EUROFER final Position Paper on Integrated Product Policy

EUROFER Position Paper on Commission’s Communication on Integrated Product Policy COM(2003) 302 final

IPP should be firmly embedded in a Sustainable Development framework to obtain an appropriate balance between the environment, social and economic aspects for products.

The close links between IPP and the Resource strategy, the Recycling strategy and the Environmental Technologies Action Program (ETAP) is welcomed, but it is essential to ensure that these initiatives are consistent with one another and do not overlap or conflict. We concur that the involvement of all stakeholders is absolutely vital.

In the text below, we elaborate further on the content of the Commission Communication on IPP and trust that our comments will be take into consideration in the on-going development of this policy.

Principles:

Life-cycle thinking

We support the Commission’s proposal to use of life cycle thinking, which is a vital part in a holistic approach. However, the approach should not be confused with the methodology of life cycle assessment. Our views on LCA are expressed below under the heading “LCA”.

Working with the market

As this is such an extremely difficult and sensitive matter, we would like the Commission to elaborate further on how it should be implemented. Promoting green products is a fine objective, but which criteria would define a product as “green”?

Stakeholders involvement

The participation of stakeholders is very much welcomed. In this respect, we believe that consumers (whether as individuals or members of an organization) have an important role to play. However, this raises the issues of consumer education and awareness as well as understanding the factors that influence consumer purchasing patterns.

Variety of policy instruments

A variety of policy instruments are essential. These instruments will have to be carefully developed so as to avoid duplication/conflict with other legislation, and should embrace all three pillars of sustainable development and ensure the inclusion of all stakeholders. This holistic approach requires clear understanding of the current material/production systems at macro level and needs to be supported by the development of tools for evaluation of induced changes.

As IPP is a new and developing concept, many uncertainties remain and are open to interpretation. Therefore, at this moment, it would be premature to develop legislative initiatives. We should therefore rely on voluntary initiatives to implement and integrate a product policy.

Toolbox:

Products with potential for improvement

The differentiation between environmental performance of products is a very complex issue. It will be extremely difficult and almost certainly counterproductive to try to distinguish between “green” and “non-green” products. Especially, as there is currently no accepted methodology to make such a distinction. Furthermore, we would like to emphasize that LCA in its current form is not suitable for this purpose.

It is essential that the eventual methodology is based on sound science, has a holistic approach and incorporates all aspect of Sustainable Development.

Public procurement

It is essential that the criteria used for the development of a product group data base are relevant to their function. Once again these criteria must be based on sound science, have a holistic approach and incorporate all aspects of Sustainable Development. In order achieve this objective, such criteria have to be developed in conjunction with industry.

Eurofer cannot support criteria based on current eco-labelling systems. Our views on eco-labelling are given below under the heading “Eco-labelling”.

Life Cycle Assessment (LCA)

As stated previously, current LCA (and LCI) methodologies are not yet sufficiently developed to permit comparison of products or materials. There is also a need to further develop other closely linked methodologies like Life Cycle Cost (LCC) and Life Cycle Social Aspects (LCSA) in order to embrace sustainable development.

Eurofer supports the Commission’s initiative to provide a platform for communication and exchange of life-cycle data. However, it needs to be recognised that this is a major, long-term exercise. Ongoing work within ISO, UNEP and other organisations has to be taken into consideration. Eurofer would like to contribute its expertise and knowledge to develop best practice guidance.

Eurofer would like to issue a warning concerning simplified LCA tools. As LCA itself is a simplified model of the real world, with many short comings, a simplified version would only increase the uncertainties and make it less precise (sometimes missing the goal – environmental protection- completely). We believe that the limitations would outweigh the benefits and that there would be serious risks for abuse.

Environmental Management Systems (EMS)

Eurofer has concerns about EMAS adapted to incorporate products and its relationship to the global and more widely used ISO 14001. Especially as the steel industry operates in a global market.

Product design obligations

In the context of product design we would encourage the Commission to take a look at other initiatives in this area e.g. the ISO Technical Report (ISO/TR 14062:2002) on integration of environmental aspects into product design.

Eco-labelling

In principle, Eurofer supports the concept of eco-labels when the criteria are relevant for the product under consideration (e.g. recyclability rather than recycled content). However, in their current form, eco-labels do not provide consumers with relevant, reliable and easily understandable information. Furthermore, the criteria are not developed to be holistic and do not consider the risk of sub-optimisation, i.e. shifting the environmental impact to another area or product.

Recent experience with the development of an eco-label for furniture revealed that the proposed criteria for steel were not environmentally relevant and were only introduced due to pressure from other stakeholders. This is evidence that the system is political and subject to compromises which result in information to consumers that is both biased and very difficult to understand.

Eurofer’s position paper concerning the criteria for steel in the proposal for eco-labelling of furniture is attached for information.

EPDs

Eurofer supports the Commission’s initiative to develop a common methodology for Environmental Product Declarations (EPDs).

Indicators

Eurofer proposes that sustainability indicators are developed to measure improvements that result from the IPP approach. Such indicators must be holistic, quantifiable, simple and transparent.

Eurofer proposals for IPP

Eurofer would like IPP to include the following:

• A section devoted to the sustainable use of materials. Its aim would be to ensure that future generations have the opportunity to enjoy the same diversity of materials, but in a manner that also protects human health and the environment.

• Development of design guidance [including life cycle costing, selection and use of materials and planning of product life cycles (cradle to grave)].

• Development of an education programme for designers on eco-design criteria and the sustainable use of resources.