brave project report survey on eu

LIFE B.R.A.V.E. PROJECT – Survey on European EMAS enterprises

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Fabio Iraldo, Francesco Testa, Sara Tessitore, Tiberio Daddi,

Benedetta Nucci

EMAS implementation in the

EU: level of adoption,

benefits, barriers and

regulatory relief B.R.A.V.E. Project – Survey on European

EMAS organizations

2013

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2 LIFE B.R.A.V.E. PROJECT – Survey on European EMAS enterprises

Available on www.braveproject.eu

Fabio Iraldo, Francesco Testa, Sara Tessitore, Tiberio Daddi, Benedetta Nucci

EMAS implementation in the EU: level of

adoption, benefits, barriers and regulatory

relief

Pisa, November 2013

Institute of Management – Scuola Superiore di Studi Universitari e Perfezionamento Sant’Anna

Piazza Martiri della Libertà, 24

I-56127 Pisa (Italy)

Tel.: +39 (0)50 883 805

Fax: +39 (0)50 883 839

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FINANCIAL SUPPORT

The B.R.A.V.E. project, co-funded by the European Commission’s Life Plus Programme, focuses on

the subject of regulatory relief for EMAS registered organizations. B.R.A.V.E. is also co-funded by

Lombardy Region and Basilicata Region, and it involves the Institute of Management at Sant’Anna

School of Advanced Study as Coordinating Beneficiary and six additional partners, four from Italy

and two from Spain: Ambiente Italia, ARPA Lombardia, Confindustria Genova and Liguria, IEFE -

Bocconi University, IAT- Andalusian Institute of Technology, Chamber of Commerce of Valencia.

Project Leader

Partners

Co-funders

Citation: Fabio Iraldo, Francesco Testa, Sara Tessitore, Tiberio Daddi, Benedetta Nucci,

EMAS implementation in the EU: level of adoption, benefits, barriers and regulatory relief. Life-

B.R.A.V.E. Project – Survey on European EMAS organisations, pp 78

The study is available on the Life B.R.A.V.E. project website: www.braveproject.eu

For information please contact: [email protected]; [email protected]

For periodical updates on the project, you are invited to join the B.R.A.V.E. group on Linkedin

EXECUTIVE SUMMARY

The present study has been carried out as a task of the Life Plus “B.R.A.V.E.” project, with the objective of

improving and easing environmental regulation for EMAS registered organizations and, especially, SMEs.

The goal of this research is to reveal the perception of the interested organisations regarding the level of

implementation of the EMAS requirements, the difficulties they encounter in implementing them, the

effects of the EMAS regulation, as well as the usefulness of the existing measures for regulatory relief at the

EU level. In particular, this study aims at investigating the dynamics and the relations between

determinants and effects of the EMS – Environmental Management System and the role that regulatory

reliefs have in pushing EMAS adoption.

The study presents the results brought forth from a survey carried out between September 2012 and

March 2013 among the companies (excluding public bodies) registered in accordance with Regulation

1221/2009 (EMAS) on the topic of regulatory relief (normative simplifications and other incentives) at the

EU level.

The study involved 244 enterprises located all over the EU and operating in different sectors and branches.

This report begins with a description of the methodology adopted and the objectives pursued (chapter 1).

The following three chapters, which present a comprehensive analysis of the responses with the goal of

investigating connections between EMAS implementation and the characteristics of the enterprises

interviewed. Specifically, the three central chapters of this study describe the following:

• The sample interviewed and its economic performance over the last few years (chapter 2);

• The level of implementation of EMAS and, more specifically, of the EMS, the resulting benefits and

barriers (chapter 3);

• The role of regulatory relief in promoting and supporting EMAS implementation and the

stakeholders’ expectations in this prospect (chapter 4).

The sample of our survey is composed of medium (27%) and small enterprises (36% + 11% micro

enterprises).

Our study reveals that the EMAS-registered companies interviewed have achieved very satisfying results in

terms of improvements in environmental performance (for example, 43% declare a good improvement in

energy consumption) and have raised their investments in environmental innovations (42%). On the other

hand, the costs of EMAS implementation and /or registration still represent the most relevant barrier

encountered by EU organizations (about 1 out of 3 respondents considers this a very important hindrance).

The survey also investigated the role of the various stakeholders in stimulating actions for environmental

improvement and it confirms the key-role of public authorities and institutions.

With regard to regulatory relief, the survey shows that approximately 40% of the interviewed companies

have adopted or benefitted from some forms of regulatory relief, mainly by making use of the measures

granting an extended duration of some permits (44%), reductions in financial guarantees in the waste-

treatment sector (31%) and tax reductions (26%). Moreover, 53% of those interviewed confirmed the

importance of regulatory relief to support companies in the path to EMAS adoption. Despite this, they also

recognize that alongside the numerous advantages, the implementation of the existing regulatory relief

and simplification measures is particularly complex (excessive bureaucracy, minimal public awareness and

information, etc.). The interviewed companies have also expressed opinions and suggestions for additional

forms of simplifications and incentives, including tax reliefs and longer duration of environmental permits.

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Table of Contents

T H E E M A S R E G U L A T I O N I N E U R O P E A N D T H E O B J E C T I V E S O F T H E B . R . A . V . E .

S U R V E Y .................................................................................................................................................................... 10 1.1 THE LIFE PLUS “B.R.A.V.E.” PROJECT AND THE OBJECTIVES OF THE SURVEY ....................................................................... 10 T H E M E T H O D O L O G Y O F T H E B . R . A . V . E . S T U D Y ............................................................................ 11 2.1 EMAS ORGANISATIONS IN EUROPE: THE POPULATION OF THE STUDY .................................................................................... 11 2.2 THE B.R.A.V.E. QUESTIONNAIRE ................................................................................................................................... 12 2.3 SAMPLE DESCRIPTION ................................................................................................................................................... 13 2.3.1 AGE AND SIZE OF THE ORGANIZATIONS.......................................................................................................................... 16 2.3.2 SUPPLY CHAIN AND POSITION ON THE MARKET ............................................................................................................... 17 2.3.3 STRATEGIC PROFILE AND ECONOMIC PERFORMANCE ........................................................................................................ 18 T H E I M P L E M E N T A T I O N O F E M A S R E Q U I R E M E N T S : B E N E F I T S A N D C H A L L E N G E S ... 20 3.1 LEVEL OF IMPLEMENTATION OF THE ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) ............................................................. 20 3.1.1 INDICATIONS EMERGING FROM LITERATURE FINDINGS ...................................................................................................... 20 3.1.2 SURVEY RESULTS ...................................................................................................................................................... 21 3.2 EFFECTIVENESS OF THE EMS: IMPROVEMENTS IN ENVIRONMENTAL PERFORMANCE AND INVESTMENTS ........................................ 33 3.2.1 INDICATIONS EMERGING FROM LITERATURE FINDINGS ...................................................................................................... 33 3.2.2 SURVEY RESULTS ...................................................................................................................................................... 34 3.3 BARRIERS TO THE IMPLEMENTATION OF AN EMS IN ACCORDANCE WITH THE REQUIREMENTS OF THE EMAS REGULATION ............... 41 3.3.1 INDICATIONS EMERGING FROM LITERATURE FINDINGS ...................................................................................................... 41 3.3.2 SURVEY RESULTS ...................................................................................................................................................... 42 3.4 STAKEHOLDER ROLE IN STIMULATING ACTIONS FOR ENVIRONMENTAL IMPROVEMENT ................................................................ 47 3.4.1 INDICATIONS EMERGING FROM LITERATURE FINDINGS ...................................................................................................... 47 I N C E N T I V E S : T H E R O L E O F T H E R E G U L A T O R Y R E L I E F .............................................................. 54 4.1 REGULATORY RELIEF IN THE EUROPEAN UNION ................................................................................................................. 54 4.2 SURVEY RESULTS ......................................................................................................................................................... 54 4.2.1 KNOWLEDGE AND UTILIZATION OF REGULATORY RELIEF MEASURES ..................................................................................... 55 4.3.2 REGULATORY RELIEFS AS AN INCENTIVE FOR EMAS ADOPTION .......................................................................................... 59 4.2.3 THE ADVANTAGES AND DRAWBACKS OF USING THE MEASURES FOR REGULATORY RELIEF ......................................................... 61 4.3.4 SUGGESTIONS FOR FURTHER REGULATORY RELIEFS .......................................................................................................... 65

ANNEX-QUESTIONNAIRE ...........................................................................................................................................69

REFERENCES ..............................................................................................................................................................75

LIST OF TABLES

Table 1: EMAS registered enterprises by region and response rate by region ............................................... 13

Table 2 Description of the “Others” shown in Figure 4 ................................................................................... 14

Table 3 EMAS registeredorganizations of the sample by sector ..................................................................... 14

Table 4 Size of the organizations interviewed by State .................................................................................. 16

Table 5 Correlation matrix between level of implementation of planning actions and control variables ..... 22

Table 6 Planning of activities in environmental areas subdivided by State .................................................... 23

Table 7 Training and employees involvement activities by Member State .................................................... 25

Table 8 Correlation matrix between level of implementation of involvement actions and control variables 26

Table 9 Implementation of operational management actions of environmental aspects by Member State 28

Table 10 Correlation matrix between Implementation of operational management actions of environmental

aspects and control variables .......................................................................................................................... 28

Table 11 Measurement, monitoring and internal control activities by Member State .................................. 30

Table 12 Correlation matrix between level of implementation of monitoring initiatives and control variables

......................................................................................................................................................................... 31

Table 13 Logistic regression for the valuation of the relationship between the level of implementation of

the EMS and control variables ......................................................................................................................... 32

Table 14 : Percentage of organizations that declared experiencing at least “good” improvement ............... 35

Table 15 Correlation matrix between environmental performance and control variables ............................ 36

Table 16 Logistic regression for the valuation of the relationship between improvements in environmental

performance and the level of implementation of the EMS ............................................................................ 36

Table 17 Correlation matrix between environmental investments and control variables ............................. 39

Table 18 Logistic regression for the valuation of the relationship between environmental investments and

level of implementation of the EMS ................................................................................................................ 40

Table 19 Logistic regression for the valuation of the relationship between environmental investments and

the level of improvement of environmental performance ............................................................................. 40

Table 20 Correlation matrix between challenges encountered in EMAS implementation and control

variables........................................................................................................................................................... 43

Table 21 Barriers and challenges encountered in EMAS implementation by State ........................................ 44

Table 22 Correlation matrix between stakeholder influence and control variables ....................................... 48

Table 23 Stakeholders that influenced the choice of the organizations to adopt actions for environmental

improvements by Member State .................................................................................................................... 50

Table 24 Typology of regulatory relief measure used by enterprises by State ............................................... 59

Table25 The role of the regulatory reliefs with respect to all other motivations by State ............................. 61

Table 26 Advantages of using the regulatory reliefs since the organization was certified/registered by State

......................................................................................................................................................................... 62

Table 27 Main challenges that organizations encountered by Member State ............................................... 64

Table 28 Further typologies of regulatory reliefs that would be appreciated by State .................................. 66

Table 29 How the existence of regulatory reliefs should be communicated to companies (by State) .......... 68

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LIST OF FIGURES

Figure 1 EMAS Organizations in Europe .......................................................................................................... 11

Figure 2 Number of registrations by year........................................................................................................ 11

Figure 3 Distribution of the sample by State ................................................................................................... 14

Figure 4 Distribution of the sample by sector ................................................................................................. 15

Figure 5 Size of the organizations interviewed ............................................................................................... 16

Figure 6 Position along the supply chain ......................................................................................................... 17

Figure 7 Market’s size ...................................................................................................................................... 18

Figure 8 Market’s scope .................................................................................................................................. 18

Figure 9 Which among the competitive factors are most utilized to valorise the principal product on the

market ............................................................................................................................................................. 19

Figure 10 Economic performance over the last three years ......................................................................... 19

Figure 13 Planning of activities in environmental areas ................................................................................. 21

Figure 14 Training and employees involvement activities in environmental subjects: .................................. 24

Figure 15 Implementation of operational management actions of environmental aspects ......................... 27

Figure 16 Activities of measurement, monitoring and internal control.......................................................... 29

Figure 17 Monitoring of environmental aspects (number of indicators by environmental aspect) ............... 33

Figure 18 Improvements in environmental aspects with reference to the production unit with respect to the

year of EMAS adoption ................................................................................................................................... 35

Figure 19 Variation in investments for environmental improvement in the last 3 years ............................... 38

Figure 20 Variation in investments for environmental improvement in the last 3 years by State ................. 38

Figure 21 Barriers encountered in EMAS implementation ............................................................................. 43

Figure 22 Stakeholders that influenced the choice of the organizations to adopt actions for environmental

improvement ................................................................................................................................................... 48

Figure 23 Awareness of national and regional regulatory relief measures by EMAS/ISO 14001 certified

companies ....................................................................................................................................................... 55

Figure 24 Percentage of awareness of regulatory relief measures by State ................................................... 56

Figure 25 Companies that have used regulatory relief measures since registration ...................................... 56

Figure 26: Percentage of companies that have used regulatory relief measures by Member State .............. 56

Figure 27 Typology of regulatory relief utilized .............................................................................................. 57

Figure 28 Regulatory reliefs as a motive for obtaining certification ............................................................... 60

Figure 29 Regulatory relief as a motive for obtaining certification by State................................................... 60

Figure 30 The role of regulatory reliefs with respect to all the other motivations ......................................... 61

Figure 31 Advantages of using regulatory reliefs since the organization was certified/registered ................ 62

Figure 32 Challenges in using regulatory relief measures ............................................................................... 64

Figure 33 Typologies of regulatory reliefs that would be appreciated (in addition to currently existing ones)

......................................................................................................................................................................... 66

Figure 34 How the existence of regulatory relief measures should be communicated to companies ........... 67

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T H E E M A S R E G U L A T I O N I N E U R O P E A N D T H E O B J E C T I V E S O F T H E

B . R . A . V . E . S U R V E Y

1.1 The LIFE plus “B.R.A.V.E.” project and the objectives of the survey

The European Commission and other EU institutions have promoted a number of initiatives in recent years

to codify, consolidate and simplify existing EU legislation and to evaluate better the likely economic, social

and environmental impacts of new regulation. Implementing regulations and laws entails costs. Some costs

are linked to obligations to provide information, either to public or private parties.

Some legal obligations to provide information have become excessively complicated, time-consuming or

useless. For this reason, small and medium-sized enterprises (SMEs) in particular find it harder to comply

with environmental legislation. By reducing unnecessary reporting or monitoring (and control)

requirements, businesses can freed up to spend more time on their core activities, which might reduce

production costs and allow additional investment and innovation, which in turn should improve productivity

and competitiveness.

The B.R.A.V.E. (Better Regulation Aimed at Valorising Emas and the EU Ecolabel) is a project that aims to

support the full integration of EMAS (and of other voluntary certification schemes, such as the EU Ecolabel)

in the environmental legislation of EU Member States. This will facilitate EMAS implementation by all

organisations (better regulation) and remove, reduce and simplify the administrative burdens for EMAS-

registered organisations, as well as for companies adopting the EU Ecolabel or other forms of certification.

This initiative will encourage the adoption and dissemination of voluntary environmental certification

(regulatory relief).

The main result of the B.R.A.V.E. project will be the identification and development of effective measures for

better regulation and regulatory relief. The usefulness and efficiency of these measures will be tested.

The specific results will be:

• Regulation analysis including recommendations for considering EMAS registration (and other EU

voluntary certification schemes) in the development of new legislation and revision of existing

legislation at national (Italy and Spain) and regional levels;

• The setting up of seven regional working groups, two national working groups, one European

working group and seven regional consultation boards: these groups will work on the definition

process, and will build consensus for the proposed measures;

• A report that will contain both the better regulation and regulatory relief proposals related to the

existing legislative framework, covering permit procedures, control and inspection procedures,

environmental taxes and administrative fee reductions;

• A list of at least 35 proposals to be tested in the regions involved in the B.R.A.V.E. project,

accompanied by a list of the competent authorities and private companies available to be involved

in the testing phase; and

• A guidance tool for EMAS-based regulation and better regulatory relief

In order to design regulatory reliefs able to support EMAS registered organizations, the B.R.A.V.E. team

planned to conduct an extensive survey involving EMAS registered organizations, in order to:

• understand what is the real level of implementation of EMAS requirements

• identify perceptions, expectations and barriers on the different better regulation and regulatory

relief measures, according to EMAS Regulation art 38.

T H E M E T H O D O L O G Y O F T H E B . R . A . V . E . S T U D Y

2.1 EMAS organisations in Europe: the population of the study

EMAS is an integral part of the European Commission’s Sustainable Consumption and Production (SCP)

Action Plan, contributing the Commission’s ambitious goals of improving resource use patterns and

reducing emissions in the European Union. After 20 years of EMAS, more than 4,000 organisations and

more than 12,000 sites in Europe (and globally) have committed to the eco-management and audit scheme,

spanning all economic and service sectors and encompassing organisations of all sizes.

At the European level, four top ranked countries clearly emerge both for number of registered organizations

and for registered sites: Germany, Italy, Spain and Austria.

Figure 1 EMAS Organizations in Europe

Source EC

The number of organizations registered in Europe has grown continuously, to increase year by year with an

average of about 10%, arriving at 8,112 registered sites in 2012. The growing number of registrations in the

‘90s was followed by a progressive decrease and in 2004 a new positive trend can be observed. A further

contraction was recorded in the beginning of 2013, both in number of sites and organizations registered.

Figure 2 Number of registrations by year

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Source EC

2.2 The B.R.A.V.E. questionnaire

In order to investigate EMAS level of adoption and perceptions, expectations and barriers on the different

better regulation and regulatory relief measures, a questionnaire survey was realized involving only EMAS

registered private companies; public administrations were excluded. The survey’s design was carried out

according the following steps:

• Definition of the list of EMAS registered companies to which to send the questionnaire;

• Questionnaire’s design;

• Data collection;

• Data analysis and report.

The first phase of the survey identified the statistical reference population by analyzing the EMAS register

published on the EMAS official web-site. Then, we excluded the organizations operating in the public sector

(i.e. public administrations), since they do not benefit from any form of regulatory relief.

The second step focused on the questionnaire design. In order to reduce the potential presence of common

method biases that generally affect survey data, we adopted several procedural remedies to reduce biases,

e.g. we proceeded: by minimizing item ambiguity avoiding vague concepts, complicated syntax and

unfamiliar terms; by keeping questions simple, specific, and concise; by avoiding the use of bipolar

numerical scale values and providing verbal labels for the midpoints of scales and by guaranteeing

respondents anonymity.

The final version of the questionnaire is composed of 27 questions grouped in 6 sections:

• SECTION 1-General information on the organization;

• SECTION 2-Level of adoption of EMS requirements;

• SECTION 3- Environmental performance of EMAS adopters;

• SECTION 4-Trend of environmental Investments;

• SECTION 5-Regulatory reliefs: use, drawbacks and expectations;

• SECTION 6- Stakeholders’ pressures and barriers.

The online platform “Survey Monkey” was used to facilitate the sending and filling-in of the questionnaire.

The email addresses of the contact persons of each organization were identified from the European

Commission’s EMAS register. The questionnaire was sent out to 3936 organisations by e-mail, with an

accompanying document that described the project and gave the instructions to access to the on-line

questionnaire. The questionnaire was first sent out in July 2012 to Italian organizations and then all the

other MSs were covered in the following months. The European Commission and other key stakeholders

(i.e. EMAS club Cataluña, project’s partners) helped promoting the survey by publishing the questionnaire

on their web-sites. On March 15th 2013, the data collection phase was officially closed.

2.3 Sample description

Overall, 224 filled questionnaires were collected with an average response rate of 6%. The following table

shows the response rate in each EU Country involved in the study. A critical element that has to be taken

into account in the data analysis is the high percentage of answers from Italian organizations. This is due to

two main reasons: the widespread knowledge and reputation of the B.R.A.V.E. partners among the Italian

EMAS organizations (much higher than abroad) and the possibility to receive an Italian version of the

questionnaire. Response rates between 15% and 25%, but with low absolute numbers, were obtained in

several Member States such as Denmark, Portugal, Czech Republic, etc.

Table 1: EMAS registered enterprises by region and response rate by region

Country EMAS companies

contacted Respondents %

Austria 248 11 4%

Bulgaria 2 1 50%

Belgium 39 3 8%

Czech Republic 24 6 25%

Denmark 67 10 15%

Finland 6 1 17%

France 24 3 13%

Germany 1260 16 1%

Greece 43 3 7%

Ireland 4 2 50%

Italy 907 141 16%

Lithuania 9 1 11%

Malta 2 1 50%

Norway 4 2 50%

Poland 29 1 3%

Portugal 60 9 15%

Spain 1162 26 2%

United Kingdom 46 7 15%

TOTAL 3936 244 6%

As above mentioned, Italian organizations represent 58% of the sample; 11% of the data was collected from

Spanish organizations and approximately 5% from organizations located in Germany, Austria, Denmark,

Portugal, United Kingdom, and Czech Republic.

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Figure 3 Distribution of the sample by State

Table 2 Description of the “Others” shown in Figure 4

Country Respondents %

Belgium 3 1.2%

France 3 1.2%

Greece 3 1.2%

Ireland 2 0.8%

Norway 2 0.8%

Bulgaria 1 0.4%

Finland 1 0.4%

Lithuania 1 0.4%

Malta 1 0.4%

Poland 1 0.4%

Regarding the industrial sectors, 17% of the sampled organizations operate in the waste treatment sector,

10% in the mechanic and chemical sectors.

Table 3 EMAS registeredorganizations of the sample by sector

Sector Organizations

interviewed % on the

total Agriculture, forestry and fishing 3 1% Mining 3 1% Agri-Food 14 6% Textile 6 2% Leather 1 0% Forniture 5 2% Paper 12 5% Press 8 3%

Sector Organizations

interviewed % on the

total Oil products 1 0% Chemical and pharmaceutical industry 23 10% Rubber and plastic 6 2% Glass processing 1 0% Metalworking 14 6% Electronics 6 2% Mechanical Industry 24 10% Other fields 6 2% Energy 18 7% Waste management 40 17% Building 6 2% Trade 3 1% Transport 10 4% Hotel and restaurants 6 2% Communication services 1 0% Other services 27 10% Total 244 100%

In order to better investigate the distribution of the answers on each question, we identified the following

main categories used to cluster the sectors included in the above mentioned table: manufacturing sector;

Agro-food sector; Environmental and energy services; other services.

The data shows the prevalence of the manufacturing sector in the sample, followed by waste and energy

services.

Figure 4 Distribution of the sample by sector

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2.3.1 Age and size of the organizations

The “age” of the interviewed firms is mainly concentrated in the last 50 years: 36% of the sample has been

founded from 50 to 25 years ago while 40% is composed of relatively “young” firms (less that 25 years old).

Moreover, only 16% of the sample dates back to more than 50 years ago (but less than 100 years) and only

5% are firms older than one century.

Regarding the organizations’ size, it can be noted that the sample is mostly composed of small

organizations, employing from 11 to 50 employees (36%) and medium organizations employing from 51 to

250 employees (27%) . The large firms are 24% of the sample and the micro firms only 11%.

Figure 5 Size of the organizations interviewed

The following table shows the distribution of the organizations’ size for the main countries involved in the

survey.

Large organizations are mainly presented in Austria (36%), Czech Republic (83%) and Germany (47%). Small

and medium organizations dominated the samples from Denmark (80%), Italy (69%), Spain (62%) and the

United Kingdom (86%).

Table 4 Size of the organizations interviewed by State

Country 1 -10 (micro) 11 -50 (small) 51 -250 (medium) > 250 (large) N.A. Total

Austria 2 2 3 4 11

18% 18% 27% 36% 0%

Czech Republic 1 5 6

0% 0% 17% 83% 0%

Denmark 5 3 2 10

0% 50% 30% 20% 0%

Germany 1 2 4 7 2 16

6% 12% 24% 47% 12%

Italy 20 64 34 23 141

14% 45% 24% 16% 0%

Portugal 1 3 2 3 9

0% 11% 33% 22% 33%

Spain 4 8 8 6 26

15% 31% 31% 23% 0%

United Kingdom 2 4 1 7

0% 29% 57% 14% 0%

2.3.2 Supply chain and position on the market

The system of economic relationships and the competitive factors are one of the main aspects of interest

for this study. An analysis of the market position of the EMAS organizations interviewed allowed to

investigate the possible incentives for the implementation of an EMS deriving from the economic system in

which an organization operates.

This section of the questionnaire posed three questions focused on the following topics:

1. Position along the supply chain,

2. Number of competitors on the market,

3. Size of the reference market.

A first feature of the sample organisations that we investigated concerns the “position” along the supply

chain, i.e. the phase of the product or service life-cycle in which they operate. The “distance” from the final

consumer is certainly relevant to determine which regulatory reliefs can be more effectively adopted and

which enhancing measures can be implemented by policy makers.

As expected, 44% of the sample operate in a “business-to-business” market, selling their products to other

manufacturing firms; 22% of the organizations provides own products to wholesalers or retailers, while for

the 28% of organizations the primary customer is a final consumer.

Figure 6 Position along the supply chain

Another investigated feature is the market’s size measured by the number of organizations with which

EMAS adopters compete. More than 50% of the interviewed organizations declared that they compete with

more than 10 competitors; 23% of the organizations with from 5 to 10 competitors , while 24% operate in a

market where they do not compete with more than 5 economic actors.

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Figure 7 Market’s size

The last aspect investigated is the market’s scope of the interviewed organizations. In detail, organizations

were asked to indicate if their market’s scope is manly local, national, European or international. As shown

in the figure below, 41% of the organizations operates in a national market; 30% in an international market;

18% operates in al local market while 18% of the organizations operates at European level.

Figure 8 Market’s scope

2.3.3 Strategic profile and economic performance

The concept of competitiveness may be defined and analysed at different levels:

1) the level of the ‘entities’ that are the actors on the competition “arena” (single firm/plant;

cluster of firms, i.e. an industry, a sector, local productive system etc.; territorial context, i.e. a

country or a region);

2) the “dimension” of competitiveness: international, national and local competitiveness,

3) according to the key variables affecting competitiveness, as well as the ways to measure them:

macro level (territorial: international/national); meso level (cluster: sectoral/industry/district) and

micro level (plant/firm).

Focusing on the firm level, competitiveness measures do relate to various aspects, such as the ability to

sustain market shares, to sustain independent existence on the market or to sustain “normal” levels of

profitability and returns.

In order to evaluate the competitive strategy of EMAS adopters, the organizations were asked to indicate

the level of importance of the following competitive factors in the own strategy: quality of products, price;

relation with suppliers and reputation.

The quality of the products was considered as very important by 82% of the interviewed organizations, and

reputation was valued as very important by 69%. Price was also considered very relevant (63%) while

relations with suppliers was evaluated “very important” only by 39% of organizations.

Figure 9 Which among the competitive factors are most utilized to valorise the principal product on the market

Since many studies analyzed the possible correlations between EMSs and economic performance (Rennings

et al., 2003) the interviewed organizations were asked to make a comprehensive judgment on their

economic performance by choosing between a range of responses that allowed them to evaluate the trend

of performance in the last three years. The majority of organizations stated that their revenues were

enough to have a profit (49%) while 14% of them declare the their revenues were well above costs.

Figure 10 Economic performance over the last three years

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T H E I M P L E M E N T A T I O N O F E M A S R E Q U I R E M E N T S : B E N E F I T S A N D

C H A L L E N G E S

3.1 Level of implementation of the Environmental Management System (EMS)

3.1.1 Indications emerging from literature findings

Environmental Management Systems (EMSs) are part of the category of voluntary tools that could be

defined as “liberal.” The organizations are not called on to demonstrate continuous improvements in their

performance through tight obligatory implementation methods (Biondi et al. 2000). On the contrary,

enterprises can freely choose the best way to implement an EMS on the basis of the results of an Initial

Environmental Review. Therefore, certain EMS can, for instance, stress more employee involvement, while

others can focus on systematic auditing activities or on operative management (the implementation of

methods associated with a monitoring system to verify effectiveness ).

With reference to the various methods of implementation of an EMS, auditing is certainly one of the most

debated subjects in the literature. Khanna and Widyawati published a study in 2011 on 500 American plants

that examined the connection between level of conformity to the regulations and frequency with which

self-audits were performed. The research found that companies that carried out the highest number of self-

audits reached a higher level of conformity to the regulations, and that companies subject to external

pressures (eg. deriving from the environmental regulations of their local communities) (Darnall et al., 2009)

chose to use auditing more often in order to conform to the regulation. Another study carried out by Mary

et al. in (2009) confirms the direct correlation between external pressures and the choice to use auditing as

a way to ensure conformity. However, the study does not show a particular connection between these

companies and the level of normative conformity reached.

Another element that that can have a strong influence on the level of implementation of an EMS is the

choice that the company makes with relation to employee involvement and the management of human

resources. Some organizations limit themselves to doing only what is necessary to conform to regulations,

leaving environmental management as a prerogative of those employees who have a specialization in

environmental and safety matters. Others, who conform more with the spirit of EMAS, involve the majority

of their workers and/or their representatives in many decisions, trying to create a real bottom-up approach

in many processes of the EMS, such as the choice of the objectives for improvement or the implementation

of the operative methods for the management of the principal environmental aspects. Daily and Huang, in

their article entitled “Achieving sustainability through attention to human resource factors in environmental

management” identify aspects such as training, employee involvement, work in groups, and reward systems

as key elements for the implementation of EMSs.

In the same way, other authors confirmed the relevance of these aspects also for the implementation of

precise environmental business strategies and for the achievement of higher environmental performances

(Fernandez et al., 2003). In contrast, as often occurs in literature, other studies do not reveal a clear

connection between the efforts made by organizations for employees involvement and the effects of these

efforts on the environmental performance (Perron et al., 2006).

3.1.2 Survey Results

In order to evaluate the level of implementation of the EMS – Environmental Management System within

the EMAS scheme, four distinct areas of analysis were distinguished. These areas correspond to the phases

of the PDCA cycle (plan-do-check-act) on which the logic of the management systems is based:

• Planning of activities in environmental subjects;

• Training activities and employee involvement in environmental subjects;

• Implementation of initiatives for the management of environmental aspects;

• Activities of measurement, monitoring and internal control.

For every area, three questions were formulated, each corresponding to an activity of the EMS.

The analysis of the planning activities shows that almost all the companies interviewed have disseminated

an environmental policy to all their personnel and planned to attain measurable goals in their

environmental improvement programme (in order to use it as an effective and improvable tool).

The inquiry shows that actions aimed at gathering employees’ observations and suggestions are well

implemented for 39% of the sample, while another 32% thinks that good results have been achieved thanks

to the implementation of these instruments.

Figure 11 Planning of activities in environmental areas

The analysis of the correlation between the responses to the three questions shows that, in relation to

environmental planning, there is a certain uniformity of approach, or rather, those who have effectively

implemented one of the three aforementioned initiatives have probably implemented the others effectively

as well.

This suggested the possibility to create a unique factor able to measure the general level of implementation

of activities in the field of “planning”, as well as to analyse the correlation with the various characteristics of

the company, described in paragraph 2.3.3. The analysis shows how those companies that operate in a

competitive market or that are in a satisfying period from the economic point of view, have a higher

probability to effectively implement planning actions.

22


Table 5 Correlation matrix between level of implementation of planning actions and control variables

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11)

Planning .072 -.051 -.058 -.005 -.013 .142** -.014 .111* .050 .103 .170**

(1) Number of years since registration was acquired (2) age of the organizations; (3) number of employees; (4) position along the

supply chain; (5) geographic size of the market; (6) number of competitors; (7) price as a competitive factor; (8) quality as a

competitive factor; (9) reputation as a competitive factor; (10) relationships with suppliers as a competitive factor; (11) economic

performances

***;**;* The correlation is significant to 99%; 95%; 90% respectively.

Table 5 shows the level of implementation of planning activities by Member State, as resulting from the

survey. The organizations that evaluated their level of planning as “very good”, with reference to the three

questions posed to them, operate mainly in Spain and Portugal. The highest score, however, comes from the

Czech Republic however, especially with reference to the dissemination of the environmental policy and the

implementation of a system capable of measuring the planned objectives achieved.

Approximately 10% of the organizations operating in Austria and in the UK declared that they had not

carried out the planning activities proposed in the three questions.


23

Table 6 Planning of activities in environmental areas subdivided by State

Good implementation of the initiatives

and positive evaluation of

their effectiveness

Good implementation

Implementation was

started but not completed

Poor implementation

Not implemented

N.A.

The environmental

policy was effectively

disseminated to all employees

Italy 53% 43% 3% 1% 0% 0% Spain 69% 23% 0% 4% 0% 4%

Germany 56% 13% 13% 0% 0% 19% Austria 55% 18% 9% 0% 9% 9%

Denmark 20% 80% 0% 0% 0% 0% Portugal 67% 22% 0% 0% 0% 11%

United Kingdom 57% 29% 0% 0% 14% 0% Czech Republic 83% 17% 0% 0% 0% 0%

others 50% 28% 17% 0% 0% 6%

Based on the policy, the

management has established measurable

objectives and targets related to the environment

Italy 59% 38% 3% 0% 0% 0% Spain 81% 12% 0% 4% 0% 4%

Germany 56% 25% 0% 0% 0% 19% Austria 55% 0% 27% 0% 9% 9%


UK 57% 29% 0% 0% 14% 0% Czech Republic 83% 17% 0% 0% 0% 0%

Others 56% 28% 6% 0% 6% 6%

There are actions aimed at gathering

opinions and suggestions

coming from the employees as regards the

environment

Italy 31% 38% 21% 7% 1% 1% Spain 42% 46% 4% 4% 0% 4%

Germany 38% 25% 19% 0% 0% 19% Austria 27% 18% 27% 0% 18% 9%


UK 38% 50% 0% 0% 13% 0% Czech Republic 50% 33% 0% 0% 17% 0%

Others 22% 44% 11% 17% 0% 6%


24

The involvement of employees represents one of the strongest elements of the EMS in accordance with the

EMAS Regulation, and this is a distinctive factor with respect to an EMS that complies with the ISO 14001

standard.

In contrast with the planning phase, if we consider the implementation of actions aimed at effectively

involving employees, a certain difficulty was noted among the companies interviewed. For example, only

24% of the surveyed organizations has effectively implemented actions to define the training needs related

to environment, and only 18% has effectively activated participatory solutions to tackle problems deriving,

for instance, from the detection of nonconformities. Lastly, only 8% of the interviewees has effectively

implemented an incentive system for employees aimed at guaranteeing conformity to the company’s

procedures for environmental management. The actions indicated in the questionnaire, although in some

cases do not represent a binding element of the management system, do constitute good practices that are

also recognized by the European Commission.

Table 7 shows the results of the study by Member State. The data on the level of implementation of

employees’ training and incentives display relevant differences between States. Organizations in the Czech

Republic, Austria and Denmark declared that they incentivize their employees in the implementation of the

EMS (50%), a practice which is much less common in Italy and Spain, where this system is not adopted at all

by approximately 50% of the respondents.

The analysis of the responses reveals that about 50% of the organizations interviewed in Spain, Germany,

Denmark, and the Czech Republic declare at least a good implementation of the activities related

employees participation. One may note a significant difference in the implementation of actions to detect

the training needs in environmental topics. In this case, we emphasize that the respondents from many

Member States, e.g. Denmark (90%), Portugal (88%) and the Czech Republic (100%) declare a good or very

good implementation of these actions.

Figure 12 Training and employees involvement activities in environmental subjects:


25

Table 7 Training and employees involvement activities by Member State

good implementation

and positive evaluation of effectiveness

good implementation

implementation was started but not completed

poor implementation

not implemented N.A.

Incentives to employees to implement the

procedures related to

environmental protection.

Italy 4% 14% 11% 18% 52% 1% Spain 12% 15% 12% 8% 50% 4%

Germany 13% 31% 13% 13% 13% 19% Austria 0% 45% 9% 18% 18% 9%



Others 17% 33% 28% 0% 11% 11%

Project teams are in charge of

solving specific environmental

issues.

Italy 18% 29% 24% 16% 12% 0%

Spain 15% 42% 4% 15% 19% 4% Germany 25% 38% 6% 0% 13% 19% Austria 0% 36% 18% 18% 18% 9%



Others 28% 22% 33% 6% 6% 6%

Formalised system to detect

any training needs in the

environmental field.

Italy 26% 37% 18% 13% 6% 0%

Spain 19% 46% 15% 8% 8% 4% Germany 6% 38% 25% 6% 6% 19% Austria 9% 18% 27% 18% 18% 9%



Others 33% 17% 39% 0% 6% 6%


26

As described above, a unique factor was created (Cronbach 0.6523 alpha test) in order to analyse the

correlation between the level of implementation of actions for employees’ involvement and the various

characteristics of the company. The statistically significant relation that appears from this analysis shows

how the level of system’s maturity and the size of the organization both positively affect the company’s

ability to adopt initiatives directed toward encouraging employees participation. In addition, organizations

that do not base their competitive strategy on price, but rather on other factors such as the quality of their

products, their reputation, and relationships along the supply chain, are those that have implemented a

larger number of actions for employee involvement. Lastly, the trend in environmental performance

represents an additional factor that can influence the implementation of such initiatives.

Table 8 Correlation matrix between level of implementation of involvement actions and control variables

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11)

Employees

involvement .214*** .027 .262*** 0.001 .091 .074 .005 .138** .163** .191*** .166**




performances


A deeper analysis of the initiatives for the operational management of meaningful environmental aspects

shows that the level of implementation is very high in almost all the organizations interviewed.

In fact, more than 66% has created specific operative instructions for the management of environmental

aspects (for example, management of temporary waste deposits, atmospheric emissions, etc.). 69% of

organizations has established one or more procedures to identify and respond to potential emergency

situations, while 70% has periodically re-examined and, when necessary, revised the management

procedures for environmental emergencies, in particular after periodic evidence or following emergency

situations.

Figure 13 Implementation of operational management actions of environmental aspects

The analysis of the level of implementation of initiatives for the operational management of environmental

aspects shows a high level of implementation in all Member States. For every considered initiative, very

positive evaluations emerged for Italy, Portugal, the Czech Republic and in general from all the

organizations involved in the study.

If we consider each Member State individually, it appears that most of the organizations operating in Italy

(75%), Spain (69%), Portugal (78%), the United Kingdom (71%) and the Czech Republic (100%) have created

specific operative instructions for the management of environmental aspects. Furthermore, these latter

organizations declare also that they have established one or more procedures to identify and respond to

potential emergency situations (at least 65% of responders). Moreover, at least 70% of the EMAS

organizations operating in Italy, Spain, the United Kingdom and the Czech Republic declare that they re-

examine their management system for environmental emergencies periodically.

28


Table 9 Implementation of operational management actions of environmental aspects by Member State

good implementation of the initiatives and

positive evaluation of

their effectiveness

good implementati

on

implementation was started

but not completed

poor implementati

on

not implement

ed N.A.

There are specific

operating instructions for the management of environmental

issues

Italy 75% 19% 6% 0% 0% 0% Spain 69% 19% 0% 4% 4% 4% Germany 44% 19% 13% 6% 0% 19% Austria 27% 27% 0% 18% 18% 9% Denmark 60% 40% 0% 0% 0% 0% Portugal 78% 11% 0% 0% 0% 11% UK 71% 14% 0% 0% 14% 0% Czech Republic 100% 0% 0% 0% 0% 0% Others 67% 17% 6% 6% 0% 6%

The company has identified one or more

procedures to detect and deal with potential

emergency situations.


Emergency response

procedures are periodically re-examined and

updated


The operational management of environmental aspects emerges as a key element of an EMS especially in

those companies that carry out their activity in a highly competitive market, in companies that present a

positive economic trend, and, though to a lesser degree, in companies that base their competitive strategy

on reputation. In fact, the analysis of correlation, using the unique factor of “Initiatives for the management

of environmental aspects” (Cronbach alpha test 0.87), shows that the meaningful relationships are those

between the levels of implementation of operative actions, the number of companies with which the

enterprise competes, the trend in economic performance, and reputation as a competitive factor.

Table 10 Correlation matrix between Implementation of operational management actions of environmental aspects

and control variables

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11)

Initiatives of for the .085 -.042 .117* -.086 -.002 .142** .005 -.004 .130* .025 .182***

management of

environmental aspects




performances


A good level of implementation emerges with reference to measurement activities, monitoring and internal

control. In particular, approximately 75% of the companies interviewed effectively carry out periodic

internal audits in order to verify the correct implementation of the instructions/procedures and respect for

the norms applicable to environmental issues. For a 16% of the interviewed companies these activities

could still be improved. Moreover, approximately 70% of companies have satisfactorily began using

methods for the recording of nonconformities together with preventative actions, while 60% are

particularly satisfied with their formalized performance measurement systems.

Figure 14 Activities of measurement, monitoring and internal control

The following table shows the state of implementation of surveillance and measurement activities in the

various Member States. High levels of implementation were found in the UK (86%), Spain and Italy. Only few

organizations declared that they had not adopted these measures and they are all located in the UK.


30

Table 11 Measurement, monitoring and internal control activities by Member State

good implementation of the initiatives and positive evaluation of their effectiveness

good implementation

implementation was started but not completed

poor implementation

not implemented N.A.

There are formal systems to

measure the performance in order to detect the degree of

achievement of the targets.

Italy 60% 30% 8% 2% 0% 0% Spain 73% 15% 4% 4% 0% 4% Germany 63% 6% 13% 0% 0% 19% Austria 36% 36% 0% 9% 9% 9% Denmark 40% 60% 0% 0% 0% 0% Portugal 67% 22% 0% 0% 0% 11% UK 86% 0% 0% 0% 14% 0% Czech Republic 67% 33% 0% 0% 0% 0% others 78% 11% 6% 0% 0% 6%

The organisation has implemented

actions to register and

investigate not compliance and

preventive actions.


Audits are scheduled, aimed at

verifying the implementation

of instructions/procedures and the

compliance with legal

requirements



31

Monitoring activities themselves also present a high correlation level. Therefore, similarly to the other

constituent areas of an EMS, a unique factor (Cronbach alpha test 0.90) was created and the correlation

between the level of implementation of surveillance actions and the various characteristics of the company

was analyzed. The results highlight that the company’s size, measured by number of employees, positive

economic trends, and the foundation of the company’s strategy on products/services quality, represent

factors that can positively coincide with the implementation of a well-structured monitoring and audit

activity.

Table 12 Correlation matrix between level of implementation of monitoring initiatives and control variables

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) Monitoring initiatives .079 .078 .143** -.009 -.060 .110 .116 .118* .063 .087 .254*** (1) Number of years since registration was acquired (2) age of the organizations; (3) number of employees; (4) position along the



performances


To reinforce the evidence emerging from the descriptive analysis and verify which contextual factors,

generally, can have a positive or negative influence on the level of implementation of an EMS, an analysis of

the causal relationships was done by using regression statistic through the STATA 12 software.

For the definition of the dependent variable (level of implementation of the EMS) an index was constructed

which was determined by a linear combination of the answers to the questions on the implementation of

the individual activities of an EMS. In addition, the responses of the non-productive companies of the

sample were not considered.

The results of the ordinal logistic regression model emphasize how the probability of implementing a well-

structured EMS grows with the increase in age of the EMS (coefficient 0.08 and meaningful to 95%). This

confirms the indications of various studies (see for example Iraldo et al. 2009) that a full implementation of

all the requirements provided by the EMAS Regulation necessarily takes time. As a consequence, the new

organizational model created for the management of environmental aspects can integrate perfectly into the

existing organization until it becomes an inseparable part of it.

Moreover, the model confirms another aspect emphasized in the literature, namely that the economic

performance of companies, by pushing them to adapt the organization model to a changing situation, can

facilitate the overcoming of challenges regularly encountered when implementing the requirements. This,

therefore, should not be exclusively interpreted as a factor that allows companies to absorb the initial costs

of implementation of the system, but also as an indicator of the readiness of the company to question itself

and to make meaningful changes to the way its organization functions with relation to environmental

aspects.

Lastly, another relevant aspect is how competitive strategies promote the adoption of a particularly

“invasive” EMS. Companies whose competitive strategies are based on quality of production are more

stimulated to implement an EMS that fully incorporates the good practices and the EU guidelines.

32


Table 13 Logistic regression for the valuation of the relationship between the level of implementation of the EMS

and control variables

EMS level of implementation

Coeff. Z

EMS maturity (Number of years since registration was acquired)

0.082** 2.02

Age of the organizations -0.003 -0.80

Number of employees -0.001 -0-86

Main customer: Traders (wholesale or retail) (with respect to customers 'other companies')

-0.381 -1.00

Main customer: Consumers/end users (general public) (with respect to customers 'other companies')

-0.971** -2.53

Main customer: Other plants within your organisation (with respect to customers 'other companies')

1.730** 2.35

National market (compared to the local market) 0.046 -0.11

European market (compared to the local market) -0.195 -0.36

International market (compared to the local market) 0.148 0.30

Number of competitors 0.154 0.84

Price as a competitive factor -0.113 -0.48

Quality as a competitive factor 0.675** 2.23

Reputation as a competitive factor 0.207 0.67

Relationships with suppliers as a competitive factor 0.250 0.97

Economic performances 0.339** 2.56*

Manufacturing activity (compared to tertiary activities) -0.366 -0.084

Agro-industrial activity (compared to tertiary activities) -0.186 -0.29

Activity environmental services (compared to tertiary activities)

0.208 0.44

Activity logistic-construction (compared to tertiary activities)

0.678 1.03

Location Italy (compared to East Europe) -2.307*** -2.70

Location Other Mediterranean Countries (compared to Est Europe)

-1.455 -1.64

Location Central Europe (compared to East Europe) -2.150** -2.42

Location North Europe (compared to East Europe) -2.435** -2.42

Examination number 220

Pseudo R-square 0.102

***;**;* The correlation is significant to 99%; 95% 90% respectively.

The last aspect of the EMS investigated was the use of “key performance indicators” for the monitoring of

environmental performance and, in particular, the number of indicators used for monitoring environmental

aspects (poor=1 indicator; sufficient = 2-3 indicators; in depth= more than 3 indicators). The following figure

shows that the monitoring of waste production, atmospheric emissions, energy efficiency, and water

consumption are scoring rather high (38% regarding water consumption and 59% for waste management)

while biodiversity and efficiency of materials, given the limited number of indicators used, are some of the

aspects to which a lower monitoring effort is applied.

A higher monitoring of environmental performance is found among those companies that consider

reputation and relationships along the supply chain as a key elements of their competitive strategy.

Figure 15 Monitoring of environmental aspects (number of indicators by environmental aspect)

3.2 Effectiveness of the EMS: improvements in environmental performance and investments


In the last years, the companies’ adoption and application of EMS has created a notable level of interest in

research, especially considering the increasing popularity and diffusion of the European standards EMAS as

well as of the ISO 14001 (Testa & Iraldo, 2010; Testa et al. 2011a)

A large amount of feedback was collected on the effects of implementation of the EMAS scheme and on the

overall environmental performance of the organizations that adopt them. The results of some of the most

recent and interesting studies and research by those who used an econometric approach are reported

below.

Considering a sample of 7,889 plants belonging to the group of production plants in the United States in

1995-2001, King et al. found evidence that the adoption of an EMS generate improvements in

environmental performance, measured as the logarithm of the weighted sum of the toxicity of the elements

present in the Toxic Release Inventory. In another study, which used the voluntary data of Japanese plants in

an OECD survey, Arimura et al.(2008) assessed the positive effects of the ISO 14001 norm on three

improvements relative to environmental impact.

However, a small amount of contrasting evidence was also found. The results of other studies show that

official EMSs (for example ISO 14001 and EMAS) do not substantially influence the environmental

performance of a company. One of the most significant empirical studies, which used a series of data from

37 pulp and paper plants in Quebec in the period of 1997-2003, did not identify any significant evidence of

pollution reduction after the achievement of the ISO 14001 certification.

Significant research on the long term impact of EMAS on performance does not yet exist due to a lack of

time series data. However, researchers have attempted to evaluate whether or not EMAS helps to promote

environmental innovations. In a study that involved 1,277 EMAS registered German plants, Rennings et al.

(2003) revealed that environmental managers consider the implementation of EMAS to be a substantial

contribution to the introduction of environmental innovations, especially organizational ones. In a

subsequent study which involved the production managers of 588 German plants, Rennings et al. (2004)

found a weak but meaningful positive influence of the ISO 14001 and EMAS standards on products

environmental innovation.

34


Hertin et al. (2004) carried out an analysis of the chronological series from industrial enterprises and

European production sites that apply various EMS policies. The main result of this study was that the

connection between a company’s EMS and its environmental performance (measured by eco-efficiency

indicators) is weak and ambiguous. The companies that have an certified EMS showed better results

regarding some indicators, but worse results in many others, and only a small number of correlations turned

out to be statistically significant. Hertin et al. (2008), in reporting the results of a research project entitled

MEPI carried out considering the data of 274 companies and 400 production sites of six different sectors in

six EU countries, confirmed the weak link between EMSs and environmental performance.

The study by Daddi et al. (2011) analyzed the trends in environmental performance of a sample of 64 Italian

companies belonging to 6 different industrial sectors that had obtained EMAS registration for at least three

years. The authors investigated especially the influence of the EMAS registration on the improvement or

decline in environmental performance and therefore the ability of this instrument to bring about

continuous improvement, which is a basic principle of the systems of certification of environmental

management. The data obtained indicate that in some cases, EMAS brings about an effective improvement

in environmental performance, also in the short term.

Whether or not an EMS turns out to be useful can therefore strongly depend on various factors. One of

these factors regards the time that the company needs in order to adapt an EMS to their specific situation

(Testa et al. 2014a). Suffice it to say that in order for an EMS to be effective and to obtain positive results in

terms of environmental improvements, a company must define its objectives and plan its management

activities and technological investments. As described in the research of Iraldo et al. (2009), who used the

data of more than 100 EMAS registered organizations, the number of years of implementation of the EMS

has a positive effect on the level of environmental performance observed in the organization. However,

even if this relationship is positive, the effect of the adoption period of the EMS is not very high. This implies

that the influence imposed over time by the EMS on the ability to improve environmental performance is

offset by other factors.

3.2.2 Survey Results

The results that emerge from our study confirm the evidence reported in literature, namely that the

adoption of an EMS does not always determine continuous improvements in all aspects of environmental

performance.

The study shows that, for example, the environmental aspects in which performance improvements are

recorded more often are the emission of pollutants into the atmosphere (61% of those interviewed

declared having obtained at least a “good” improvement), waste production (66%), water consumption

(59%) and energy consumption (65%). The improvement in terms of efficiency in the use of primary or

auxiliary materials in production processes was shown to be limited.

Figure 16 Improvements in environmental aspects with reference to the production unit with respect to the year of

EMAS adoption

The following table shows the environmental aspects about which the interviewees expressed a positive

judgment in terms of consequent improvement (good and high). The manufacturing sector declared a

substantial improvement particularly with reference to waste production (72%), energy efficiency and

atmospheric emissions (68% and 66% respectively). The sector of environmental services recorded an

improvement in their performance with reference to the production of waste and to atmospheric emissions

(69% respectively), while the food industry declared good and high performance with regards to energy

efficiency and water consumption (82% and 71% respectively). The sector that includes various services

sectors records a higher level of improvement in energy efficiency and waste production (61% and 57%

respectively).

Table 14 : Percentage of organizations that declared experiencing at least “good” improvement

Energy efficiency

Material Efficiency

Water consumption

Waste production

Biodiversity Air emissions

Manufacturing 79 55 76 83 12 76

68% 47% 66% 72% 10% 66%

Food industry and agriculture

14 9 12 11 3 10 82% 53% 71% 65% 18% 59%

Environmental and Energy services

34 16 29 40 7 40 59% 28% 50% 69% 12% 69%

Other sectors 31 18 26 29 16 25

61% 35% 51% 57% 31% 49%

N.A. 0 0 0 0 1 0

0% 0% 0% 0% 50% 0%

The analysis of the interdependencies between improvements in environmental performance and a few

control variables shows some statistically significant relationships. For example, it shows that organizations

with an EMS that has been implemented for some years have experienced positive improvements in waste

management and in the quality of atmospheric emissions. In contrast, the age of the organizations presents

36


a negative relationship with environmental performance related to waste and biodiversity. Also some

strategic approaches seem to be correlated with improvements in the management of specific

environmental aspects. For example, companies with competitive strategies centered on relationships along

the supply chain and on reputation declare that they have experienced relevant improvements in terms of

the quality of atmospheric emissions. Lastly, it seems clear from the analysis of interdependencies that

organizations characterized by a positive economic trend declare that they have experienced positive

performance in various environmental aspects, namely the quality of emissions, water and energy

consumption, and use of materials.

Table 15 Correlation matrix between environmental performance and control variables

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) Energy efficiency

.017 .012 .002 .041 .074 .076 -.122 .201 .099 .137 .264*

Material Efficiency

-.003 .039 .153 .004 .116 .108 -.080 .173 .172 .111 .363**

Water consumption

.168 .052 .173 .047 .176 .262* -0.167 .065 .012 .046 0.248*

Waste production .345** .249* .072 .094 .064 .070 -0.041 .047 .131 .196 -.068

Biodiversity -.167 -.249 -.132 .115 -.116 .139 -.131 .222 .416*** .272* -.032

Air Emissions .347** -.077 .050 .009 -.016 .043 -.260* 0.173 .334** .347** .261*




performances


In order to verify which factors influence improvements in environmental performance and, in particular, if

these are determined by the level of implementation of an EMS, an analysis of causal relationships was

carried out by using regression analysis.

For the definition of the dependent variable (improvement in environmental performance) an index was

created which was determined by a linear combination of the responses to the questions about

performance improvements related to energy efficiency, waste production, water consumption and

atmospheric emissions, as they had a very high response rate. For the measurement of the level of

implementation of the management system, through the analysis of the principle components, a unique

factor was created using the responses to the 12 questions with which the researchers attempted to

measure the level of implementation of individual requirements.

The results of the ordinal logistic regression model show that an EMS with well-structured, correctly

implemented monitoring activities increases the probability of achieving greater improvements in

environmental performance. This confirms that the achievement of the EMAS registration does not

guarantee continuous improvement in environmental performance, but only its full implementation brings

about observable effects. This finding does not determine any effectiveness or benefits resulting from the

certification alone.

Among the control variables it is shown that, in line with the results of Iraldo et al. (2009), the maturity of

the management system has a positive effect on performance improvements.

Table 16 Logistic regression for the valuation of the relationship between improvements in environmental

performance and the level of implementation of the EMS

Environmental performance improvement

Coeff. Z

EMS level of implementation 0.489** 2.46

Environmental monitoring 0.352*** 4.28

EMAS maturity (Number of years since registration was acquired)

0.117** 2.48

Age of the organizations -0.001 -0.38

Number of employees -4.484 -0.15


0.366 0.79


0.184 0.41


0.522 0.47

National market (compared to the local market) -0.445 -0.82

European market (compared to the local market) -0.778 -1.24

International market (compared to the local market) -0.512 -0.95

Number of competitors -0.129 -0.65

Price as a competitive factor -0.416*** -3.12

Quality as a competitive factor 0.180 0.53

Reputation as a competitive factor 0.012 0.04

Relationships with suppliers as a competitive factor 0.2020 0.76

Manufacturing activity (compared to tertiary activities) 0.1056 0.21



0.485 0.67


0.232 0.33

Location Italy (compared to Est Europe) 0.799 0.89

Location Other Mediterranean Countries (compared to Est Europe)

0.494 0.54

Location Central Europe (compared to Est Europe) 0.749 0.80

Location North Europe (compared to Est Europe) 0.707 0.66




The improvement in environmental performance, and therefore the efficacy of the implementation of an

EMS which complies with EMAS requirements, necessarily depends on the investments made for

environmental improvement.

The study shows that in the last three years about 40% of EMAS registered companies have increased their

investments for environmental improvements, and only 15% have diminished them. This is rather

comforting information, considering the difficult situation the European economy is currently confronting.

38


Figure 17 Variation in investments for environmental improvement in the last 3 years

In the following figure the results of the analysis are reported by Member State. The figure shows that

about 50% of respondents in Italy (51% in total, of which 13% declare a significant increase in investments

while 38% declare an increase in investments) and from the United Kingdom (57% declare an increase in

investments) declare at least an increment in investments in environmental issues, which is also true in the

case of 30% of respondents in Spain (27%), Austria (27%) and Denmark (30%).

Figure 18 Variation in investments for environmental improvement in the last 3 years by State

Our study confirms what was already found in the literature on the ability of EMAS to stimulate

environmental investments (Rennings et al., 2007; Iraldo et al., 2009). This effect is concentrated especially

in the first years after the registration, and is naturally influenced by the economic situation of the

organization and by a strategy other than cost leadership, as shown by the results of the correlation matrix.

Table 17 Correlation matrix between environmental investments and control variables

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11)

Environmental investments

-.183*** -

.114* -.124* .011 -.065 -.018 -.207*** .024 .021 .084 .255***




performances


This evidence, which is also confirmed by the analysis of causal relationships, shows that only a well-

structured and implemented EMS acts concretely as a stimulus to the organization to continuously increase

investments in order to achieve continuous improvements in environmental performance.

Therefore, summarizing the main results of this section of the study, only a correct implementation of the

EMS can stimulate environmental investments and guarantee the real attainment of continuous

performance improvements.

40


Table 18 Logistic regression for the valuation of the relationship between environmental investments and level of

implementation of the EMS

Environmental investments

Coeff. Z

EMS level of implementation 0.318** 2.70

Environmental monitoring 0.141* 1.93

EMAS maturity (Number of years since registration was acquired)

-0.116*** 2.71

Age of the organizations 0.001 0.13

Number of employees 5.074 0.18


-0.552 -1.32


-0.609 -1.44


0.865 1.13

National market (compared to the local market) 0.576 1.32

European market (compared to the local market) 0.126 0.22

International market (compared to the local market) 0.078 0.16

Number of competitors -0.129 -0.65

Price as a competitive factor -0.862 -3.12

Quality as a competitive factor 0.332 0.26

Reputation as a competitive factor -0.409 -1.13

Relationships with suppliers as a competitive factor 0.672**0 2.30

Economic performances -0.629 -0.41

Manufacturing activity (compared to tertiary activities) -1.291**6 -2.34



-1.471** -2.51


-2.364** -2.88

Location Italy (compared to Est Europe) 1.207 1.07

Location Other Mediterranea Countries (compared to Est Europe)

1.725 1.52

Location Central Europe (compared to Est Europe) 1.458 1.27

Location North Europe (compared to Est Europe) 1.442 1.13




Table 19 Logistic regression for the valuation of the relationship between environmental investments and the level

of improvement of environmental performance

level of improvement of environmental performance

Coeff. Z

Environmental investment 0.341 2.37**




3.3 Barriers to the implementation of an EMS in accordance with the requirements of the EMAS

regulation


The barriers encountered by organizations when adopting an EMS are generally broken down into two

categories: those which are internal and those external to a company (Milieu Ltd e Risk and Policy Analysis

Ltd, 2009). (Milieu Ltd. and Risk and Policy Analysis Ltd., 2009). Various interpretations of this phenomena

are generally applied, since the obstacles encountered are heterogeneous in form and nature. As a

consequence, these latter can be further classified into smaller groups based on various criteria, given that

the obstacles can be of a nature that is internal or external, organic or economic, general or specific (SME

for example), etc.

First of all, the academic literature demonstrates that the cost of implementation is a notable disadvantage

for smaller companies because these latter tend to have more limited financial resources (Hillary, 1999,

2004; Biondi et al., 2000). Various studies agree in highlighting the crucial role of this obstacle. A 2005

survey, for example, shows that the lack of financial resources (33%) and the cost of certification (23%) are

among the main obstacles for “the implementation of an EMS (ISO, 2005).”

On the other hand, studies on the costs of EMSs (Hamschmidt and Dyllick 2001, Milieu Ltd. and Risk and

Policy Anaysis Ltd., 2009) suggest that the numbers discussed above may have been conservative estimates.

The differences in the results of the various studies are attributable to many factors, not least, the lack of a

system for accounting environmental costs.

In general, the costs resulting from an EMAS registration are low, although this may vary depending on the

competent national authorities. In some countries the costs are connected to the size of the plant and their

turnover, and to their attempt to limit obstacles for SMEs. For example, in Italy the predicted amount varies

from 50€ for small enterprises to 1,500€ for large ones.

On the one side, to give an idea of the financial resources necessary, it is worthwhile to quote the “EMAS

toolkit” (European Commission, 2000), which provides average data on the costs for companies of various

categories and sizes: €10,000 for very small companies (<10 employee), €20,000 for small companies (<50

employees), €35,000 for medium enterprises (50 <250 employees), €50,000 for large enterprises (> 250

employees)

One of the few variables studied in the literature that is indirectly “connected” to the assessment of the

costs for registration is the time of implementation that companies need in order to implement or maintain

an EMS.

In a recent study on the costs and benefits of the EMAS system (Milieu Ltd. and Risk and Policy Analysis Ltd.,

2009), registered companies were asked to indicate the number of work hours (either of their own

personnel or of employees from external companies) needed for the initial implementation of the EMAS

regulation. The range of responses varied highly. Most companies declared that they had needed external

consultants to implement the EMAS regulation (59%). There may be a compromise between the complexity

of the EMAS system (lower in smaller companies) and the skills available (also probably fewer in small

companies). As for internal employees, the activities that are more time-consuming are the environmental

analyses, the development of the EMS and internal revision.

The lack of public recognition and interest in the EMAS system (and its logo) is well-noted, and many studies

and research are in line with this hypothesis. Obviously, a limited amount of awareness means a low

response from the market. This is true for all kinds of companies, but it is probably a larger obstacle for

SMEs, who have to make a larger effort to comply since their resources are more limited. Lastly, the EVER

study revealed that the lack of competitive advantage and recognition from public institutions is a large

hindrance, while costs seem to have a marginal influence

The internal obstacles can be defined as those that hinder or limit the adoption/implementation of EMS

(Hillary, 2004). This is a vast category, which includes factors such as the lack of resources (time and human

capital), the difficulties in understanding the EMS, the inconveniences occurring during its implementation,

the internal organizational culture, etc.

42


For example, according to the related literature (Biondi et al., 2000), a first, substantial obstacle to EMAS

registration derives from the difficulty in effectively understanding the structure and its requirements. In

fact, it seems that many companies are not able to understand the EMAS system precisely, especially

regarding the initial environmental review and the EMS (Hillary et al., 1999, Hillary 2004).

Additionally, Zackrisson et al. (2000) demonstrate that 49% of companies have trouble identifying the

environmental aspects and that more than 1 in 4 are unable to identify some meaningful environmental

characteristics. Moreover, some studies found that many companies value the importance of environmental

aspects in a generic way and not according to an objective and reproducible method (IEFE et al., 2006). For

many companies the elaboration and diffusion of the EMAS Statement represents another of these

requirements which are difficult to implement. This is often due to a lack of skills and knowledge in the area

of organization, particularly within SMEs (Biondi et al., 2000).

However, other studies maintain that this is not only a question of lack of skills. MacLean (2004) defines it as

a question of “harmony” within a company (for example the interaction between businessmen and SAS

managers) relative to company priorities. It is not surprising that in such situations it is very difficult to

define performance objectives, and therefore to recognize the relevant aspects to deal when defining the

scope of EMAS.

3.3.2 Survey results

One section of the survey was dedicated to the evaluation of the main difficulties encountered by the

organizations for the active maintenance of an EMS complied with EMAS requirements.

Our results shown clearly that the costs of implementation, including therefore the internal and external

costs (31% very important and 41% moderately important), and/or the costs of registration (28% and 42%)

are again amongst the challenges that more often European organizations have to tackle. As shown by the

correlation matrix, small and medium enterprises mostly suffer from the lack of economic resources. The

regulatory relief introduced by article 7 of the new version of the EMAS regulation, which foresees the

extension of the registration’s duration to four years, with the contextual reduction of the frequency of the

surveillance audits, has not yet produced the desired effects, also due to a lack of clarity in the conditions

necessary for its application.

Therefore, as intervention aimed at clarifying this point is desirable in order to avoid an excessively

restrictive interpretation of the aforementioned requirements that could limit or offset the application of

this important regulatory relief measure. Furthermore, it is advisable to provide forms of fiscal incentives

for the costs sustained for the adoption of an EMS.

Numerous organizations (27% and 47%) indicate the pursuit of continuous improvement of their

environmental performance as another relevant challenge. In particular, this difficulty is perceived by those

who adopt a competitive strategy based on sales price and by those organizations that do not consider their

reputation to be a competitive factor. This is in line with what was shown in the preceding sections relating

to the organizations that are more likely to make investments for environmental improvements.

Lastly, the involvement of employees represents a significant difficulty for 22% of the companies

interviewed. Similarly to the findings related to the difficulty in reaching continuous improvements, also in

this case the challenge is tough especially for those companies who adopt a competitive strategy based on

sales price, and less relevant for organizations that operate in a B2B market. With regard to the difficulties

that were “less experienced”, the role of auditors and of competent bodies does not represent a problem

for more than half of the organizations interviewed. This assumption is confirmed especially by

organizations that have been registered under EMAS for many years. This gives evidence of the fact that a

possible initial difficulty connected with the lack of experience in interacting with auditors can be overcome

easily over the years following the attainment of the first registration.

Legal compliance, the functioning of the management system and the correct implementation of EMAS

requirements no longer seem to be relevant barriers for the organizations interviewed (about 50%).

Figure 19 Barriers encountered in EMAS implementation

Table 20 Correlation matrix between challenges encountered in EMAS implementation and control variables

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11)

Implementation costs (included consultants )

-.044 -.140* -.186** -.085 .059 .103 .164* .105 .006 .127 -.129

Registration costs (included auditor)

-.023 -.221***

-.172** -.031 .008 -.088 -.026 .080 .034 .120 -.192

Difficulties deriving from the functioning

of the EMAS scheme

0.013 .064 -.049 -.090 -.048 -.055 .174 .007 -.043 .001 -.179*

Difficulties related to the role of the

verifier

-.263*

-.155 -.165** -.209 .035 .133* .114 -.001 .034 .143 -.073

Difficulties related to the role of the competent body

-.199 -.129 -.168** -.096 .018 -.065 .144 -.170 -.006 .142* -.125

44


Difficulties in

implementing the requirements

.131 -.015 .040 -.021 .030 .094 .127 .217*** -.055 -.013 -.112

Difficulty attaining or maintaining legal

compliance .058 .049 -.120 -.042 .073 .095 .138 .101 -.073 .067 -.145**

Difficulties in attaining a steady

improvement of the environmental performance

.008 .137 .060 -.097 .059 .134 .204 .022 -.205 -.058 -.107

Difficulties related to drafting the Environmental

Statement

-.102 -.040 -.094 -.019 -.059 .065 .041 .171 -.050 -.101 -.064

Difficulties in involving and

motivating personnel or in getting their

commitment.

-.026 .128* .003 -.160 .093 .038 .176** .055 -.089 -.111 .022




performances


The focus on the barriers encountered in the various Member States (in the following table) shows that the

costs of implementation of the management system, as well as that of the EMAS registration, are a relevant

problem for many enterprises, and mainly for those located in the UK and in Portugal, where the highest

percentages are found.

As for continuous improvements in environmental performance, 30% of the Danish organizations declare

that this represents an important problem, as also confirmed by 29% of Italian enterprises and 27% of

Austrian ones as well.

Only a limited number of EMAS organizations consider the activities of auditors (13% of German

enterprises), and EMAS competent body (9% of those interviewed in Austria) as an obstacle, confirming

therefore that these two actors do not constitute a limitation for EMAS implementation.

Table 21 Barriers and challenges encountered in EMAS implementation by State

Difficulties encountrered

Very Important

Moderately Important

Not Important N.A.

Not answered

Implementation costs (including

consultants)

Italy 33% 45% 16% 2% 5% Spain 23% 31% 12% 0% 35%

Germany 38% 31% 13% 0% 19% Austria 18% 73% 0% 0% 9%

Denmark 20% 50% 20% 0% 10% Portugal 44% 22% 0% 0% 33% United

Kingdom 57% 14% 14% 0% 14%

Czech Republic

0% 33% 50% 17% 0%

others 28% 33% 11% 0% 28%

Registration costs (including

Italy 28% 48% 18% 1% 4% Spain 35% 31% 19% 4% 12%


Very Important


Not Important N.A.

Not answered

verifier costs) Germany 19% 31% 31% 0% 19% Austria 27% 45% 18% 0% 9%


Kingdom 71% 14% 0% 0% 14%

Czech Republic

0% 33% 50% 17% 0%

others 17% 28% 22% 6% 28%

Difficulties deriving from the functioning of the

EMAS scheme

Italy 12% 40% 42% 1% 5% Spain 15% 35% 31% 4% 15%

Germany 13% 44% 19% 6% 19% Austria 18% 27% 36% 9% 9%


Kingdom 14% 14% 57% 0% 14%

Czech Republic

0% 0% 83% 17% 0%

others 11% 44% 17% 0% 28%

Difficulties related to the role of the verifier

Italy 6% 30% 57% 1% 6% Spain 12% 42% 27% 4% 15%

Germany 13% 6% 56% 6% 19% Austria 0% 36% 45% 9% 9%


Kingdom 29% 0% 57% 0% 14%

Czech Republic

0% 17% 67% 17% 0%

others 6% 33% 33% 28% 0%


Italy 7% 38% 48% 1% 6% Spain 15% 42% 27% 0% 15%

Germany 6% 25% 44% 6% 19% Austria 9% 27% 45% 9% 9%


Kingdom 0% 14% 71% 0% 14%

Czech Republic

0% 17% 67% 17% 0%

others 11% 33% 22% 6% 28%

Difficulties in implementing the requirements

Italy 11% 40% 41% 1% 6% Spain 23% 31% 31% 0% 15%

Germany 13% 50% 19% 0% 19% Austria 9% 27% 55% 0% 9%


Kingdom 14% 14% 57% 0% 14%

46



Very Important


Not Important N.A.

Not answered

Czech Republic

0% 33% 50% 17% 0%

others 17% 33% 17% 6% 28%

Difficulties in attaining or maintaining regulatory compliance

Italy 9% 32% 52% 1% 6% Spain 23% 27% 31% 0% 19%

Germany 6% 38% 31% 6% 19% Austria 9% 18% 55% 9% 9%


Kingdom 0% 14% 71% 0% 14%

Czech Republic

0% 33% 50% 0% 17%

others 11% 39% 22% 0% 28%

Difficulties in attaining a steady improvement of the environmental performance

Italy 29% 48% 18% 1% 5% Spain 23% 42% 19% 0% 15%

Germany 25% 56% 0% 0% 19% Austria 27% 27% 18% 18% 9%


Kingdom 14% 14% 57% 0% 14%

Czech Republic

17% 33% 33% 17% 0%

others 22% 33% 17% 0% 28%

Difficulties related to drafting the environmental Statement

Italy 9% 40% 45% 1% 5% Spain 12% 27% 23% 0% 38%

Germany 13% 31% 38% 0% 19% Austria 18% 36% 27% 9% 9%


Kingdom 14% 0% 71% 0% 14%

Czech Republic

0% 33% 50% 17% 0%

others 11% 33% 28% 0% 28%

Difficulties in involving and motivating personnel or in getting their commitment.

Italy 26% 48% 20% 1% 6% Spain 23% 31% 8% 0% 38%

Germany 13% 50% 19% 0% 19% Austria 9% 36% 36% 9% 9%


Kingdom 14% 43% 29% 0% 14%

Czech Republic

17% 50% 17% 17% 0%

others 17% 39% 17% 0% 28%

3.4 Stakeholder role in stimulating actions for environmental improvement


As posited by the stakeholder theory, stakeholder pressure significantly motivates organizations to adopt

various environmental practices (Sarkis et al. 2010). Beginning with Freeman’s definition of stakeholders, i.e.

any group or individual who can affect or is affected by the achievements of the organization’s objectives

(Freeman, 1984), Clarkson (1995) identified two key stakeholder groups according to their main interests:

the primary stakeholder group without whose continuing participation the corporation cannot survive; the

secondary stakeholder group which has an interest in the organization but it is not essential for its survival.

Not all stakeholders, however, have the same influence: Mitchell et al. (1997) state that organizations

mostly take into account the stakeholders who are considered powerful, legitimate, and urgent.

In the literature, the analysis of determinants for the adoption of environmental practices, such as an

environmental agreement, focused on different sources of “stimulus” that drive the development of these

instruments and that encourage an organization to participate (Reed, 2008; Blanco et al. 2009). Di Maggio

and Powell (1983), for instance, argue that managerial decisions to adopt environmental initiatives may be

influenced by three institutional mechanisms: normative, coercive and mimetic. Normative pressures, such

as customer requirements, cause organizations to conform in order to be perceived by the public as more

legitimate. In addition, community and environmental interest groups (Henriques & Sadorsky, 1996) and

industrial associations (Guler et al. 2002) can exert this kind of pressure encouraging managers to undertake

supply chain-oriented strategic actions, to increase their reputation and upgrade their image on the market.

Coercive pressure can be imposed by several external stakeholders, depending on their power. For instance,

by means of stringent environmental regulations, government bodies may force firms to adopt

environmental practices (Delmas, 2002, Testa et al. 2011b; Testa et al. 2012). This pressure arises from

threats of penalties and fines for non-compliance, or from requirements to publicly disclose information

concerning the organization’s environmental impact (Konar and Cohen, 1997).

Henriques and Sadorsky (1999) found that pressure from regulatory stakeholders (e.g. governments, trade

associations) is higher in environmentally reactive firms whereas pressure from organizational stakeholders

(e.g. customers, suppliers, employees, shareholders) is higher in environmentally proactive firms.

By focusing on specific types of stakeholder several studies found the positive influence of stakeholders

such as consumers (Dasgupta et al. 2000), shareholders (Henriques and Sadorsky, 1996), industrial

association (Jimenez, 2007), environmental interest groups (Henriques and Sadorsky, 1996), public

authorities (Alberini and Segerson, 2002, Daddi et al. 2013; Testa et al. 2014b) in motivating environmental

actions. Internal stakeholders also play a significant role in the adoption of environmental practices:

employees, for instance, are the source of a company’s competitive advantage and a successful

environmental strategy requires their participation (Buzzelli, 1991). However, to ensure an organization is

deeply committed to environmental issues, employees must have support from top management (Sarkis et

al. 2010).

Furthermore, managers can also be encouraged to participate in voluntary programs by strategic

motivations (Testa and Iraldo, 2010). Voluntary programs, in fact, can provide a variety of benefits such as

public recognition (Alberini and Segerson, 2002, Gusmerotti et al. 2012) which enables firms to increase

market share or charge higher prices for their products (Khanna, 2001). In the effort to increase productivity

of resources and decrease costs, an EMS can be adopted to rationalize the use of an input (resources) such

as energy and primary materials, and at the same time, reduce the outputs of waste (Khanna & Anton,

2002). The adoption of an EMS can improve the reputation and image of a company, and consequently, its

relationships with clients, investors, the local community, and other stakeholders (Biondi et al., 2000;

Bransal and Roth, 2000; Khanna and Anton, 2002; Bansal and Hunter, 2003).

The results of another recent study also show that normative obligations and other external pressures

stimulate proactive behaviour at the managerial level and bring about the application of an EMS (Darnall et

al., 2008; Gavronski et al., 2008). In a 2008 study by Darnall et al., based on some aspects of the

institutional theory, and on a vision of companies which are based on resources, it was found that

48


institutional pressures (normative pressures, social and market pressures), resources and skills (such as

employee engagement and environmental R & S), encourage a more complete adoption of an EMS.

The overcoming of informative asymmetries (King et al., 2005) and the conformity to ever-increasing legal

requirements (Biondi et al., 2000) represent further determining causes.

3.4.2 Survey results

In order to evaluate the role of the external stakeholders in the activities (and strategies) of EMAS registered

companies, organizations were asked to evaluate the level of influence of a few categories of stakeholders

related to the adoption of actions for environmental improvement.

The results of our study confirms the important role of public authorities in stimulating actions for

environmental improvement. Such pressure can be interpreted in a twofold way. On the one hand, the

pressure exerted on companies by public subjects at the territorial level stimulates, for example, the

participation in voluntary initiatives of a local character, directed towards adopting a certain practice or a

specific technology. On the other hand, attention and strictness of the legislator is constantly increasing

through command and control tools. The pressure from public authorities is considered very important by

36% of companies interviewed, while 19% considers the influence of commercial buyers relevant, especially

in the companies that deem their reputation a central element of their strategy.

The stakeholders that exert least pressure towards actions for environmental improvement are workers

unions and banks. While this result is rather expected regarding trade unions, our study highlights that

financial institutions still do not consider environmental risk to be a influent element in the analysis of the

financial risk of an organization and they do not, in fact, take any action to stimulate improvements in

environmental performance by client-enterprises. 20% of the sample recognizes the role of Non-

Governmental environmental groups and consumers (25%).

Figure 20 Stakeholders that influenced the choice of the organizations to adopt actions for environmental

improvement

Table 22 Correlation matrix between stakeholder influence and control variables

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11)

Public authorities -.066 -.198 -.136 -.037 -.165* .102 .003

-.198***

-.044 -.233 -.015

Consumers .254** .167* .171 .253*** -.078 -.158 -.132 -.010 .106 -.043 -.193 Trade buyers .116 -.005 .018 .057 .149* .161* .063 .102 .198 .097 -.142 Suppliers of goods and services -.018 -.194 -.203 -.029 .112 -.088 -.069 .063 .176 .246*** -.127

Shareholders and investment funds .165 .008 .059 .072 .087 -.063 -.119 -.014 -.031 -.077 -.044

Banks and other financial institutions

. 185 219** .202** -.043 .114 .082 .164 .078 .049 .147* .030

Trade unions .191 .152* .163* .072 .133 -.100 .002 .180*** .072 .173*** -.160* Industrial or trade associations

.121 -.036 -.015 -.088 -.039 .168* .048 .068 -.041 .132 -.124

Environmental groups or organisations

.022 -.102 -.097 -.130 -.053 .146* -.058 -.055 .062 .010 -.109

Neighbourhood groups/communities .095 .020 .035 -.072 -.075 -.067 -.003 .082 .095 .006 .007




performances


The focus on the responses at Member State level reveals different opinions that are not always paralleled

in the European context. The role of public entities is shown to be very important for 44% of respondents in

Italy and for 67% in Portugal. The role of public entities is less significant in countries such as Austria and

Germany. The role of consumers is judged differently by the organizations in the different States.

Consumers play a very important role in Austria (73%) and in Denmark (70%), while only 37% of Italian

organizations did judge them to be so. Activists and investment funds are considered very important by

56% of Portuguese respondents. Industries and commercial associations are considered very important for

30% of Danish respondents, environmental groups by 86% of the United Kingdom and 55% of Austrian

respondents.

The results of the study depict a totally heterogeneous picture and a peculiar role of the various

stakeholders which strongly differs from country to country.

50


Table 23 Stakeholders that influenced the choice of the organizations to adopt actions for environmental

improvements by Member State

Stakeholder Country Very Important


Not Important N.A.

Not answered

Public authorities

Italy 44% 29% 18% 3% 6%

Spain 19% 31% 0%

8% 42% Germany 25% 19% 31% 0% 25% Austria 18% 45% 27% 0% 9% Denmark 30% 60% 10% 0% 0% Portugal 67% 11% 0% 11% 11% UK 0% 57% 14% 14% 14% Czech Republic 33% 50% 0% 0% 17% others 28% 22% 22% 6% 22%

Consumers

Italy 11% 21% 37% 17% 14% Spain 38% 15% 15% 8% 23% Germany 31% 25% 19% 0% 25% Austria 73% 9% 9% 0% 9% Denmark 70% 10% 10% 10% 0% Portugal 33% 33% 22% 0% 11% UK 57% 29% 0% 0% 14% Czech Republic 50% 17% 0% 33% 0% others 33% 28% 22% 0% 17%

Trade buyers


Stakeholder Country Very

Important Moderately Important

Not Important N.A.

Not answered

Suppliers of goods and services


Shareholders and investment funds


Banks and other financial

institutions


52




Not Important N.A.

Not answered

Trade unions


Industrial or trade associations


Environmental groups or

organisations




Not Important N.A.

Not answered

Neighbourhood groups/communities

Italy 9% 13% 48% 17% 13% Spain 8% 19% 19% 31% 23% Germany 6% 31% 31% 0% 31% Austria 27% 45% 18% 0% 9% Denmark 20% 30% 50% 0% 0% Portugal 11% 22% 11% 22% 33% UK 43% 14% 14% 14% 14% Czech Republic 17% 50% 17% 17% 0% Others 28% 17% 28% 11% 17%

Other groups or associations


54


I N C E N T I V E S : T H E R O L E O F T H E R E G U L A T O R Y R E L I E F

4.1 Regulatory relief in the European Union

Over the last years, the European Commission and other EU institutions have promoted many initiatives to

observe and consolidate the process of simplification of the European legislation in order to reduce its

economic, social and environmental effects.

The objective of the EU policies and strategies was that of simplifying the environmental norms in order to

provide tangible advantages for citizens, enterprises and public administrations. This strategy was received

in the EC Communication “Minimizing regulatory burden for SMEs” (COM(2011) 803 final) and with the

ECAP program, which focused on improvements in the environmental conformity of small and medium

enterprises.

The issue of regulatory reliefs in the area of environmental policy is tightly connected to that of

dissemination of EMAS and ISO14001. The possibility of providing administrative relief for the companies

that adopt an EMS-based certification scheme has two effects: that of valorising the environmental

commitment by organizations through a reduction in the administrative “burden” to which they are

subject, and that of simplifying the bureaucratic apparatus, in favour of all the organizations, citizens and

public administrations.

The B.R.A.V.E. project, starting form the first studies of the Commission, in which a survey was taken of the

regulatory relief measures existing in the various Member States to favour the EMAS registered

enterprises, analyzed the level of diffusion of regulatory relief measures in some Eu countries (Austria,

Denmark, Germany, Italy, Portugal, Spain), selected among those with the highest number of registrations.

The study conducted in the project is focused on the two macro typologies of tools indicated by the

Commission:

• Regulatory flexibility, including simplifications in administrative proceedings, controls, etc.,

• Promotional incentives, including financing, measures for the incentivizing of Green Public

Procurement etc.

As an outcome of the research, as a whole, 155 existing measures emerged at the regional level as well as

81 national measures. The results show that the tools for economic support and funding are still rather

widespread for supporting environmental voluntary certification schemes and they represent a significant

share of the total identified measures. Measures for reducing monitoring and information requirements

that organizations must provide in the phases of issuance and renewal of the permits and authorizations

are significantly widespread.

The application of these instruments is different between the Member States. For example, in Austria, the

objective of most of the regulatory relief measures is to valorize the EMAS validated documentation as the

Environmental Statement. In Denmark, the main goal is to reduce controls and inspections, a common

aspect in Italy as well, where, on the other hand, measures to reduce costs connected to instructive

proceedings and financial guarantees prevail.

4.2 Survey results

The following paragraph presents and describes the results of the study with reference to the level of

knowledge and application of the normative and administrative reliefs existing in the EU. The findings of

our survey not only offer some hints to reflect on the organizations’ knowledge and application of the

existing measures and incentives, but they especially highlight the role of these instruments to incentivize

the adoption of EMAS and the advantages and challenges connected with its implementation.

In general, a high level of knowledge of the regulatory and administrative provisions that give value to

EMAS and environmental vountary certifications was found, along with a significant level of adoption of

these measures. The outcomes of our survey clearly show that some specific measures outnumber others,

e.g. the extension of permits and authorizations, which are today largely predominating over other

provisions that companies rarely utilize.

An in-depth analysis has been dedicated to the role of the regulatory relief measures in incentivizing EMAS

implementation, in order to better understand their influence over the last years. The paragraph on the

advantages and challenges connected with environmental voluntary certification shows how the issues

related to economic efficiency and bureaucratic burden are still among the most relevant aspects for EMAS

organizations.

The last paragraph presents the proposals and suggestions for the definition of new regulatory relief

measures arising from the study.

4.2.1 Knowledge and utilization of regulatory relief measures

The study reveals that regulatory relief is known by most of the EMAS organizations interviewed. The first

question of section 6, dedicated to this subject, aimed to investigate the level of awareness of the existing

measures in Italy.

The results, reported in the following figure, show that 63% of organizations declared awareness of the

existing measures.

Figure 21 Awareness of national and regional regulatory relief measures by EMAS/ISO 14001 certified companies

Analyzing the data with the geographical breakdown, we found that more than 50% of organizations

operating in Italy, Spain, Germany and Austria are aware of the normative reliefs for EMAS registered

companies (75%, 54%, 81% and 64% respectively) that are available in those countries. Approximately 40%

of organizations are aware of the existing regulatory reliefs in the United Kingdom and in Denmark, while

this number decreases to 11% in Portugal and even to 0% in the Czech Republic.

56


Figure 22 Percentage of awareness of regulatory relief measures by State

Regarding the level of application of the regulatory reliefs, we found that only 43% of the interviewed

organizations have adopted or benefitted from one of the existing regulatory relief measures.

At the geographical level, the most significant data are again those of Italy, Spain and Austria, where more

than 50% of the organizations of the sample declare that they have utilized some measure of regulatory

relief (50%, 58% and 55% respectively). The percentage is reduced to about 40% in Germany and Denmark,

and down to 11% in Portugal.

Figure 23 Companies that have used regulatory relief measures since registration

Figure 24: Percentage of companies that have used regulatory relief measures by Member State

The study included a focus on the types of regulatory reliefs most used by organizations. The following

figure shows that 44% of the organizations confirmed that they took advantage of the possibility to extend

the length of their authorizations and/or permits. The number of enterprises that utilized the reduction in

financial guarantees was also significant (about 32%), as well as the number of those companies that

obtained some form of tax reduction (26%).

Figure 25 Typology of regulatory relief utilized

58


The geographical breakdown of the data shows the prevalence of Italy, Austria and Germany when it comes

to using the regulatory relief measures involving EMAS as a sort of “self-certification”.

An analysis of the results shows that for Italy, the reduction in financial guarantees (42%), a longer duration

of the authorization (59%) and tax reduction (32%) are the measures that organizations use most.

In contrast, considering the data about Germany, it is evident that the reduction in inspections by the

competent authorities (83%) and the self-certification procedures for renewal or issuance of the permits

(50%) are the measures that most organizations use. The same was found in Austria, where along with self-

certification for the issuance/renewal of permits and the reduction in inspections by the competent

authorities, the reduction in internal auditing obligations was also found to be one of the most-utilized

regulatory reliefs. In Spain, the measures that organizations adopted most were those relative to self-

certification for the renewal and issuance of permits and the reduction in technical reports to be sent to the

competent authorities (27% respectively), but the percentage of organizations that used these measures

was found to be much lower in Spain than in Germany and Austria.

Table 24 Typology of regulatory relief measure used by enterprises by State

Italy Spain Germany Austria Denmark # % # % # % # % # %

Reduction financial guarantee required for specific activities

30 42% 1 7% 1 17% 1 17%

Extension of permit period 42 59% 2 13% 1 17%

Self-declaration in the procedure of extension of a permission

7 10% 4 27% 3 50% 3 50%

Self-declaration in the procedure of achieving a permission

2 3% 4 27% 3 50% 1 17%

Fast track permits 5 7%

1 25%

Reduced reporting and monitoring requirements

4 6% 1 7% 1 17% 4 67% 2 50%

Reduction of inspections 7 10% 2 13% 5 83% 3 50% 1 25%

Reduction of technical reports to the competent body or use of reports drafted within the certification procedure

7 10% 4 27% 1 17% 1 17% 1 25%

Tax Reduction 23 32% 1 7% 2 33%

1 25%

Advantages in the execution of contracts to supply and / or work with the Public Administration

6 8% 1 7% 1 17% 2 33%

Other 3 4%

1 17%

4.3.2 Regulatory reliefs as an incentive for EMAS adoption

This section, dedicated exclusively to those organizations that previously responded that they had used (or

benefitted form) some regulatory reliefs, aims to investigate specifically the relationship between the

measures for regulatory relief and EMAS registration.

The questions posed in this section of the questionnaire clearly aim at understanding the role of regulatory

relief as an incentive to adopt EMAS. The present section also aims to compare the level of interest of the

organizations in these measures, with other motivating factors that have pushed them to obtain

registration.

50% of respondents declared that the possibility to access regulatory relief measures contributed, along

with other factors, to the organization choice to obtain EMAS. In contrast to this indication, 37% of the

sample did not consider regulatory relief to be a motivation to obtain certification, but instead indicated

other factors such as competitiveness, the opportunity to increase efficiency and effectiveness, etc.

60


Figure 26 Regulatory reliefs as a motive for obtaining certification

The analysis of the role of regulatory relief as an incentive for EMAS adoption shows that the these

measures were the most important motivation for a significant percentage of organizations in Austria (16%).

In the other Member States, the most common response tended to attribute a certain relevance to the

regulatory relief along with other motivations (Italy 55%, Germany 67%, Denmark 50%, Austria 67%). It is

necessary to mention Spain individually, where the percentage of companies that consider regulatory relief

to be an incentivizing factor, along with other factors, decreases to around 7%, while 33% do not consider

regulatory relief important at all.

Figure 27 Regulatory relief as a motive for obtaining certification by State

Comparing the role of the regulatory relief measures with the other possible motivations in the decision to

adhere to the EU regulation (improvement of the organization’s image, improvement of relations with the

authorities, improvement of internal organization, etc.), the study found that for a significant quota of the

interviewed organizations, regulatory relief played a significant role. In particular, for 44% of the sample

regulatory relief was important (and very important for 9%).

The percentage of companies that were indifferent or attributed no relevance to regulatory relief stands at

38%.

Figure 28 The role of regulatory reliefs with respect to all the other motivations

The geographical breakdown of the data shows that for most organizations located in the various Member

States, the role of regulatory relief was important with respect to other motivations.

For about 50% of the organizations operating in Italy, Germany and Denmark, regulatory relief played an

important role with respect to other motivations, a datum that contrasts strongly with the data of the other

three countries reported in the following table; for organizations in Spain, Portugal, and Austria, these

measures do not prevail over other motivations that push organizations to adopt EMAS.

Table25 The role of the regulatory reliefs with respect to all other motivations by State

Very important Important Indifferent No importance Not answered

Italy 9 37 10 13 2

13% 52% 14% 18% 3%

Spain 2 3 4 6

0% 13% 20% 27% 40%

Germany 3 2 1

0% 50% 33% 17% 0%

Austria 1 1 3 1

17% 17% 50% 17% 0%

Denmark 2 2

0% 50% 50% 0% 0%

Portugal 1

1

0% 0% 50% 0% 50%

4.2.3 The advantages and drawbacks of using the measures for regulatory relief

The advantages and challenges connected to the possibility of using the existing measures of regulatory

relief are another issue that was examined in this study.

The objective of the regulatory reliefs is to provide concrete advantages to companies that are actively

engaged in reducing their impact on the environment, beyond what is required by law. The type of

advantage is often connected to the type of relief that generates it and it can be a direct or indirect

economic savings (reduction in costs or time) or a market opportunity. Therefore, our survey asked the

organizations to judge some types of advantages obtained thanks to the regulatory reliefs used:

62


• Improved company motivation to obtain the certification

• Savings in the time of employees

• Reduction in costs

The advantage of the regulatory relief on which the highest number of the respondents agreed is the

reduction of costs, followed by higher motivation within the company. The advantage that was recognized

by the lowest number of organizations was the savings in management time and in time of employees.

Other advantages were listed by some companies, which can be attributed to two larger categories: those

relating to improved internal management, and those that influence external relationships (image, third

parties, etc.). In the first category, for example, the management of the flow of data and information was

mentioned as a considerable benefit, along with improved control of processes for the necessary regulatory

compliance. For the improvement of relations with external entities, the inherent advantages of improved

image and credibility were listed, as well as improved environmental communication and better

relationships with third parties in general.

Figure 29 Advantages of using regulatory reliefs since the organization was certified/registered

The motivational aspect proved to be the main advantage in organizations located in Italy (24%), Germany

(50%) and Austria (17%). The organizations that consider the improvement of company motivation one of

the main advantages connected to regulatory relief are distributed throughout all the EU, confirming a

common opinion at the geographical level. The data clearly show that the savings in costs is an advantage

noted by the enterprises that have utilized regulatory reliefs, in contrast with the savings in the time of

employees, which is considered an advantage only in Denmark (50%), Austria (33%) and Germany (33%).

Table 26 Advantages of using the regulatory reliefs since the organization was certified/registered by State

Strongly agree Agree Disagree N.A.

Not answered

Reduction of costs

Italy 18% 49% 24% 1% 7% Spain 13% 13% 20% 13% 40%

Germany 0% 100% 0% 0% 0%

Austria 17% 67% 17% 0% 0% Denmark 25% 50% 0% 25% 0% Portugal 0% 0% 100% 0% 0% others 50% 50% 0% 0% 0%

Saving employees'

time

Italy 6% 37% 42% 11% 11% Spain 13% 7% 27% 40% 40%

Germany 33% 50% 0% 0% 0% Austria 33% 50% 0% 0% 0%

Denmark 50% 25% 0% 0% 0% Portugal 0% 0% 100% 100% 100% others 50% 0% 50% 0% 0%

Stronger company's motivation to maintain certification

Italy 24% 58% 11% 0% 7% Spain 0% 47% 7% 7% 40%

Germany 50% 50% 0% 0% 0% Austria 17% 33% 33% 17% 0%


Other

Italy 4% 7% 1% 61% 27% Spain 0% 0% 0% 0% 100%

Germany 0% 17% 0% 0% 83% Austria 0% 0% 0% 0% 100%


In addition to the advantages, the difficulties and hurdles encountered by organizations in utilizing the

regulatory relief were also analyzed. The data on the use of the existing measures clearly show some limits

in access to the regulatory reliefs by EMAS organizations. Only about 40% of the sample actually declared

having benefited from administrative facilitation / simplification or from incentives. Furthermore, the

feedback on the types of measures shows that despite the high number of rewarding provisions for EMAS

registered companies, only two types (extending the validity of the authorization / permit and reduction in

financial guarantees) were shown to be significantly utilized.

Our study shows that the most significant obstacle in accessing the regulatory reliefs is (quite paradoxically)

that of an excess in the “red tape”, i.e.: the bureaucracy needed to adopt the regulatory relief measure. This

is followed by minimal publication of the regulatory relief and a lack of clarity of these measures in the

relevant normative and legislative text.

64


Figure 30 Challenges in using regulatory relief measures

The analysis of the data at the geographical level shows that the excess in bureaucracy was perceived as a

problem in Italy, Spain, Germany and Austria, albeit this problem is considered a challenge for the

companies located in the other Member States as well. In Germany and Austria the lack of competence of

those responsible for adopting the regulatory reliefs represented a considerable barrier (in Germany 50%

strongly agree with this, while in Austria 67% agree). The problem of the “clarity” with which the measure is

expressed is strongly felt in all the Member States, while the problem of publication of the measure is

particularly noted in Germany (100%) and Austria (50%).

Only a circumscribed percentage of enterprises did not encounter any barrier in accessing the regulatory

relief and they are all located in Italy (18%), Austria (17%) and Spain (7%).

Table 27 Main challenges that organizations encountered by Member State

Strongly agree Agree Disagree N.A. Not

answered

Regulations did not clearly explain measure

Italy 13% 37% 11% 11% 15% Spain 27% 53% 0% 0% 7%

Germany 67% 17% 17% 17% 0% Austria 33% 33% 17% 17% 0%

Denmark 25% 50% 25% 25% 0% Portugal 0% 100% 0% 0% 0%

The measure was not advertised and I was not

aware till too late

Italy 13% 37% 8% 8% 14% Spain 27% 40% 0% 0% 0%

Germany 100% 0% 0% 0% 0% Austria 50% 17% 17% 17% 0%


Too much red tape

Italy 13% 48% 6% 6% 13% Spain 13% 40% 13% 13% 0%

Germany 33% 33% 17% 17% 0% Austria 33% 50% 17% 17% 0%


Low competence/knowledge of

Italy 14% 32% 6% 6% 17% Spain 13% 13% 40% 40% 20%

Strongly agree Agree Disagree N.A. Not

answered public servants Germany 50% 33% 0% 0% 0%

Austria 0% 67% 17% 17% 0% Denmark 25% 0% 50% 50% 0% Portugal 0% 0% 0% 0% 100%

None

Italy 18% 20% 11% 11% 21% Spain 7% 7% 0% 0% 87%

Germany 0% 0% 83% 83% 0% Austria 17% 50% 17% 17% 0%


Other

Italy 1% 6% 61% 61% 28% Spain 0% 0% 0% 0% 100%

Germany 0% 0% 0% 0% 100% Austria 0% 0% 0% 0% 100%


4.3.4 Suggestions for further regulatory reliefs

In order to provide indications on the future opportunities for new measures to be developed or existing

measures to be strengthened, the two final questions of our survey were essential. These were aimed at

gathering proposals for further regulatory relief that the respondents would appreciate, in addition to

those that already exist in the national and regional regulations. Furthermore, it was investigated how these

measures should be effectively communicated to the potentially interested companies.

The measures that emerged as “most desired” (65%) are the introduction of new forms of tax cuts, the

reduction in technical reports to be sent to the competent authorities (41%) and the reduction in controls

(e.g. inspection frequency, 39%). Moreover, 38% of the organizations interviewed indicated among their

preferences the renewal of the authorization through self-certification. The least successful proposal was

the reduction in internal auditing obligations, about which the companies expressed limited interest (this is

due to the fact that in many Member State such an obligation does not exist).

66


Figure 31 Typologies of regulatory reliefs that would be appreciated (in addition to currently existing ones)

All interviewed organizations, regardless of their geographical location, stated they would strongly

appreciate (further) tax reductions for EMAS registered companies. The interest in this type of incentive is

strongly felt in all Member States, especially in the Czech Republic (83%), in Italy (76%) and in Austria (64%),

where a high percentage of those interviewed emphasised this measure. Regarding Italy, it has to be noted

that tax relief measures are already implemented at the regional level and forms of reductions of the

financial guarantees are very commonly requested to enterprises (for example for waste treatment plants).

Registered organizations from Austria and Italy also confirm they are interested in promoting reduced

controls in favour of EMAS enterprises and in a stronger and extended use of self-certification for the

renewal of the authorizations and permits. Organizations operating in Denmark are in favour of a reduction

in technical reports (40%). The Danish government has already undertaken this approach by adopting a

norm that provides that EMAS registered enterprises are not obligated to send the annual Green Report.

The reduction in technical reports is relevant for all organizations throughout the Member States.

Table 28 Further typologies of regulatory reliefs that would be appreciated by State

Further tax reduction

Less controls by the

competent control bodies

Longer lasting

authorisation

Renewal of the

authorisation by self-

certification

Reduction of

compulsory internal

monitoring

Reduction of technical

reports to the competent body/use of

reports drafted

within the certification procedure

Other

% % % % % % % Italy 107 76% 66 47% 53 38% 63 45% 25 18% 66 47% 9 6% Spain 11 42% 2 8% 3 12% 7 27% 3 12% 6 23% 0% Germany 6 38% 5 31% 6 38% 4 25% 4 25% 7 44% 1 6%


Less controls by the

competent control bodies

Longer lasting

authorisation

Renewal of the

authorisation by self-

certification

Reduction of

compulsory internal

monitoring

Reduction of technical

reports to the competent body/use of

reports drafted

within the certification procedure

Other

Austria 7 64% 5 45% 4 36% 7 64% 2 18% 3 27% 0% Denmark 2 20% 3 30% 3 30% 1 10% 3 30% 4 40% 0% Portugal 7 78% 3 33% 4 44% 3 33% 1 11% 3 33% 0% UK 4 57% 0% 2 29% 3 43% 0% 1 14% 2 29% Czech Republic

5 83% 3 50% 2 33%

0%

0% 1 17%

0%

others 10 56% 9 50% 6 33% 5 28% 2 11% 8 44% 1 6%

The ways in which the measures should be communicated to the companies, on which the respondents

agree most, are periodical updates by the authorities (76%) and communications from the accredited

verifier (70%). Moreover, updates through seminars and conferences would be appreciated by respondents

(57%) as would communications by the industry associations (59%).

In contrast, the modes of communication that respondents prefer least are consultants (39%) and

newspapers and specialized magazines (48%).

Additional communication “channels” were listed, specifically the following:

- Public entities

- Mailing list

- Competent authorities

Figure 32 How the existence of regulatory relief measures should be communicated to companies

Finally, the data on the communication tools for regulatory relief were elaborated at the Member State

level. Among Italian organizations, all methods of communication seem to be highly appreciated, although

68


the expectations are essentially concentrated on the figure of the competent authorities (95%) and on the

accredited verifier (90%). In Spain, 43% of enterprises are in favour of communication through the

verification body, while only 23% deem that seminars and conferences are important and communication

through the competent authorities is effective. In Germany, the information and communication are

thought to be more effective if they come from the competent authorities (63%) and the verification body

(50%), while only 30% would like to receive information through seminars, newspapers and industry

associations. In Austria 64% of respondents declare that they would like to receive periodical updates from

the competent authorities, 36% suggest also seminars, newspapers and industry associations. Also in

Denmark the most appreciated solution is that of updates from the competent body.

Table 29 How the existence of regulatory reliefs should be communicated to companies (by State)

Seminars/ Conf.

Trade organisations

communication

Newspaper/trade

journal

Periodic update by competent bodies (Region, EMAS

Committee)

Dissemination by my certifying

body Consultants Other

Italy 74% 89% 70% 95% 90% 58% 10% Spain 23% 0% 4% 23% 42% 12% 0% Germany 31% 31% 25% 63% 50% 13% 0% Austria 36% 36% 36% 64% 18% 0% 0% Denmark 20% 0% 20% 70% 30% 0% 0% Portugal 33% 0% 33% 44% 33% 11% 0% United Kingdom 43% 29% 43% 57% 86% 29% 0% Czech Republic 67% 33% 0% 33% 33% 17% 0% others 44% 28% 17% 67% 44% 22% 0%

A N N E X - Q U E S T I O N N A I R E

SECTION I ORGANISATION DETAILS

1 How many years has your organisation been in business?________________________

2 How many full-time employees do you have (average for the last three

years)?________________________

3 How would you describe your main clients? (pick one checkbox)

Other producers 1

Traders (wholesale or retail) 2

Consumers/end users (general public) 3

Other plants within your organisation 4

4 What is the dimension of your main market?

Local 1

National 2

European 3

International 4

5 How many competitors do you have with regards to your main commercial product?

Less than 5 1

5-10 2

More than 10 3

6 Please tell us which of the following competitive factors you use to enhance your most important

product on the market

Not Important Moderately Important Very Important

1 2 3

Product price

Product quality

Organisation's reputation

Relationship with suppliers

7 How would you evaluate the economic performance of your organisation during the last three years?

(pick one checkbox)

1. Revenues were so low that we had major losses 1

2. Revenues were not enough to cover costs 2

3. Revenues were enough to break even 3

4. Revenues were enough to have some profit 4

5. Revenues were well above costs 5

SECTION II THE EMS

8 Please give each of the following statements an evaluation (from 1 to 5) of the degree of

implementation of the initiatives (1: not implemented; 2: poor implementation; 3: implementation was

started but not completed; 4: good implementation; 5: good implementation of the initiatives and

positive evaluation of their effectiveness).

70


Planning of environmental related activities

1 2 3 4 5

The environmental policy was effectively

disseminated to all employees

Based on the policy, management established

measurable objectives and targets related to the

environment

There are actions aimed at gathering opinions and

suggestions coming from the employees as regards

the environment

With reference to training activities and the involvement of employees in environmental matters:

1 2 3 4 5

Employees are offered incentives to implement the

principles and procedures related to environmental

protection.

Project teams coming from different company

departments are in charge of solving specific

environmental issues.

There is a formalised system to detect any training

needs in the environmental field.

With reference to the implementation activities of management of environmental issues (including build

up and emergency response)

1 2 3 4 5

There are specific operating instructions for the

management of environmental issues (e.g.

management of a temporary waste site, emissions to

the atmosphere, etc.)

The company has identified one or more procedures

to detect and deal with potential emergency

situations.

Emergency response procedures are periodically re-

examined and updated when necessary, especially

after scheduled checks or after emergency situations.

With reference to measurements, surveillance and internal control

1 2 3 4 5

There are formal systems to measure the

performance in order to detect the degree of

achievement of the targets.

The organisation has implemented actions to register

and investigate non compliance and preventive

actions.

Internal verifications (audits) are scheduled, aimed at

verifying the correct implementation of

instructions/procedures and the compliance with

applicable legal requirements related to the

environment.

SECTION III ENVIRONMENTAL PERFORMANCE

9 Which of the following environmental issues is best monitored in terms of number of

indicators/environmental issue?

Poorly Sufficiently In depth

(only 1 indicator) (2-3 indicators) (over 3 indicators) NA

1 2 3

• energy efficiency

• efficiency of the materials

• water consumption

• waste production

• biodiversity

• air emissions

• wastewater discharge

10 With reference to the production unit, what is the environmental improvement attained in the

following environmental aspects after implementing EMAS?

None Poor Sufficient Good High NA

1 2 3 4 5

• energy efficiency

• efficiency of the materials

• water consumption

• waste production

• biodiversity

• air emissions

SECTION IV INVESTMENTS

11 In the last three years how did the organisation's investments change in order to reach its

environmental improvement targets?

Investments significantly decreased 1

Investments decreased 2

Investments did not change 3

Investments increased 4

Investments significantly increased 5

72


SECTION V REGULATORY RELIEFS

12 Are you aware of any regional or national regulatory relief measuresfor EMAS registered companies?

Yes

No

13 Has your organisation ever benefited from regulatory relief measures since registration?

Yes

No

14 If you answered 'Yes' please specify the type of regulatory relief used?

Tax Reduction (IRAP reduction)

Reduction financial guarantee required for specific activities (for instance waste plan)

Extension of permit period (such as extension of IPPC)

Self declaration in the procedure of extension of a permission

Reduction of inspections

Reduction of technical reports to the competent body or use of reports drafted within the certification

procedure (es. Environmental Statement)

Other (specify ___________________________)

15 Was regulatory relief one of the reasons that made you apply for certification?

Yes, the main reason

Yes, one reason among others

No

16 How important was regulatory relief when compared to the other reasons for registering (such as

image, better relations with institutions, better internal organisation, etc.)?

Very important

Important

Indifferent

No importance 1

17 What are the advantages due to regulatory relief since your EMAS registration?

Strongly agree Agree Disagree - NA

Reduction of costs

Saving employees' time

Better relations with competent authorities

Stronger company's motivation to

maintain certification

Other (specify: ___________________________)

18 What are the difficulties you had when trying to take advantage of the measure for regulatory relief?


Regulations did not clearly explain the relief

The measure was not advertised and I was not aware till too late

Too much red tape

Low competence/knowledge of public servants

None

Other (specify: _________________________)

19 What type of regulatory relief would you like (apart from the ones already available)?


Less controls by the competent control bodies

Longer lasting authorisation (e.g. IPPC permit)

Renewal of the authorisation by self-certification

Reduction of compulsory internal monitoring

Reduction of technical reports to the competent body or use of reports drafted within

the certification procedure (es. Environmental Statement)

Other (specify ___________________________)

20 How should organisations be informed of such measures of regulatory relief?


Seminars/conferences

Trade organisations communication

Newspapers/trade journal

Periodic update by competent bodies (Region, EMAS Committee)

Dissemination by my certifying body

Consultants

Other (specify: ___________________________)

21 In which years in token advantage from the reduction of IRAP for EMAS enterprises?

2004

2005

2006

2007

2008

2009

2010

2011

22 That was the average annual savings obtained from the benefit of this regulatory relief?

Less than 5.000€

Between 5000 € and 10.000 €

Between 10.000 € and 25.000€

More than 25.000€

23 The cost savings achieved by the IRAP tax reduction enabled you to cover the specific costs that you

incur for maintaining the registration of EMAS (verifier costs and consulting costs)?

Si, completely

It covered a significant portion of the costs incurred (>50%)

No, it has covered only a small part

I don’t know

74


SECTION VI INCENTIVES AND HINDRANCES

24 Which of the following stakeholders influenced your organisation's choice to adopt environmental

actions aimed at reducing the impact of its activities on the environment? (Pick one checkbox for each

line)

Not Important Moderately Imp. Very Imp. N/A

1 2 3

Public authorities

Consumers

Trade buyers

Suppliers of goods and services

Shareholders and investment funds

Banks and other financial institutions

Trade unions

Industries or trade associations

Environmental groups or organisations

Neighbourhood groups/communities

Other groups or associations

(specify)___________

25 Which of the following hindrances and difficulties do you encounter in implementing EMAS?

Not Important Moderately Imp. Very Imp. N/A

1 2 3

Implementation costs (including consultants)

Registration costs (including verifier costs)

Difficulties deriving from the functioning of the EMAS scheme

Difficulties related to the role of the verifier


Difficulties in implementing the requirements

Difficulties in attaining or maintaining regulatory compliance

Difficulties in attaining a steady improvement of the environmental performance

Difficulties related to drafting the environmental Statement

Difficulties in involving and motivating personnel or in getting their commitment.

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