Options to improve the implementation of the EU Ecolabel Regulation EUEB Meeting 16 April 2015, Brussels Hugo Schally, Silvia Ferratini, Sylvie Ludain, DG ENVIRONMENT, EUROPEAN COMMISSION 1
Background The Commission invited Competent Bodies/Member States to provide views/opinions on how to improve the implementation of the EU Ecolabel (EUEB meeting, November 2014) Suggestions received from: 6 CBs/MSs, 1 NGO,2 industry associations providing options implementable: Through a potential future revision of the EU Ecolabel Regulation or In the framework of the current EU Ecolabel Regulation
Suggestions for improving the EU Ecolabel through a potential future revision of the Regulation will be considered in case the results of the REFIT exercise call for a revision of the EU Ecolabel Regulation. Today we focus the discussion on suggestions for improving the EU Ecolabel in the 3
Improving the EU Ecolabel in the Suggestions related to: The EUEB The Regulatory Committee CBs and CB Forum Criteria Process for criteria development and revision Communication and promotion 4
Suggestions on the EUEB's role (1/2): The EUEB should: Discuss only strategic, political and horizontal issues and work to achieve consensus on these issues Not be used for detailed technical discussions on criteria (it is the role of AHWGs, or of special sub-meetings on horizontal issues that could be arranged) Agree on a "road map" for the developement/revision of criteria with priorities and timetable (not more than 6 product groups to be revised at the same time). 5
Suggestions on the EUEB's role (2/2): The EUEB should have more time to prepare for the meetings timetables, draft criteria and guiding information should be circulated in advance (8 weeks, or before the ISC). Last minute changes in the criteria should be avoided to allow EUEB members sufficient time to consult stakeholders/superiors Draft criteria should be presented to the EUEB together with the comments received (from the EUEB and the CB Forum) and with EC's responses/recommendations, and only if consensus across MS has been secured in advance. 6
EUEB Role - Our answers (1/3): Yes to EUEB to be more political than technical; avoidance of reopening close discussions CBs to increase participation/follow up of AHWG meetings Workplan to better include a "road map" for the developement/revision of criteria with priorities and timetable Not possible to limit to 6 the number of revisions carried out at the same time but only successfull PGs to be continued, new PGs to be limited. Moreover N of drafts of documents and related presentations reduced as much as possible. PGs presentations on intermediate drafts of criteria revisions (when needed) to focus mainly on key points that require EUEB decisions (to be circulared in advance). 7
EUEB Role - Our answers (2/3): Agreement of Commission Services on the text of criteria to vote to be sought in advance in order to limit the last moment changes as much as possible Draft criteria to vote to be circulated to EUEB members with technical report and list of comments received EUEB members and stakeholders to respect deadlines for comments The only possibility to extend the time for circulating comments is the reduction of the EUEB meetings from 3 to 2 ( Amendment to "the European Union Ecolabelling Board Rules of Procedure") 8
EUEB Role - Our answers (3/3): Should we, on ad-hoc basis, reduce the N of meeting weeks from 3 to 2 per year? e.g for 2016 Instead of 3 meetings: Only 2: March: vote TAS and WFC June: vote detergents and cleaning services Nov: political meeting April: vote TAS and WFC Nov: vote detergents and cleaning services Pro: more time to prepare docs and for CBs to get prepared; less meetings to prepare and attend; more free projects' cycle (for criteria revisions); more environmentally friendly Cons: vote for detergents and cleaning services delayed (need to further prolong current criteria); no meeting dedicated entirely to political discussion (but do we need this?); more use of the Virtual CB Forum (we can moreover decide to have 2-day CB Forum each time) 9
Suggestions on Regulatory Committee: The voting intentions and opinions should be collected by the EC at least 2 weeks prior to the meeting There should be no changes to the text to be voted within the 24 hours preceeding the meeting. 10
Regulatory Committee - our answers: MSs consensus can be sough in advance Last minute changes to the text to be voted within the 24 hours preceeding the meeting should be avoided 11
Suggestion on CBs and CB Forum : CBs should better harmonise the way the work; application forms should be the same (differences could prevent a level playing field and entail duplication of work) CB should: Have a strengthened role to harmonize the work of Competent Bodies and their interpretation of the criteria Be a platform to build knowledge, share information and exchange experience (eg. organisation of workshops on new product groups) Share information/practice on promotional approaches including a shared online platform. 12
CBs and CB Forum - our answers: User Manuals and included forms should be used by all CBs Database on CIRCA now available with the results of all physical and virtual CB Forum discussion Marketing session to be planned regularly (on-line platform?) Any proposals on how to strenghten harmonisation? Establish list of "expert CBs" per each PGs? 13
Suggestions on EU Ecolabel criteria (1/2) The precautionary approach in developing criteria is working against the successful implementation of the scheme. A scientific, risk-based approach should be taken to developing criteria Too many environmental impacts (including non significant ones) are tackled: N of criteria to be reduced, focussing on the (3-4) most important impacts identified in the LCA, but maintaining the environmental credibility and selectivity of the EU Ecolabel. There should be no fixed limited N of criteria. The EU Ecolabel should remain an instrument of environmental excellence covering ambitious criteria at all important stages of the life-cycle of a product (rather than limiting it to a number of 5 pre-defined issues). Criteria should be easy to understand and to apply. User Manuals should be developed and published in tandem with criteria. 14
Suggestions on EU Ecolabel criteria (2/2) Before adding social/ethical criteria in the EU Ecolabel, workability of the criteria and costs for their compliance need to be considered. Hazardous substances: The standard text copied in all criteria documents is too complex and not sufficiently clear. A new legal interpretation of provisions on hazardous chemicals should be found The possibility to include intermediate products during criteria development/revision should be exploited. To create more sustainable supply chains, producers meeting part of the criteria for a product group should be enabled to obtain an EU Ecolabel license. 15
EU Ecolabel criteria - our answers: Indeed it is not possible to set a precise number of criteria but the number of criteria should be reduced, they should focus on the main environmental impacts. Right balance to be found between simplicity (in terms of N and requirement) and need to mantain a high credibility of the scheme - This is a joint effort that all stakeholders should embrace. Efforts to be increased to produce UMs timely. Workability and cost of social and ethical criteria (as well as the environment ones) should be ex-ante estimated to the extent of possible. Standard text on hazardous substances to be removed in future revisions; work in progress to improve the implementability of Art. 6.6 and Art. 6.7. Open-mindedness to the labelling of intermediate products (issue to be discussed at the next EUEB?) 16
Suggestions on Criteria development/revision (1/2): A "road map" agreed by the EUEB to be developed prior to developing/revising criteria for a product group priorities and timetable. Prior to developing/adding new product groups, it should be verified what the market penetration of the exisiting product groups is, and what proportion of the market could meet the proposed criteria. Criteria to be developed for products/services that really benefit from a multi-criteria approach (vs single issue product groups). Criteria to be consistent with wider SCP activity/tools (eg. ecodesign). EU Ecolabel and GPP should harmonize their requirements as much as possible. Sufficient resources to be foreseen (including at EC level) to revise existing criteria in time and develop new criteria. 17
Suggestions on criteria development/revision (2/2): Alignment opportunities and mutual recognition with other type I ecolabelling schemes need to be explored for every product group under development or revision Changes to existing criteria documents should be made faster: less complicated criteria decisions could be delegated to the EC or the EUEB or to a board within the EUEB, or necessary changes could be agreed using a gentlemen's agreement at the EUEB or the CB forum level Need to develop a practical methodology to use the shortened procedure for criteria development and revision as envisaged by the Regulation. 18
Criteria development/revision our answers (1/2): Not clear what a "road map" means; at the starting of each revision we have a detailed planning that maybe can be shared with EUEB Members? In any case project milestones to be better indicated on JRC website Market penetration is roughly assessed before development of new criteria; proportion of market that could meet criteria very difficult to estimate. How are other Type-I labels doing? Yes to develop criteria for products/services that really benefit from a multi-criteria approach and to the consistency among SCP tools. EC Resources: The importance of the work on the EU Ecolabel recognised by the allocation of one additional post in 2015. However it is clear that the institution wants to see the results of the scheme. 19
Criteria development/revision our answers (2/2): Mutual recognition not possible at the moment but harmonisation to be further sought. Changes to existing criteria documents can be done through amendments unfortunately no gentlemen's agreements at the EUEB or the CB forum level are possible! The use of the shortened procedure for non-substantial revision of criteria may be sympler in the next round of revisions but would it be really possible in case of criteria already developed by other Type I ecolabels? 20
Suggestions on Communication, marketing and promotional support (1/2) Need to increase brand recognition and visibility among consumers and business operators More funding needed (including at EU level) for marketing campaigns to consumers and potential licence holders. Need for a clear definition of roles for communication/promotion between the EC, MS, NGOs, business operators, EU ecolabel license holders. Use communication "multipliers" such as NGOs, industry, etc. Need to develop communication on EU Ecolabel environmental benefits and for a better understanding of the label's environmental criteria Need to promote new and revised criteria when they are developed (eg. in collaboration with the industry). 21
Suggestions on Communication, marketing and promotional support (2/2) Need for a system to collect data/statistics to provide evidence of the benefits generated by the EU Ecolabel (information on product groups and licenses given, product group market share/penetration, information on whether revision to existing criteria lead to greater/fewer licence holders etc.) Need for an attractive and user friendly catalogue with all EU Ecolabel products, with much more search options. ECAT should be improved. 22
Communication, marketing and promotional support our answers Looking for funding for the development and implementation of a communication campaign at EU level But in the meanwhile joint efforts are needed from everyone, catalised by targeted CB Forum sessions. Everyone should be a multiplier (subscription to our Facebook page; provision of contents to our Newslaert+ Facebook page) Licence holders should be encoraged to communicate about the EU Ecolabel (success stories page on our website?) Need to develop a system to measure environmental benefits (maybe easier after the results of the Product Env Footprint pilot phase) Suggestions on how to build a system to collect data/statistics on market share are welcome We are starting improving ECAT For Tourism Accommodation and Campsites 23
Any other suggestion? Thank you for your attention! 24