information.

• Real value for the users of the information

Information tools should be designed to be efficient to use for the relevant actors in the supply chain, enabling them to adjust their actions on the basis of the information.

C. USERS OF PRODUCT INFORMATION

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1. The policy framework should be designed to meet the needs of all potential users (and not simply, as was often assumed in the past, the needs of the final ‘household’ consumer).

2. Information is needed throughout the product life cycle - from design and production, through to processing and distribution, and then through to use and disposal by the end consumer.

3. In this way, information systems can help to drive the sustainability of: • the raw materials that make up products; • the processes, resources and ‘intermediate products’ used within production; • the properties of the final product (its impacts in the hands of the consumer and after it leaves the

consumer); and • the manner in which the consumer uses and disposes of the product.

4. Information regimes therefore need to recognise the diversity of the stakeholders in the supply chain

who can benefit from good information on the environmental impacts of products.

5. There are two main groups in the market, who have quite distinct economic interests and information interests: • Those whose role is to ‘add value’ to a product in the marketplace. These include:

o material producers o manufacturers o service providers o wholesalers o retailers

• Those who are purchasing products for an ‘end use’, rather than to add economic value to them. These include: o business o national and local government o non-profit organisations o household consumers

6. These different types of economic actor are ‘mapped’ in the following illustration of the supply chain.

7. In addition to these users of information, who operate directly in the product market, there are further

categories of ‘information user’:

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• public authorities, who need data in order to assess the environmental impact from products over time; to identify priorities; and to develop other IPP tools (eg, legislation or economic instruments) which may be needed to improve the performance of the market;

• other economic actors, such as the financing and insurance sector, and the media, who have an interest in information about companies’ products without being involved in adding directly to the value chain of those products.

8. The policy framework must take account of these different needs and try to meet them in the most

efficient way. D. TRANSACTIONS IN WHICH PRODUCT INFORMATION IS NEEDED 1. Within the supply chain for any one product there is a complex web of transactions

(a) between different actors within the first of the above groups (the ‘value adders’); and (b) between different actors in the first group and different actors in the second group (the ‘end users’).

2. Each of these actors has different needs for information about the environmental performance of a product or service. For example: • Material producers will be looking to demonstrate the environmental credentials of the

commodity they are selling to various other businesses who ‘add value’ to it (such as manufacturers and service providers) but they may also be selling some of their product to different types of ‘end user’.

• Business and government, when buying as an ‘end-user’, will be most interested in being able to identify that a product meets their own purchasing criteria.

• Retailers will ‘face both ways’ - needing to ensure that the products that they stock meet their own environmental criteria, while also looking to present clear information to their customers.

• Household consumers are a complex and diverse audience, whose needs vary widely - and whose attitudes are sometimes contradictory. In most cases, information that gives quick and simple assurances or ‘ratings’ will be the most popular.

3. The complexity of the relationship in these transactions is illustrated in the following ‘transaction’

chart. The type of information useful to any transaction will vary, depending on the types of actors involved in the transaction.

5

4. The policy aim under IPP is to ensure that the right environmental information is available, at the right time, and in the right form - so that all the supply chain transactions involved with the product are well informed and can take environmental considerations into account. Note: There are at least two further information flows which are not captured in the ‘transaction’ chart above: • a ‘reverse’ flow of information, feeding back from buyers to sellers, which is needed for product

development and improvement; and • a two-way flow of information between sellers of a product and the recycling / waste industry

which finally handles or reprocesses it at end-of-life. E. GENERATING RELEVANT INFORMATION EFFICIENTLY 1. In whatever form information is communicated, it has to start with some form of data generation.

There are many stages in the product’s life-cycle where producers are able to generate environmental data, and several different uses which the data may serve. This is illustrated in the following chart.

2. An important function of the EU’s approach should be to encourage the efficient generation of data -

i.e., in ways that make it suitable for multi-purpose use.

3. The main ‘building blocks’ for information tools within the strategy are the elements identified and categorised by the International Organisation for Standardisation (ISO) in the ISO 14000 series. These (mainly voluntary) tools are described in the list below. • Life Cycle Assessment (LCA) (ISO 1440 series)

LCA is an analysis of a product’s environmental impact throughout its life-cycle. It is a supportive tool for product design and for other instruments (for example, LCA is used as a basis for eco-labelling criteria and for environmental product declarations). The standards for LCA are technical and procedural, ensuring that analytical studies are conducted in a consistent and transparent manner.

• Environmental Product Declarations (EPDs) (ISO Type III labels) These are declarations or product ‘profiles’ which appear in a standardised format (and sometimes with third-party verification) designed by some form of market requirement or collective agreement. Schemes which follow the ISO guidance are life-cycle based, focussing on the main environmental considerations for the type of product concerned. EPDs are likely to be most used in business-to-business transactions, either between sellers at different points in the supply chain, or between sellers and corporate buyers who wish to set detailed environmental purchasing criteria.

6

• Self declaration (green claims) (ISO Type II labels) These are labels or textual claims which a business applies to its own products (generally without third-party verification). They generally focus on a single environ-mental consideration which the business itself considers is significant. These claims are most commonly used in transactions between sellers and all types of end-user, but they also feature further up the supply chain in seller-to-seller transactions.

• Award labels (ecolabels) (ISO type I labels) These are labels awarded by a third party organisation, showing that a product meets a certain set of environmental criteria. They give quick evidence of the environmental ‘superiority’ of the product for users who do not wish to spend time assessing the details for themselves. Again, these are likely to be most useful in transactions with end-use buyers, but sometimes further up the supply chain between sellers (eg, in the case of basic goods like timber or cotton).

4. In addition to these voluntary information tools, there are various types of mandatory information - such as information required under the IPPC regime, SDS (Safety Data Sheets); PRTR (the Pollutant Release and Transfer Register); the EU energy label; and perhaps in due course information that may be required under the proposed REACH directive and the proposed EUP directive.

Efficiency 5. The challenge is to make the information ‘process’ as efficient as possible, so that data generated for

one stage of the product life-cycle can be used to meet several different requirements for information. A study funded by the Danish EPA is currently looking at the scope for maximising efficiency in this area.

6. In this connection, there is great potential for environmental management systems (EMSs) to help companies maximise their efficiency in generating and using information about the products they buy and sell. • Environmental management systems (EMSs) (ISO 14001, EMAS)

These systems (which are third-party verified) for monitoring and managing the environmental impacts of a business have tended to concentrate on the processes of production rather than on the impacts built into the product. However, the techniques of EMSs could be applied very effectively to generation of data about product impacts, and could thus be used to meet a range of demands for product information.

7. Environmental reporting is another area which could be better integrated into the systems for gathering and communicating information. • Environmental reporting (EMAS, GRI, etc)

These systems (which use third-party verification) for reporting on the environmental impacts of a business have tended to concentrate on the impacts of production rather than of the product. But there is plenty of scope to use the frameworks and techniques of reporting systems to communicate information about this important area of a business’s environmental performance.

F. FORMS OF GOVERNMENTAL INFLUENCE There are four main areas in which government influence can be applied to create action in the market. 1. Framework influence - setting out standards and guidance for ‘sellers’ who provide information;

facilitating the development and coordination of information tools. 2. Promotional influence - programmes to encourage interest and action among ‘sellers’; campaigns to

raise awareness of information tools among buyers.

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3. Purchasing influence - adopting active policies for sustainable procurement; specifying minimum criteria of product performance and information to be demanded from governments’ own suppliers.

4. Mandatory authority - setting clear rules about the type and quality of information to be placed in the

market. G. POSSIBLE ELEMENTS OF AN EU FRAMEWORK EU policy on product information needs to: • set out how and where these potential influences should be applied; • provide an agreed list of priorities for action at EU and national government level; • at the same time, take full account of the global perspective (because of the trade implications and the

increasing globalisation of supply chains). Actions are suggested below for all four types of government influence over the market. However, within this ‘package’, most emphasis is being placed on action within the third and fourth types of intervention (public purchasing and mandatory approaches). Actions in these areas will make the most effective contributions towards delivering the WSSD commitment to promote more sustainable patterns of production and consumption. (1) Framework action

a. Adopt a policy vision and an action plan at EU level, agreed by the Commission and its regular IPP committee.

b. Develop mechanisms to evaluate the effectiveness of this approach in the market.

c. Support work which promotes the efficient generation of data capable of multi-purpose use: − the development of LCA, encouraging greater accessibility and use of data; − analysis of the types of data generated within different instruments and life-cycle phases;

d. Ensure greater coherence and coordination between relevant EU instruments for voluntary

action by business, for example: − ensure a healthy framework for Type III labelling (EPDs for business-to-business and public

procurement) in the Single Market. − review the aims and operation of EU activity on Type I labelling (eco-label awards). − review the aims and operation of EU activity to promote environmental management systems

and environmental reporting (EMAS, CSR, etc).

(2) Promotional action e. Promote the case to business of good environmental product information as a whole - i.e., a

whole ‘suite’ of relevant tools, rather than promoting individual schemes or instruments.

f. Attempt to reach a new range of actors in the supply chain. These include (for example) the marketing and purchasing professionals within the product supply chain; and the professionals in parallel business sectors such as investment, advertising and consultancy.

g. Fill ‘knowledge gaps’, through support programmes for eco-designers, especially in SMEs.

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(3) Purchasing action h. Member states should adopt an active national policy

of setting clear purchasing criteria for the environmental performance of the goods and services they buy for their own use.

i. Knowledge of the criteria should be shared and networked among member states.

j. Purchasing specifications should draw on existing information tools and should be used to require suppliers to provide information in a standard format.

k. Governments should also promote wider knowledge of these purchasing criteria to the private sector and also to household consumers.

(4) Mandatory action l. Include clear information requirements within any new environmental

product obligations, such as those proposed in the draft EUP Directive.

m. Consider how other forms of ‘product stewardship’ requirement in future might include obligations to pass product information down the supply chain.

n. The EU energy label approach has shown how a ‘single issue’ label can gain the confidence of consumers and move the market forward. It should be extended to more products and to further sectors with high CO2 impacts.

o. The proposed new Framework Directive for energy labels should also allow other major environmental impacts to be included in the mandatory declaration for a product.

p. The legal framework for self-declared claims (Type II) should be strengthened through, for example, a Commission Recommendation or a more binding instrument.

q. ‘Product panels’ should be used to negotiate sector agreements on product standards and information.

This will raise the environmental performance of products (because of the scale of Government purchasing) and create the demand for product information on which standards can be based and verified.

This will help increase supply chain pressure and lead to market convergence. This will encourage the uptake of existing tools and will also encourage individual sectors to develop their own tools (e.g., EPDs) and other kinds of standardisation.

This will help empower other types of buyers to demand better performance and good information.

All of these actions will help to raise the performance of products and add to the publicly available information about the environmental characteristics of products.

This will prevent misleading claims (a barrier to fair competition) and will improve the overall quality of information in the market.

The approach envisaged in the draft EUP Directive could be used more widely - to secure voluntary action from key sectors, rather than directly pursuing the mandatory options.

9

ANNEX - possible priorities for an ACTION PLAN ? The following suggestions have been made (by a number of colleagues in the IPP Informal Network) for actions which could be prioritised in the for implementation of an EU action programme on product information. 1. Develop the ‘knowledge base’

There are many systems established or proposed in specific sectors or parts of the supply chain, mainly in the business-to-business market. There are also interesting developments in the framework of ISO, CEN and national standardisation organisations; in eco-label-oriented groups; and in industry organisations. Better knowledge of these systems would show us where there are economic and technical groups with a special interest in information transfer. This knowledge could mapped onto the ‘transactions’ chart. Gaps could also then be identified. • Compile better knowledge (via a workshop and a consultancy) about existing information

instruments, among different member states and stakeholders, in order to: − Identify barriers (and drivers) for a better information flow in the supply chain; − Identify the needs for information among different actors; − Identify what measures are needed to improve the information flow; − Analyse what kind of data is generated within the framework of different instruments; which life-

cycle phases are covered; how data differs when generated within different instruments, etc; − Consider examples of a few specific product groups where information systems already exist. − Analyse how an efficient generation of data can be brought about - i.e., ways that make it suitable

for multi-purpose use; − Identify the main gaps; − Consider how different information instruments, both voluntary and mandatory, could be further

developed and better coordinated. 2. Develop some key information tools • Undertake a fundamental review of existing EU voluntary instruments on ecolabelling, environmental

management systems and environmental reporting; • Use this review to help rethink priorities about where EU resources should be focussed to deliver

results under IPP. • Expand the role of the mandatory ‘energy labelling’ approach, covering further environmental issues. • Develop an EU framework to promote voluntary EPDs. • Increase the attention to product information within EMSs. • Improve the coverage of chemicals within LCA and EPDs. • Promote efficiency and cost-effectiveness by allowing one information system and one third-party

verification to serve all relevant regimes (e.g., requirements under labelling schemes and public procurement tenders).

3. Reinforce other IPP tools • Public procurement using good minimum criteria for environmental performance.

There is a growing policy view that procurement is a key driver for delivery of national and EU environmental goals and commitments, including the WSSD commitment on sustainable consumption and production.

• Information about product impacts and performance (‘what to specify’ and ‘how’) is essential for sustainable procurement to happen. It is therefore very important for an EU information strategy to serve the needs of an active green procurement policy. How can this be done in practice? Can resources be found (or switched from other areas, such as the

10

administration of the ecolabelling scheme) to agree minimum specifications which can be promoted for use in all public purchasing across the EU?

• ‘Technology procurement’ for future high standards of environmental performance.

This is seen (e.g., in the EU Environmental Technology Action Plan) as a way of driving innovation for environmental improvement. Can better frameworks for product information help deliver procurement specifications which challenge companies to bring forward new, high-performance technologies?

• Support for mandatory regimes - e.g., the information requirements which are expected to arise from

the proposed EuP Directive (and the possibility of extending such a ‘framework’ approach to more types of products, as proposed by the European Parliament).

Documents

The Informal European IPP Network Workshop · product life cycle covered The NOKIA product information system covers the entire life-cycle (cradle to grave) of the mobile phone although