28.5.2009   

EN

Official Journal of the European Union

C 120/56

—

considers organisations' environmental management systems and product Ecolabels to be a good, market-based means of encouraging environmental responsibility among various players in society and raising the level of environmental protection;

—

considers the EMAS regulation to be a useful instrument for many kinds of organisations, which could benefit in a wide variety of ways from adopting them, e.g. reduction in harm to the environment, cost savings (energy and waste disposal), certainty that environmental legislation is being complied with, more efficient operation, etc.;

—

believes that it is also necessary to define the scope of environmental performance assessment for organisations under the EMAS scheme, as well as the appropriate requirements for environmental audits at different levels, namely the primary (production), secondary (supply) and tertiary (other) levels of analysis. The information, skills and expertise needed for environmental audits are not available in all SMEs or local and regional authorities; rather, they have to rely on external consultants;

—

sees keeping the ex-ante evaluation procedure as important in terms of the European Ecolabel's credibility and reliability. Meeting the ISO standard requires the body responsible for the label to check both ex ante and ex post that the product for which the Ecolabel was requested meets the Ecolabel criteria. The proposal to switch from assessment to registration and ex post monitoring is a serious threat to the credibility and reliability of the label.

Rapporteur-general

:

Ms Britt Lundberg (FI/ALDE), Member of the Regional Government of the Åland Islands

1.

considers revision of the EMAS scheme and the EU Ecolabel to be particularly necessary and firmly supports the EU's objectives of promoting a sustainable product and consumption policy, as laid down in the Lisbon agreement and the Community's sustainable development strategy, also with a view to achieving the Community's climate policy goals;

2.

believes that the revisions are particularly necessary because neither scheme has had the uptake or impact that were originally aimed at;

3.

considers organisations' environmental management systems and product Ecolabels to be a good, market-based means of encouraging environmental responsibility among various players in society and raising the level of environmental protection;

4.

believes that local and regional authorities could also make more use of these systems, and that the revised legislation and Member State support measures should draw attention to the potential for both small and large public-sector organisations to make use of them;

5.

considers that although the proposal on the EMAS scheme includes quite detailed rules, procedures and requirements, it still complies with the subsidiarity and proportionality principles (implementation being left to the Member States or their local and regional authorities). The Ecolabel scheme is not exclusive, but can operate in parallel with national and regional schemes, provided these are based on rigorous criteria;

6.

believes that neither of the two schemes, which are based on voluntary participation, creates unnecessary burdens — the development and revision of the criteria for the Ecolabel are flexible, and the proposal for the EMAS scheme provides for flexible rules;

7.

believes that the proposals are consistent with the European Commission's Better Regulation strategy (simplifying legislation and reducing administrative burdens for business and public authorities);

8.

considers the EMAS regulation to be a useful instrument for many kinds of organisations, which could benefit in a wide variety of ways from adopting them, e.g. reduction in harm to the environment, cost savings (energy and waste disposal), improvement in environmental image, certainty that environmental legislation is being complied with, more efficient operation, etc.;

9.

supports the setting of measurable quantitative targets for the number of EMAS-registered organisations five and ten years after entry into force of the Regulation;

10.

believes that it would help to reach the target if the Member States were required to set their own targets for increasing the number of EMAS-registered organisations;

11.

strongly endorses raising the visibility of EMAS by every means possible, since for instance in the Nordic countries EMAS is hardly known or used in the public sector;

12.

believes that the structure of the regulation should take into account the perspective of the organisations planning to adopt EMAS. A key issue for such organisations is the structure of the EMAS scheme, which is tucked away in Annex II of the proposal. The easiest way to rectify this shortcoming would be to make Annex II an article in its own right, with the heading ‘Structure and requirements of the EMAS scheme’;

13.

welcomes the suggestion that national or regional environmental management systems should be able to acquire full or partial EMAS recognition, which if applied would help organisations to switch from these schemes to EMAS. This would give the EMAS scheme a large number of potential applicants for registration under EMAS that are already moving towards eligibility for EMAS. This would also improve the credibility of local schemes, as they would become a part of the EMAS scheme;

14.

considers that the Commission could set minimum requirements for schemes that are partially EMAS-compliant, so that applications are not made for separate elements of an environmental management scheme that cannot yet be defined as such a scheme;

15.

suggests that such minimum requirements could for instance be the following: an environmental policy under which a commitment is made to ongoing improvement; an environmental review specifying the environmental aspects of the organisation that have a significant impact on the environment; compliance with provisions of environmental legislation; environmental objectives covering important environmental aspects; an environmental programme or action plan setting out the responsibilities, measures and timetable for implementing measures in order to achieve environmental objectives; adequate resources for implementing the environmental programme; internal communication about the environmental management scheme at various levels within the organisation; and external audit of the environmental management scheme;

16.

considers that the guidelines on environmental reporting contained in Annex IV of the proposal should be improved. It is impossible in particular for small and medium-sized service sector businesses, and for instance local players, to calculate a number of the values envisaged, such as material efficiency. The amount of material used is so large that gathering data, even for most important materials, is often an insuperable task. The impact of organisations on biodiversity is also negligible for the majority of SMEs and small public-sector organisations, and reporting requirements that would affect them should not be proposed;

17.

believes that it is also necessary to define the scope of environmental performance assessment for organisations under the EMAS scheme, as well as the appropriate requirements for environmental audits at different levels, namely the primary (production), secondary (procurement) and tertiary (other) levels of analysis. The information, skills and expertise needed for environmental audits are not available in all SMEs or local and regional authorities; rather, they have to rely on external consultants;

18.

Questions the costs involved for public authorities and private companies in applying EMAS and the eco-label schemes; believes a broader participation in both schemes would be possible if the fees could be abolished or reduced. However distinction should be made for EMAS on the one hand and eco-label on the other hand because of different cost structure for participating organisations;

19.

Considers that businesses must be relieved of administrative burdens when introducing EMAS, although cutting back red tape must never result in a loss of the EMAS system's credibility in the eyes of the public authorities, consumers, or organisations likely to join the scheme;

20.

considers the objectives set to be a step in the right direction, especially opening up the development of Ecolabel criteria to different stakeholders and shortening the acceptance process, since in this way new products can be brought more quickly into the labelling scheme;

21.

Calls for the name ‘EU’ to be added to the label itself in order to make it clearer for the general public that the Ecolabel is a European Union initiative;

22.

considers the shortened criteria development procedure in other Ecolabel schemes to be useful for accepted product groups, since for instance the swan label in the Nordic countries and the German Blue Angel are such well-recognised brands in their own countries that they could give impetus to the EU Ecolabel;

23.

endorses the proposal to abolish annual fees for products that have been awarded the Ecolabel, because this removes the financial barrier to joining the scheme for many SMEs;

24.

welcomes the proposal requiring the parties concerned to produce a manual for authorities awarding public contracts. This will make it easier for public contractors to incorporate the Ecolabel criteria into their procurement procedures. A manual would be a welcome source of support for the work of the regional and local authorities;

25.

sees keeping the ex-ante evaluation procedure as important in terms of the Ecolabel's credibility and reliability. The European Ecolabel is a labelling scheme based on life-cycle assessment in accordance with ISO 14024, verified by a third party. Meeting the ISO standard requires the body responsible for the label to check both ex ante and ex post that the product for which the Ecolabel was requested meets the Ecolabel criteria. The proposal to switch from assessment to registration and ex post monitoring is a serious threat to the credibility and reliability of the label;

26.

does not endorse the proposal to make the criteria for national or regional labelling schemes at least as strict as the Community Ecolabel criteria in the case of those product groups for which EU Ecolabel criteria already exist. The stringency of labelling requirements applicable under different labelling schemes should be evaluated in the relevant context and in relation both to the environment and to the market. Many key labelling factors, such as the state of the environment, environmental stress and resistance, differ very widely between EU regions;

27.

believes it is particularly important that the Member States and Commission step up their awareness-raising and information activity for the Ecolabel. In this context, cooperation with traders may be the most effective approach, since from the consumer's perspective shops are the places in which decisions about choosing and buying products are most often taken, and thus shops have considerable power to influence those decisions;

28.

considers that the progressive growth in the range of products and services available to consumers, that satisfy the criteria for obtaining a Community Ecolabel, should be one of the priority aims. This growth needs to be promoted by supporting the development of design methods for products that meet the established criteria for the relevant product group throughout their life cycle. It therefore recommends that the competent authorities implement programmes to promote eco-design (based, amongst other things, on existing Ecolabel environmental criteria), to support businesses in this area, and to back pilot projects;

(11)

The establishment of a uniform national accreditation body should be without prejudice to the allocation of functions within Member States.