The Comments of the Confederation of Danish Industry (DI) on the EU Commissions Stakeholder Consultation on Sustainable Consumption and Production (SCP)

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Nov 9, 2013 (3 years and 7 months ago)

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March 28
th

2012



The Comments of
the

Confederation of Danish Industry (DI)

on the EU Commissions S
takeholder
Consultation

on
Sustainable Consumption and P
roduction (SCP)

The European Commission calls for

input to the existing SCP A
ction
P
lan, which is
going to be
revised in 2012, as well as EU

s
Green P
ublic

P
rocurement Directive

and the efforts to establish

footprint
methodolo
gies” for products and organizations
.

The EU commission has therefore initiated an interesting study consisting of a comprehensive
questionnaire. The study runs until
3

April 2012.

DI has chosen to comment on selected initiatives instead of filling out the questionnaire which is
only partly re
levant to DI members.

T
he EU Can M
ake a
D
ifference

The overall goal of the existing action plan

is to establish dynamic frameworks continuously
contributing to improving the energy efficiency and environmental
impacts

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
fewer resources
.

And her
e

the EU has a central role, as a coordinated strategy will have a much greater
impact
,
providing better opportunities and enforcing equal competition, opposed to national
strategies
.

Especially the global dimension is important when promoting sustainable production and
consumption and therefore the Commission is encouraged to incorporate t
he global dimension
m
ore actively in the coming revision
.

At the same time the
C
ommission needs

to focus on achieving a sustainable development
based
on three pillars; the environmental aspects, the social aspects and the financial aspects. A focus
solely

on environmental aspects is not
desirable, since it will distort th
e

m
arket
,

damaging civil and
corporate

society, without guaranteeing an environmental gain.

The
E
xisting
A
ction
P
lan

The approach of the action plan has been to incorporate many different political tools. To secure a
coherent
implementation of the different
schemes

w
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
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the
Action Plan

must be transparent and the tools must be supported by international standar
d
s
and methods, making them comparab
le

across the EU.

Also the consumer information must be
uniform within the EU.

DI
finds

that one of the

strengths
of the SCP Action P
lan is that there is freedom for the
individual
company and industry to choose the instruments most appropriate for their
specific efforts to
contribute to the development towards sustainability.
Also

different instruments exist

for affecting
the consumers’ choice of products
. Among other instruments
Ecolabel Regulation
,
E
nvironmental
Management System
,
goals for
Green P
ubli
c

Pr
ocurements, the
E
nergy
L
abel

D
irective
, the
E
codesign
Directive and E
nvironmental
Technology V
erification

(ETV)

can be mentioned
.




Overall DI wishes

to
st
ress the importance of letting new initiatives prove their worth and be
thoroughly evaluated b
efore any changes or restrictions are initiated, t
h
at

applies

especially the
Eco
design
D
irective.

Before the
Revision

of the
SCP

A
ction
P
lan

DI finds it disturbing
that it is suggested that several initiatives are launched without clarity of how
the
diverse

initiatives

are interacting, overlapping or at worst counteracting.

Therefore DI stresses the need for gaining a concrete overview of the present legislation and

of
the more or less voluntary initiatives already promoting sustainable production an
d consumption,
before any new initiatives are launched.
Th
at

would be expedient to do as the
revision

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
is
aimed

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 Commission’s
P
roposals
on

N
ew
I
nitiatives

The Europe 2020 S
trategy

”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:

Work
ing

for developing new products using new and more accessible raw materials or using less
of the

limited

raw materials


doing more with less.

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Increase the
amount of limited resources being
recycl
ed, by including reuse in the
design process
and focusing on ”functional recycling”.

DI therefore stresses the need
to

focus on including the environmental aspect already in the
design process

in order to prevent future environmental and resource availability problems. Thus
the coming
action plan needs to focus on research and development of methods
which supports
these aspects
.

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

the

lifecycle

approach
(LC
As)
. This
lifecycle
approach

could be used by the commission t
o lead the way forward.

DI
is
concern
ed that

it will not be possible to

agree

on the constructing of such a
n assessment

system on EU level. For th
e

evaluation
system to
be
built

on

the
L
C
A

is obvious and crucial for the
credibility of the system
, but it is

a
lso the weakness since L
C
As are both comprehensive and costly.
To base the milestones in the Action Plan on L
C
As

could
therefore
prove financially impossible,
especially for the SME

s. Also generally it can be questioned whether

the Environmental footpri
nt
symbol
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
demand contribute
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
ts
and here the tools are the joint European procurement criteria. A
n increased

focus on life cycle
costs (LCC)
can also be one of the means. The effect of changes in public procurements has great
potential due to the volume

of goods

bought
.

If green taxes

are considered
,

it is decisive
that they are

calculated using

harmonized and
transparent
data and that the regulation

is simple to
implement

for the companies.
G
reen taxes
cannot function alone and must be followed by other initiatives, they do not always

provide the
desired outcome and it must be secured that no double taxation is applied in any member state.

DI advices that great
caution is

exercised

if green taxation
is applied
in the work towards more
sustainable production and consumption.


The idea
of supporting companies in a change from selling products to selling
services

provides the
opportunity for producing with the use of fewer resources. This is worth supporting and the
possibilities can prove extensive. Also the initiatives supporting SME

s
are positively received, but
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the requirements for the companies must be the same regardless of size


competition must be
equal.

DI
finds

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
companies have

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
o

and

we
are far from

reaching

the end goal, which is also why DI is looking forward to the
revision

of the
SCP action plan.

Best Regards

Tina Sternest