Action Plans on Sustainable Consumption and Production and Sustainable Industrial Policy - EUROFER contribution to the Internet consultation
Action Plans on Sustainable Consumption and Production and Sustainable Industrial Policy
EUROFER contribution to the Internet consultation
EUROFER regrets to discover that only one of the pillars of sustainability is emphasised in the background paper for the consultation on the Action Plans on Sustainable Consumption and Production and Sustainable Industrial Policy and would urge the Commission to also take the economic and social aspects of sustainability into account to a larger extent.
The steel industry is currently working on several important research initiatives that aim at reducing the environmental impact of steel production and use including production of better steel products and new and improved applications. These include:
In the context of the ongoing review of the IPPC Directive, we support the tentative suggestion that a mechanism be introduced to permit temporary derogations from permit obligations during the testing of new, innovative techniques (as long as this is not taken by the MS competent authorities as a justification for imposing conditions that go beyond what is achievable with BAT).
Where technology will be successfully translated into innovative products and services it needs to provide significant competitive strengths. Intellectual property rights need to be observed in any case of technology transfer.
For example, current Life Cycle Assessment (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.
To transform the European Platform for Life-Cycle Assessment into a Data Centre for environmental performance of products seems very ambitious. It is naïve to think that this “Data Centre” will be able to provide all information necessary to make advanced comparisons of complicated products in a correct and fair manner.
It is essential that all comparisons of products must be made on a like for like basis i.e. at the functional level and not at the individual product level. For example, in the specific case of building construction, comparison of products should look at the building as a whole since the use of one particular product will affect the design of the rest of the building, and hence its environmental performance (e.g. steel framed construction can significantly reduce the mass of foundations required).
Eurofer believes that Environmental Product Declarations (EPDs) should be standardised and streamlined so as to minimise costs to manufacturers, and at the same time adequately reflect the true net contribution to sustainability. So far,EPDs only account for the environmental aspects of sustainability, and further research is required to develop systems for recognising the social and economic benefits of products. Equally important, they should cover the full life cycle of a product, including the benefits associated with recycling at the product’s end-of-life. In the case of steel, the use of standard LCI data for steel production would be a step in the right direction, given that there is little environmental benefit in differentiating between steel manufacturers in the EU.
Eurofer is convinced that eco-design of non-energy using products will have a much lower environmental benefit in comparison to the potential for energy-using products, although further enhancement of the recyclability of these products would increase resource efficiency and reduce waste. Eco-design instruments should therefore always take the full life cycle of a product into account.
Eurofer supports the idea of improving resource efficiency along the supply chain. However, we seriously doubt that effective indicators can be established and also believe that the proposed 3% per annum resource productivity improvement is too ambitious and most probably unachievable. It is too simplistic to point to the current average 2.2% efficiency saving year on year and assume that this can be further improved in the future: in reality, the law of diminishing returns applies and each incremental improvement becomes increasingly difficult to achieve. Also, the GDP does not indicate individual performances. Thus an indicator based on domestic figures cannot stimulate sectoral or even company’s productivity gains.
In any case, there is a danger that the setting of too ambitious targets could have unforeseen consequences and be counter-productive. For example, indicators established for each material type could constrain positive shifts between materials. Moreover, the establishment of non material-specific targets might result in negative shifts between materials in a drive to reduce overall consumption at any cost. For the steel industry a “distance-to-target” approach for the production seems reasonable, taking into account the part of production impacts over the whole life cycle and the actions taken in the past decades.
We strongly assert that the IPPC Directive, with its integrated approach taking environmental objectives (including cross-media effects), local conditions and economic aspects into account in a balanced manner, is the key to delivering continuous improvement in the efficiency of EU production. Any additional measures will complicate the regulatory landscape and will detract from the benefits that IPPC provides. In particular, we strongly oppose any proposals (for example those alluded to in Section 4.4.2) for any emissions trading scheme for pollutants already regulated by IPPC. See industry PP on SO2/NOx ET
We agree that IPPC should be implemented consistently across all member states and we have made some positive suggestions along these lines in our communications with the Commission (for example, we support the inclusion in the revised Directive of an article that makes it mandatory for MS competent authorities to justify deviations from BAT AELs when setting permit conditions). We do not accept that the current inconsistency of application of IPPC should be interpreted as an inherent weakness of the regime. Rather, it reflects that we are still in the early stages of implementation and that competent authorities and industry alike are still on a steep learning curve.
The circumstances in which operators can be required to go ‘beyond BAT’ are set out in the IPPC Directive. We strongly oppose the introduction of any additional regulatory or financial measures to ‘incentivise’ operators to go beyond BAT. Any such measures would detract from the underlying concept of IPPC. In addition, we strongly believe that EMAS should remain voluntary.
The steel industry will not support the introduction of any further market based instruments that would introduce additional burdens, thereby reducing the competitiveness of a sector that is operating in a highly competitive global market where regional costs cannot be passed on to its customers. See MBI PP
Eurofer does not agree with the introduction of differentiated VAT for products based on their environmental performance as the current methods for evaluation of products have significant deficiencies (see sections above on LCA and Data Centre) and are far from fair and transparent.
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. An earlier 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 political pressure. 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. 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.
We believe that sectoral agreements are the way forward as far as climate change policy is concerned and we are pleased to see that then Commission appears to share this view. Levelling the playing field for industry worldwide would create fair global markets and international sectoral approaches for energy intensive industries offer a significant potential to set global baselines for energy and material efficiency and foster technologies that meet these baselines.1BusinessEurope Position Paper on the ETS review, July 2007: A further method of encouraging linking could be the development of sector approaches, for certain sectors, as expressed by the Commission in the January Climate Change package (COM 2007-2) which notes “another option is the introduction of sector-wide company-level emissions trading in sectors where the capacity exists to monitor emissions and ensure compliance particularly for energy-intensive sectors such as power generation, aluminium, iron, steel, cement, refineries and pulp and paper, most of which are exposed to international competition. Such schemes would be either global or national; if national, schemes in developing countries should be linked with schemes in developed countries, with targets for each sector covered being gradually strengthened until they were similar to those set in developed countries. This would also limit the transfer of high-emission installations from countries where they are subject to reduction commitments to countries where they are not.”
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