The Comments of
Confederation of Danish Industry (DI)
on the EU Commissions S
Sustainable Consumption and P
The European Commission calls for
input to the existing SCP A
lan, which is
going to be
revised in 2012, as well as EU
and the efforts to establish
gies” for products and organizations
The EU commission has therefore initiated an interesting study consisting of a comprehensive
questionnaire. The study runs until
DI has chosen to comment on selected initiatives instead of filling out the questionnaire which is
only partly re
levant to DI members.
he EU Can M
The overall goal of the existing action plan
is to establish dynamic frameworks continuously
contributing to improving the energy efficiency and environmental
of goods and at the
same time to diss
eminate the use of environmentally sound goods. The increased focus on global
resource availability calls for focus on producing more goods with
the EU has a central role, as a coordinated strategy will have a much greater
providing better opportunities and enforcing equal competition, opposed to national
Especially the global dimension is important when promoting sustainable production and
consumption and therefore the Commission is encouraged to incorporate t
he global dimension
ore actively in the coming revision
At the same time the
to focus on achieving a sustainable development
on three pillars; the environmental aspects, the social aspects and the financial aspects. A focus
on environmental aspects is not
desirable, since it will distort th
damaging civil and
society, without guaranteeing an environmental gain.
The approach of the action plan has been to incorporate many different political tools. To secure a
implementation of the different
ill continuously be of utmost importance.
Due to the level of interaction with the surrounding world, the
tools in use must be based on
internationally recognized prerequisites. Meaning that data and scientific information supporting
must be transparent and the tools must be supported by international standar
and methods, making them comparab
across the EU.
Also the consumer information must be
uniform within the EU.
that one of the
of the SCP Action P
lan is that there is freedom for the
company and industry to choose the instruments most appropriate for their
specific efforts to
contribute to the development towards sustainability.
different instruments exist
the consumers’ choice of products
. Among other instruments
Directive and E
can be mentioned
Overall DI wishes
ress the importance of letting new initiatives prove their worth and be
thoroughly evaluated b
efore any changes or restrictions are initiated, t
DI finds it disturbing
that it is suggested that several initiatives are launched without clarity of how
are interacting, overlapping or at worst counteracting.
Therefore DI stresses the need for gaining a concrete overview of the present legislation and
the more or less voluntary initiatives already promoting sustainable production an
before any new initiatives are launched.
would be expedient to do as the
of the SCP
Action Plan is being conducted.
It is important that the established politics support each other, that they are being coordinated
and that it
to achieve a synergy between the different politics and instruments.
Also actions should be taken towards understanding the possibilities of deregulating the
companies as they voluntarily move towards achieving more of the SCP goals.
The Europe 2020 S
”Communication on a Resource
efficient Europe” is the
flagship of the
Commission and sets goals for sustainable production and consumption.
The efforts of fulfilling the strategy has l
ed to the preparation of
”EU´s Resource Efficiency
Roadmap”, which has the purpose of stimulating a systematic improvement of the environmental
capabilities of the companies
in the EU
The roadmap focuses on two central aspects, which must be further deve
loped in the future:
for developing new products using new and more accessible raw materials or using less
doing more with less.
amount of limited resources being
ed, by including reuse in the
and focusing on ”functional recycling”.
DI therefore stresses the need
focus on including the environmental aspect already in the
in order to prevent future environmental and resource availability problems. Thus
action plan needs to focus on research and development of methods
To reach the goals
a set of milestones are applied, using among other parameters “environmental
footprints” from products and businesses.
The aim is to guide t
he choices of the consumers and in
the long run enable the use of other political instruments.
The footprint should be determined from a joint set of rules, based on
could be used by the commission t
o lead the way forward.
it will not be possible to
on the constructing of such a
system on EU level. For th
is obvious and crucial for the
credibility of the system
, but it is
lso the weakness since L
As are both comprehensive and costly.
To base the milestones in the Action Plan on L
prove financially impossible,
especially for the SME
s. Also generally it can be questioned whether
the Environmental footpri
can comprehend the complexity of sustainability.
In addition to
the production aspect also consumption must be considered thoroughly. The
consumer must be guided and educated for making environmentally sound choices, so that the
s to developing a more resource efficient production, in other words simple
supply and demand mechanism must be utilized.
The same mechanisms can be applied in public
procurements. The public buyers should also be guided and educated to demand green produc
and here the tools are the joint European procurement criteria. A
focus on life cycle
can also be one of the means. The effect of changes in public procurements has great
potential due to the volume
If green taxes
it is decisive
that they are
data and that the regulation
is simple to
for the companies.
cannot function alone and must be followed by other initiatives, they do not always
desired outcome and it must be secured that no double taxation is applied in any member state.
DI advices that great
if green taxation
in the work towards more
sustainable production and consumption.
of supporting companies in a change from selling products to selling
opportunity for producing with the use of fewer resources. This is worth supporting and the
possibilities can prove extensive. Also the initiatives supporting SME
are positively received, but
the requirements for the companies must be the same regardless of size
competition must be
that with the SCP Action Plan, containing
effective instruments and tools, we are well on
our way to a more
sustainable production and
consumption pattern. The
accepted the challenge and are working towards contributing to a more sustainable society by
applying the tools and focusing on minimizing their resource use. Still there are lots to d
are far from
the end goal, which is also why DI is looking forward to the
SCP action plan.