The sustainability of goods and services is of increasing concern to the public at large. No product or service is delivered without an environmental or social cost. As a result, many consumers are coming to base their purchasing decisions not only on quality, price and availability, but also on the environmental and social aspects associated with the product or service. Sustainability therefore plays a significant role in consumer product policy and standards.
The work programme of the Sustainability sector also encompasses the ANEC strategy on how to reduce exposure from hazardous chemicals in consumer products. Further to actions planned in the sustainable consumption and production policies, ANEC has specific interest in the EU strategy to achieve a non-toxic environment foreseen in the seventh EU Environment Action Programme (7EAP).
Please see more on the Page on Chemicals.
ANEC focuses on consumer and health related concerns with regards to the EU environment policy priorities for 2020, in the implementation of the seventh EU Environment Action Programme (7EAP). Better application of existing technologies and more consideration of environmental implications already in the product design stage can make an enormous contribution to environmental protection. ANEC has since long collaborated with its sister organisation BEUC on the consumer expectations from the European Sustainable Consumption and Production (SCP) Policy.
Also, in light of the amount of information that consumers are bombarded with when purchasing (green) products, consumer organisations warn that consumers should not be expected to take all the responsibility for overconsumption and consequent excess of waste. In our activities, we have advocated instead for an enhancement of the EU environmental related product regulation establishing performance requirements using synergies between different existing environmental instruments.
ANEC keeps calling for the level of ambition of existing SCP policy tools such as Ecodesign, the Ecolabel and the Energy label being maintained and enhanced.
ANEC collaborates with BEUC – the European Consumer Organisation - on defending and representing the consumer perspective in the implementation of the Ecodesign Directive and the Energy labelling of consumer products.
ANEC also cooperates with ECOS – the European Environmental Citizens Organisation for Standardisation – in a project to represent environmental and consumer NGOs in Ecodesign related standardisation.
To find out more, please visit ANEC website page on Energy.
We all agree that resources are finite and, sooner or later, the limits to further growth of material and energy flows will be reached. However, to ANEC, it is difficult to see how the long-awaited Commission communication ‘Closing the loop - An EU action plan for the Circular Economy’ could contribute to the desperately needed fundamental change of direction associated with significantly reduced resource use, as opposed to the concept of infinite growth enriched with circular flows.
In our position paper, we stress the discussion on circular economy risks being misled from the onset if we lose the key aim of a strategy leading to sustainable development. The final objective shall remain the socially acceptable reduction of the use of resources and of environmental and human health impacts. There is also a need to develop measures based on meaningful, robust and verifiable indicators and we believe any policy measures should bring about changes in a foreseeable future. We call for a ‘resource-saving economy’ including circular elements, rather than reversing the order and going for a ‘circular economy’ in which resource saving is a mere side aspect.
Environment-related labelling schemes need to provide clear and unambiguous information if they are to support consumer choice. This is not the case at the moment where there is an overload of information on environment-related labelling schemes and where inconsistencies exist among the different schemes. It is also important to provide clear scales of comparison, as in the case of the EU Energy Label. In addition to LCA-based information, important additional environmental information from other sources should also be taken into account (such as the impact on human health, risk assessment, eco-label criteria and declaration of chemicals), and such information should be displayed in formats that clearly indicate the relative magnitude of the environmental impact of one product compared to another one.
ANEC has been for long actively involved in the international committee for Environmental management standardisation ISO TC 207 and reacts to issues of consumer interest. ANEC is concerned that the enforcement of and compliance with environmental standards and, in particular, labelling schemes vary between Member States across the EU. This issue is of great importance to consumers as without independent validation of claims made by manufacturers, the reliability of label information cannot be checked and the schemes are open to abuse. Furthermore, if the label is not displayed correctly, the consumer cannot make an informed choice.
The European Commission is proposing a harmonised methodology for the calculation of the environmental footprint of products, services and organisations based on a Life Cycle Assessment (LCA) approach. ANEC, as well as industry stakeholders, strongly oppose the use of Product Environmental Footprint/Organisation Environmental Footprint as basis for the SCP instruments and environmental labelling schemes. Studies conducted by ANEC have highlighted the methodological constraints of the LCA approach such as lack of precision, limited comparability, difficulty to identify superior products or omission of relevant environmental aspects.
Life cycle assessment is a suitable tool for orientation at the onset of indicator development or regulatory requirement setting. However, suitable production, consumption or disposal indicators are typically more robust and in many ways more meaningful or relevant as well as cheaper; they can be measured and are easier to verify.
In its position paper 'Environmental Assessment goes astray: A critique of environmental footprint methodology and its ingredients' ANEC criticised that many LCA indicators are used for advertising, but do not necessarily provide sound information to help consumers to choose an environmentally friendly product. We confirmed that LCA methodology features fundamental shortcomings including the dependency on numerous subjective choices, lack of adequate data and limited precision, and is not suited to adequately address certain environmental impacts at all. ANEC criticises Life Cycle Assessment (LCA) as a tool for the measurement of environmental impacts of products and organisations and calls on the European Commission in particular to re-think its approach to environmental assessment. ANEC put forward an alternative approach to that of the European Commission, also proposing a framework for the selection of environmental indicators. Although the critiques of ANEC and other stakeholder delayed the process, the Commission still published the package "Building the Single Market for Green Products” in April 2013. The Commission encourages private actors to use the environmental footprint methodologies on a voluntary basis. ANEC is following the three-year testing period for the methodologies.
Construction products should not pose a threat for the occupants or the environment. Standardisation in construction facilitates the equal assessment of environmental, economic and social aspects of sustainability of construction products, buildings and services. Also the communication to the consumer, preferably by labelling, plays an important role. The ambition of ANEC is to establish a harmonised and coordinated EU policy which leads to a significant reduction of all environmental burdens associated with buildings and takes into account both the businesses’ and the consumers’ interests.
ANEC calls on a European concept of sustainability in buildings, involving all relevant actors and ongoing activities, for the development of a suitable framework to address environmental issues in the construction sector by using a broad range of environmental assessment instruments. ANEC advocates the work on any European building related specification to establish criteria based on well-established national building schemes which have shown their usefulness in practice for many years.This includes for example also European tools such as the Green Public Procurement (GPP) Product Sheet Construction. ANEC position paper ‘Sustainable construction - A building site without end. Alternatives to flawed standards’ gives further details on ANEC standpoints.
For several years, ANEC actively participated in CEN TC 350 ‘Sustainability of construction works’ and its Working Group 3 ‘Product level’. In light of the limited uptake of the consumer concerns over the years, we reduced our input to monitoring and reacting when issues of crucial consumer concern are addressed. ANEC believes that the goal of standardisation work in CEN TC 350 should be the equal assessment of environmental, economic and social aspects of sustainability of products, buildings and services and its communication to the consumer (preferably by labelling).
Specific stipulations that lead to comparable results are needed. The results of the standardisation work have been disappointing from a consumer perspective and in particular we deem EN 15804:2012 Sustainability of construction works. Environmental product declarations. Core rules for the product category of construction products unacceptable. ANEC expressed its views in the ANEC paper ‘Sustainable construction - A building site without end. Alternatives to flawed standards’.
Separately, ANEC was also involved in the development of Ecolabel criteria for buildings and EMAS - EU Eco-Management and Audit Scheme sectoral documents for buildings. ANEC has especially welcomed the latest draft of the EMAS Reference Document, 'Best environmental management practices' (BEMPs) in the construction sector, developed by the Institute for IPTS of the European Commission Joint Research Centre. The document takes into account the findings of the ANEC study on environmental & health-related criteria for buildings. It provides an overview of the common specific indicators for the construction sector and derived benchmarks.
In our position paper 'Laying the foundations for sustainable buildings', we call for the development of a European strategy for sustainable construction to achieve reliable sustainable performance assessment of buildings and provision of meaningful measurement indicators and information to consumers and construction professionals. ANEC believes energy performance remains crucial for the overall environmental performance of buildings, as we highlighted also in our response to the Consultation on the Evaluation of the Energy Performance of Buildings Directive.
ANEC highlights a more consistent and harmonised methodology is required to improve the reliability of energy performance certificates of buildings. It is important to streamline the variety of calculation methods used in Member States, and various indicators used in energy performance certificates. Such a rationalization should derive from an open discussion about the strategies, concepts, environmental indicators and benchmarks that should be pursued to achieve a truly sustainable buildings sector.
In the framework of the resource efficiency debate, ANEC also outlined the consumer perspective in a paper on the common EU framework of core indicators for the environmental performance of buildings, and published a related position paper.
Current CSR reporting schemes are not fully comparable and often impeding reliable benchmarking. In its position paper on Corporate Social Responsibility (CSR) reporting, ANEC argues that an ineffective reporting scheme can trigger greenwash or the advertising of pseudo-sustainable products and services.
ANEC believes a European approach to corporate accountability reporting should therefore be started with guidelines for non-financial reporting. A first set of requirements and indicators could be built upon, supported by more detailed and comprehensive reporting requirements and indicators later. (See also ANEC paper). The broad discussion needs to take place in a democratic multi-stakeholder platform. We included our requests in our reply to the EC’s public consultation on non-binding guidelines on methodology for reporting non-financial information.
ANEC also participates on a specific committee on sustainable and traceable cocoa, CEN TC 415. The committee aims at developing three standards - one on sustainability, one on traceability and one on requirements for the certification of sustainable and traceable cocoa. It addresses in addition to human and labour rights issues such as empowerment for e.g. of farmer organisation and basic needs such as access to quality education and literacy/numeracy.
CEN Strategic Advisory Body on Environment (SABE) plays an important role in the development of positions in the environmental field based on discussions with relevant stakeholders. Participating in SABE’s activities is therefore crucial for ANEC. CEN SABE ENIS team ‘Environmental Issues in Standardization’ has a special focus on addressing Environmental aspects in product standards (including services). In relation to ANEC participation in SABE activities, ANEC has also been promoting the greening of standards in the committees and working groups in which we are involved.
As a response to ANEC member, ASI Consumer Council’s intense work, SABE also agreed to set up an ad hoc group to work on the development of guidelines for addressing chemicals in products standards in a consistent manner. ANEC participates in the multi stakeholder panel of experts responsible for advising the project team and looks forward to the implementation and use of the guide in relevant technical bodies.
Resource efficiency has become one of the key political priorities of the Commission to foster sustainable growth and to shift towards a resource-efficient, low-carbon economy. The Commission is currently looking into possibilities to develop indicators for measuring resource efficiency. ANEC believes that indicators should make resource inefficiency visible, thus allowing to set requirements through ecodesign or other policy instruments which can help to keep/ lower costs for consumers during the use phase.
Another initiative of the Commission is to limit the negative impacts on the environment is to cut down waste. ANEC has given the consumer input to DG Environment consultations on resource efficiency indicators, plastic waste reduction, and in particular of plastic bags, and we will bring forward consumer requirements in this area, asking for reduction targets from a broader perspective looking at e.g. durability of appliances. ANEC supports the notion of mandatory requirements on packaging optimisation and a minimisation by strengthening existing instruments, in particular the Packaging Waste Directive. The most effective measure to reduce the use of plastic bags would be to ban the use of disposable carrier bags.
ANEC is represented in, or monitors, the work of various Technical Committees dealing with environmental issues at both the European and international level:
- ISO TC 207 ‘Environmental management’
- CEN TC 415 ‘Sustainable and traceable Cocoa’ and ISO TC 34 SC8 ‘Cocoa’
- CEN SABE ‘Strategic Advisory Body on Environment’
- CEN/SABE/ENIS - Environmental Issues in Standardisation
- CLC TC 111X ‘Environment’
- CEN TC 350 ‘Sustainability of construction works’
- CEN TC 261 ‘Packaging' SC4 ‘Environment’
- CEN TC 444 ‘Test methods for environmental characterization of solid matrices’
European Commission groups:
- European Commission Integrated Product Policy (IPP/SCP) Regular Group
- European Commission Ecolabelling Board Working Group ‘Buildings’
- European Commission Environmental Footprint Steering Committee
On 30 November, the EC published its “Winter Package”, proposing ‘new rules for consumer-centred clean energy transition’.
The measures relevant for consumers focus on:
- setting the framework for improving energy efficiency in general
- improving energy efficiency in buildings
- improving the energy performance of products (Ecodesign) and providing information to consumers (energy labelling)
- finance for energy efficiency, with the smart finance for smart buildings proposal.
ANEC finds the measures relating to energy efficiency in buildings of particular interest. Based on earlier consultations, the EC has proposed a review of the Energy Performance of Buildings Directive (EPBD) and relevant articles of the Energy Efficiency Directive (EED).
ANEC contributed to the public consultation on Evaluation of the Energy Performance of Buildings Directive (EPBD) last year and released the position paper, 'Laying the foundations for sustainable buildings'. We called for development of a European strategy for sustainable construction to achieve reliable sustainable performance assessment of buildings, and provision of meaningful measurement indicators and information. We welcome the intention to encourage the energetic retrofitting of buildings. Quality and comparability of Energy Performance certificates (EPCs) remain to be improved in light of the enhancement foreseen in the proposal, and the intention to set up EPC databases.
In October, ANEC responded to the consultation, ‘Towards a common EU framework of core indicators for the environmental performance of buildings’, and published a related position paper.
The EC 2014 Communication on Resource Efficiency Opportunities in the Building Sector identified the need for a common EU approach to the assessment of the environmental performance of buildings. The starting point would be a 'common framework of core indicators' to drive improvement in performance and allow for comparison between buildings. A study was initiated by the EC in 2015 (also considering the circular economy package) to develop an initial framework of core indicators, with the idea that they would be flexible in their use, so could potentially be incorporated into new and existing assessment schemes, or be used on their own by a diverse range of stakeholders.
ANEC regrets the EC consultation gives a biased interpretation of the environmental indicators to consider in the construction sector. We consider the suggested approaches by the authors questionable or only partly suitable. In addition, several critical issues are not addressed.