Miljøbeskyttelse og bæredygtig udvikling i det indre marked

Re: Draft strategy for the integration of environmental protection and sustainable development into internal market policy

In general the Danish Consumer Council welcomes the strategy aimed at integrating environmental protection and sustainable development into single market policy.

The Danish Consumer Council believes that there is a need for a strategy ensuring that a high level of environmental protection and sustainable development are reached along with an increased economic activity and trade following the single market.

We find it important that a balanced and common approach is reached, which integrates sustainable development as well as environmental, social, ethical and economic considerations into the overall strategy of the EU.

The Danish Consumer Council is particularly pleased that the precautionary principle is mentioned as a basic principle for implementing sustainable development and environmental protection.

Also we agree that the concept of Integrated Product Policy (IPP) could be seen, and in fact used, as a general framework for implementing the strategy.

The point of departure for such a strategy must be an effective implementation of community legislation. Therefore the Danish Consumer Council welcomes that the strategy focuses on the fact that there is a significant lack of implementation of various community legislation by some Member States. Improvement in the current situation is a prerequisite for progress on integration of sustainable development. The Danish Consumer Council therefore urges the Commission and Member States to take responsibility for achieving full implementation of their various environmental directives.

The Danish Consumer Council also believes that a stronger regulatory policy is important in order to integrate environmental protection and sustainable development into the general regulatory framework. But on this point we believe that the strategy and objectives are not strong enough. It should be stated in the strategy that not only should the regulatory policy include specific considerations on how to integrate environmental protection and sustainable development, but in fact it should include not only considerations, but also concrete suggestions on how to integrate environmental protection and sustainable development.

Regarding standardisation and the new approach, it is very important that environmental considerations are taken into account in relation to the standardisation processes. The Danish Consumer Council believes that on this issue there is a strong need for the following:

Improvement of the standardisation process so that a high level of environmental protection is integrated into the standards.

Relevant stakeholders must be involved in the standardisation process. This also requires sufficient resources to address the structural inequity between industry and NGOs. It must be recognised that NGOs such as consumer organisations do not have the adequate resources to be actively and permanently in the standardisation process.

The resource problem must be addressed, if environmental protection and sustainable development are to be properly integrated into standardisation and the use of the new appoach.

We recognise that Integrated Product Policies (IPP) can be a valuable framework for integration of sustainable development into the Commission’s policies. Again it is very important and must be strongly emphasised that stakeholder involvement is essential to the success of IPP. Also the Danish Consumer Council believes that IPP cannot only be focused at environmental problems, but it should also include issues such as ethical and health considerations. Again it is important that sufficient resources are allocated so that a proper stakeholder involvement can be assured.

We acknowledge the three overarching goals of IPP:

stimulation of consumer demands for green products.

stimulation of business leadership in the supply of green products.

the use of price mechanisms to develop a market for green products.

But again we must emphasise that it is very important that business and industry take a lead in supplying green products to the consumer. The consumers cannot demand green products, if the green products are not on the shelves and properly labelled. In this connection the Danish Consumer Council urges the Commission to work on improved information to the consumer, including work on expanding environmental labelling as well as environmental declarations. Finally the Danish Consumer Council very much welcomes that the Commission investigates the concept of differentiated VAT in order to incorporate the polluter pays principle more actively into the strategies of the community.

In relation to public procurement, the Danish Consumer Council finds that the most important role of the Commission is to ensure that there is and still will be a possibility for public authorities to include environmental criteria when purchasing goods and services.

The Danish Consumer Council are very much in favour of the use of eco-labels as a transparent and easily recognised information tool, which enables the consumer to select products which have an overall better environmental performance. Therefore we very much welcome that more focus is put on eco-labelling schemes and how to raise the number of product groups, and therefore also raise the number of products which can be bought by the consumers. Also the Danish Consumer Council believes that work should be initiated in order to explore all ways of communicating environmental performance to the consumers, e.g. environmental declarations.

In relation to consumer awareness and knowledge building, the Danish Consumer Council is in favour of increased focus in this area. A change in consumption patterns is of course a prerequisite for sustainable development. But it is also important to recognise that the consumers cannot change consumption patterns if more environment friendly products are not on the shelves. Therefore it is essential that business and industry are actively encouraged by e.g. both voluntary agreements and a suitable regulatory framework so that they are motivated to develop and market greener products followed by credible and transparent environmental information to the consumers.

The use of economic instruments can be an effective tool in integrating environmental considerations into the internal market. Again the Danish Consumer Council welcomes for instance the use of differentiated VAT as stated in the IPP Green Paper, but also we are in favour of the use of green taxation.

The draft strategy encourages the use of voluntary environmental agreements. Voluntary agreements can be a useful tool in promoting environmental protection. But we must emphasise that, if voluntary agreements are to achieve this goal, they must be followed by clear objectives and set within a limited and clear time framework. Also experience shows that voluntary agreements work much better if they are followed by an early warning stating that if targets and objectives are not met, then more sufficient regulatory measures will be taken.