15/09/2003
Integration of environmental aspects in standardisation
CIAA comments on the Commission working document for a Communication on
the integration of environmental aspects in standardisation

CIAA, the voice of the European food and drink manufacturers, welcomes this stakeholder consultation on the integration of environmental aspects in standardisation.

CIAA members have for some time been active in numerous areas of standardisation. This involvement includes notably the work of CEN/TC 261 ‘Packaging’ and CEN/TC 308 ‘Characterisation of Sludges’.

Based on this experience, CIAA wishes to provide valuable input in this consultation and has made several comments on the various ideas proposed in the working document.

General comments
CIAA fully supports the voluntary standardisation process at international and EU levels in opposition to mandatory product design prescriptions.

We agree that integrating relevant environmental aspects in standardisation can make positive contributions to the protection of the environment and has actually already contributed to do so.

It should indeed be noted that several CEN Technical Committees develop standards that include and promote environmental goals as part of the industry commitment.

We hope this consultation will highlight that a certain flexibility is required to ensure an appropriate level of integration of relevant environmental aspects.

Specific comments

Questions 13, 14 and 15 – Setting priorities
Setting priorities is essential and this should be done in an open and transparent consultation with all stakeholders. We do not encourage, however, to set priorities from an isolated environmental perspective at all because other essential issues such as safety and health might be affected or neglected.

In the same way, standards are primarily used for fostering the internal market competitiveness by common technical specifications. We should not either lose sight of this objective.

Questions 17 and 20 – European and national discussions of standardisation
Given the globalisation of the market, efforts to improve the integration of environmental aspects should be placed on top at international level, followed by European level. National island solutions should be avoided as they could impede the good functioning of the internal market or even be contrary to WTO agreements.

Question 19 – Involvement of stakeholders
Standards should be developed with the cooperation and consensus of all relevant stakeholders. From the beginning of the standardisation process, a broad representativity of stakeholders (business, NGOs, SMEs etc.) should be ensured so as to avoid last-minute opposition and veto on the outcome of the discussion. We believe that the Commission funding, which is now available to help other stakeholders to participate in standardisation, can play a significant role facilitating a broad panel of stakeholders to be represented in the process.

Question 22 – Standardisation and eco-labelling
CIAA is highly preoccupied by the idea of ‘cross-fertilisation’ between eco-labelling and standardisation.

We do not see any value to use the eco-labelling for the production of European standards. Eco-labels and standards do not have the same objectives. Besides, environmental standards should be related to ensuring environmental improvement (process-oriented) and not establish product specifications, which is the case of eco-labels.

Conclusion
CIAA supports the aim of integrating relevant environmental aspects in the development of standards where these are appropriate. We believe that the greening of standardisation should however be done step by step balancing what industry can do based on existing equipment and technology, and increased availability of new technologies.