Brussels (June 18, 2003) – The European Environmental Bureau (EEB) is relieved that the European Commission has finally published its next effort on Integrated Product Policy after a two year gestation period, but is extremely disappointed that it fails entirely to give the Community what it needs to create significant reductions in the environmental life-cycle burden of products and services.

The IPP Communication makes some small steps in the right direction compared to the Green Paper from February 2001 – namely putting resources behind product selection methodology and product pilot projects, and setting up Commission-run working groups and some steering mechanisms. It also commits to developing IPP indicators to asses environmental improvements, requiring member states to report on IPP implementation, and calling on member states to draw up action plans on greening Public Procurement. However, it lacks its most vital component: a legislative platform on which to make effective use of these actions and any results thereof and to lay down a common vision on what concrete environmental objectives are trying to be achieved, and by when.

The previous draft committed the Commission to coming forward with a discussion document on Product Design Obligations within 2003 and mentioned a framework directive. This commitment has been replaced with only a vague commitment to a discussion document in 2005 that will only "consider whether there is need for some form of general obligation on produces to ensure the IPP is implemented in all companies"

" We need general Product Design Obligations in the form of an IPP Framework Directive. Without this framework the IPP process will have no political drive and no ability to create major change in the near future. Does it have to take 10 years from the start of IPP studies and discussions in 1997 to 2007 to realise what is necessary?" says Melissa Shinn, Ecological Product Policy Officer for the EEB. " Whilst the Commission commits to ‘establishing framework conditions for the continuous environmental improvement of ALL products’ it proposes no initiatives that will in fact achieve this."

The EEB emphasised some of the appropriate so called "framework conditions’ in a vision paper developed in February this year. This does NOT necessarily mean product-specific legislation, but first, a general legislative platform in the form of a general IPP Framework Directive. This creates the appropriate setting for the Commission and Member States to turn IPP into a ‘live’ policy.

It should include laying down clear environmental objectives based on existing policies such as Kyoto and Ospar, creating a general legal provision for environmentally-sound products (to deny market access to those products designs that have the greatest negative impacts), obliging producers to supply product lifecycle information and setting up the necessary resources to be able to provide producers and the standardisation process with important tools such as product benchmarks. It also creates the ‘working framework’ to establish working groups on specific IPP tools, such as economic incentives, where maybe the only immediate option for Community action is through the enhanced co-operation procedures of like-minded and proactive member states.

"It is highly relevant to note that on the same day that IPP is published, one of the most powerful tools for greening the market demand – green public procurement – is in the process of being undermined.", says Roberto Ferrigno, the EEB’s EU policy unit co-ordinator. "Yesterday the European Parliament’s Legal Committee proposed to effectively exclude the use of production- and process-related environmental criteria from the procurement award, and to restrict the economic benefit exclusively to the purchasing authority - despite the Court of Justice deciding last September that it could also be to the advantage of the ‘public at large’. This appears to be a clear indicator of the low level of understanding and political ambition that exists on IPP – both from within the Commission and the other EU institutions."

Some non-exhaustive additional comments.

More specifically the IPP communication fails to provide:

• Clear environmental objectives – the Commission does not even go so far as to mention the concrete commitments in the 6EAP and other existing policy ambitions – Kyoto, Ospar, POPs, marine strategy, air quality FWD, waste prevention strategy etc
• The ‘paradigm shift’ – ie a clear indication of the direction and scale of the future innovations necessary – ie towards use of service and whole systems innovation to achieve the level of environmental performance necessary to respect ecological limits.
• Concrete support of tools such as reduced VAT on EU Ecolabels, this is especially regreatable in view of pending negotiations on the amendment of the 6th VAT directive
• Concrete activities on consumption - such as a working group towards a policy to deal with this - despite recognition of the problem of increasing consumption
• No clear map on the development of Product Information requirements or Product Data Files
• No mention of potential of Producer Responsibility for Environmentally sound products as a driver for ‘mass integration’ of life-cycle thinking and environmental considerations into manufacturing and the standardisation process
• Recognition of the necessity to create efficient, tailor-made resources such as the IPP or Benchmarking Institute in the style of the IPPC Seville Bureau and setting up of important ‘consumer information tools’ such as EU Eco-test networks
• Recognition of the usefulness of individual responsibility as employed by the WEEE directive

Furthermore, whilst product pilot projects may be useful, it is a pity that the Commission did not stick to its original commitment to start ‘learning by doing’ in 2001. Furthermore, it remains to be seen what the Commission can do with the results of such ‘learning by doing’ if there is no legal mandate to use the results.