policy management group questionnaire...

1Delivering sustainable solutions in a more competitive world

Policy Management Group

Questionnaire Results

Brussels, 30 September 2004Robert Nuij

2

Delivering sustainable solutions in a more competitive world

Structure of the presentation

1. Objectives and Scope

2. Specific findings

3. Conclusions


1. Objectives and Scope

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• To obtain an overview of what different stakeholders are expecting from the EU Eco-label in the context of the upcoming revision of the scheme.

• Opinions sought via written consultation on the basis of a questionnaire, which was developed taking into account previous PMG discussions on the revision.

• A total of 23 responses received:

PolandFinland

SwedenNetherlandsCzech RepublicUnited KingdomNorwayDenmark

SpainItalyCataloniaPortugalFranceAustria

AeA TechnologyVKEEuroCoopÖkotexBDIEEBECVM, Euro Chlor, APMEUEAPMEBEUC


2. Specific findings

6


Question 1: Is it necessary (or at least very desirable) for there to be an ecolabelling award scheme at EU level? Why?

• Most stakeholders believe it is (very) desirable to have an EU Eco-label scheme

• Key reasons:• Eco-labelling is seen as an important tool

in IPP and SCP• Eco-labelling is an important tool to allow

consumers to choose ‘green’ products• EU Eco-label is appropriate for the internal

market and provides an example function• EU Eco-label process is based on strong

stakeholder involvement and could be used in other contexts (EuP, GPP, B2B)

yesnono repsonse

7


• Member States/Competent Bodies• Low, medium and high were all mentioned.• New Member States - low

• NGOs• EU Eco-label is important but should not

replace the need for minimum mandatory requirements.

• Industry• Generally low (several ‘no responses’)

“The scheme rates high and is seen as

a benchmarking standard with strict

criteria.”

“The Eco-label scheme doesn’t

rate as a priority for environmental policy nor as a

significant marketing

instrument”

1 a) How high does the scheme now rate as a priority of environmental policy?

8


• Other instruments mentioned were:• Environmental Product Declarations (but only

in a B-to-B context)• Product standards• Information requirements under the EuP draft

Directive• Energy labelling

• However;• Eco-labels are seen as the most transparent

and the best-suited for final consumers.

“Environmental product

declarations may be a possible

guideline for the business-to

business market and for

professional purchasers.”

“For consumers third party certified

labelling using a simple symbol to

communicate is the most credible

option.”

1 b) Are there other approaches to green product information that may be a more cost-effective use of public resources?

9


• Overall• Most stakeholders believe the EU should be

doing both. • However

• Several stakeholder indicate that the final aim should be only one scheme in the EU

• And that this will only work if the EU Eco-label can be made more ‘successful’ than the national schemes (in terms of visibility, requirements and information to consumers).

“The EU should run its own eco-label

scheme and should try to improve its visibility so as to

have a single label in the European

Market.”

“Cooperation should be on a

voluntary basis and will only work if the

Flower develops a more flexible structure for

decision making.”

1 c) Should the EU play a more coordinating role instead of running its own labelling scheme?

10


• In principle, most stakeholders see the need to improve the cost-effectiveness of the scheme.

• However, several stakeholders indicate that it might not be possible to reduce the cost of running the scheme, as stakeholder involvement will always be time and resource consuming.

• Moreover, more resources would be needed for promotion to improve the visibility of the scheme

“one should be aware that a system

with a great involvement of

stakeholders (which is one of the

strengths of ecolabelling) will

always be time consuming”

“Yes. But this does not mean that costs have to be reduced.

It is important to ensure that the eco-

label has a higher visibility”

1 d) If an EU scheme continues, should it be a priority to improve its cost-effectiveness?

11


• In principle, most stakeholders see the need for a clear vision and scope of the scheme.

• However, several stakeholders indicate that the current vision and scope are okay and that redefining them would not necessarily solve any of the problems.

• Others indicate that the vision needs to be spelled out more clearly, implemented more rigorously and be the basis for practical targets and guidelines that many could embrace.

“Preferred vision: A widely

recognised quality scheme enabling

businesses to tell consumers that

their products meet good environmental

standards.”

Question 2: Is it necessary to establish a clear vision and scope for the EU ecolabel?

yesnono response

12


• A small majority of stakeholders believe that the EU Eco-label should be both, and that these roles are interdependent.

• Most industrial stakeholders, as well as few Member States, indicate that it should primarily be a marketing instrument for promoting ‘greener’ products.

“The actual criteria setting should - as a part of IPP - support

the environmental policy of the EU but be

developed with participation of all

types of stakeholders, and the levels of the

environmental demands should

reflect the market situation, as should

the choice of product groups”

“A marketing instrument for better

competitiveness”

2 a) Should the EU Eco-label mainly be a policy or a marketing instrument?

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• Compared to the national labels, the EU Eco-label should have a complementary character (e.g. by focusing on more international product groups). It also fulfils the role of ‘national’ label in countries without their own scheme.

• Other roles could be;• Benchmark for EPDs• Criteria for EMAS• Compliance for EuP• Replacement of self-claims.

“Representing a standard that

works at the level of the EU Single

Market.”

“The EU Eco-label should guarantee

an international recognition and

should be an assurance of

environmentally friendliness”

2 b) What should be the specific role of the EU Eco-label compared to the national labels and other information instruments?

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• Most stakeholders believe that the Eco-label should have a relationship with other IPP instruments.

• Public procurement and standardisation are mentioned as main areas where eco-label criteria could be directly used.

• For public procurement purposes it was seen as necessary that specific promotion towards public purchasers would be undertaken and relevant product groups developed.

• However, other areas such as EMAS, EPDs and eco-taxes were also mentioned.

“The European eco-labelling scheme

cannot stand alone but must be seen

as a whole together with the other environmental

initiatives from the EU Commission”

“First the eco-label scheme has to be proven effectively

and have a clear vision”

2 c) Should the EU Eco-label have a strong relationship with other IPP instruments?

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• Most stakeholders believe that the label should have a ‘green’ image (e.g. to obtain NGO support), but that a case-by-case approach cannot be avoided with 27 participating countries.

• Next to this, criteria should be based on a life cycle approach and have a scientific underpinning.

“Could be a mixture of the two. This

means having a clear policy towards all the

key issues and substances (which

should explain exceptions where

necessary).”

“It should be considered that a

green image is very often founded on

emotional feelings, without any real scientific basis,

leading to the exclusion of particular

substances.”

2 d) Should it have a ‘green’ image or a ‘pragmatic’ image?

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• Most stakeholders see the current aim of 25-30% market share as the preferred level. Some call this exclusive, while others believe this to be inclusive.

• One stakeholder suggested that a more results oriented approach would be preferable; i.e. what can be achieved by adopting criteria at a certain level for each product group?

“The label should definitely be

exclusive and 20-30% would be the

preferred level.”

“Inclusive, aiming for 25- 30% of the

market.”

2 e) Should it be exclusive (e.g. 5-10% of the market) or inclusive (e.g. 30-50% of the market)?

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• Most stakeholders see the Commission keeping a central role in the scheme, either in the current system or in a more hands-of approach (e.g. in an oversight role).

• Some stakeholders prefer an outside organisation or industry to drive the criteria development.

“This must be a joint effort with the

Commission, the Member States and

the Competent bodies, with the need

to keep the Commission in a central position”

“Alternatively, ‘franchise’ the

scheme to individual industry sectors to

run (like forestry and paint schemes at

present) to ISO14024 standard, under supervision of a

Commission committee.”

2 f) Who should be mainly in charge of the scheme and why?

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• Most stakeholders believe that the main focus of eco-label criteria should be on environmental issues.

• However, some see the need to include health (which is already included to some extent) and social issues, possibly at a later stage.

“In the future social issues could be

added but it would be more useful to first obtain some

success for the label in terms of

market penetration and once this is

functioning to take this next step”

“Only environment. Other labels (e. g. fair trade) can be more efficient in

tackling other kinds of problems.”

2 g) Should the EU Eco-label cover only environmental issues or also other considerations?

19


• In principle, most stakeholders see the need for a wide range of product groups, with as a minimum an increase on current levels.

• However, stakeholders realise that this is limited by the resources needed to develop and maintain criteria.

• Anyway, market acceptance for existing product groups might be more important than adding more and more product groups that are unsuccessful.

“It requires a considerable amount

of resources to maintain existing, and develop new, criteria. Assessing the market potential of new (and

revised) criteria should therefore have

a lot of focus”

“There is an urgent need to incorporate

more everyday products, if the eco-

label is to be made more visible and more

present on the shelves.”

2 h) Should it aim for as many product groups as possible or should there be a limit?

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• Most stakeholders believe that it should address both categories but based on different criteria;

• Everyday consumer products to raise visibility of the scheme

• Environmentally ‘important’ products, whose performance can be improved through eco-labelling

• Other selection criteria mentioned were;• Producer’s interest, available at retailers,

belonging to a product group family, environmentally superior products.

“It should address environmentally

important products, i.e. products with

high environmental impact in multiple

categories used universally (e.g. refrigerators) as

well as the products with low

environmental impact per se, but used every day by many people (e.g. shopping bags). ”

2 i) Should it only address environmentally ‘important’ products or should it also cover other categories?

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• Most stakeholders believe that the life cycle approach underpinning the EU Eco-label makes single, or even very limited, criteria impossible.

• Moreover, several stakeholders indicate that this should be dependent on the type of product group and not limited in principle.

• However, some stakeholders realise that fewer criteria (e.g. by focusing on the key impacts) would be useful to improve the user-friendliness of the scheme, for example in terms of criteria revision and verification.

“The basic idea is the life cycle approach,

and the number of criteria is determined by the complexity of

the products.”

“We should be much better in limiting the

number of criteria generally – at the

moment there is a “trend” to include too

many aspects in order to

accommodate the views of all member

states and stakeholders”

2 j) Should there be a limit to the number of criteria per product group (e.g. a single criterion)?

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• Stakeholders overwhelmingly acknowledge the need to improve the visibility of the scheme.

• Ways for achieving this could be:• Partnerships between the entities responsible for

promoting the label and license holders.• Simplify and streamline the scheme to make it

easier to participate in.• More marketing/advertising such as the EU wide

campaign in October• More resources allocated at national level.• Indicate minimum size of the logo• Create market benefits e.g. via public procurement• More products• Involve industry in criteria development

“The visibility of the EU Flower should

definitely be improved,

particularly in some Member States

where there are very few products

with the EU Eco-Label or in some

cases none at all. ”

Question 3: Is it necessary to improve the visibility of the EU Eco-label scheme?

yesnono response

23


• Most stakeholders believe it’s not the amount of product groups but their respective take-up (in terms of market share or number of applicants) that is important for visibility.

• However, in some cases 1 applicant could be sufficient to guarantee visibility if it is a well-known brand.

• The issue of visibility per Member State is also important as some product groups are successful in some but have no applicants in others.

“It is more important to focus

on getting high market shares of

ecolabelledproducts within

selected product groups”

“At least one – if it has a good presence in mainstream

retailers”

3 a) and b) How many product groups and applicants are necessary to guarantee a significant level of visibility?

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• Most stakeholders believe Member States should be promoting the scheme but only a few believe they should be obliged to do so.

“At least there should be some degree of

“pressure” so as to the member states assume

more responsibility in publicising the scheme.”

“If the Eco-Label competent bodies do

not support the scheme with tangible concrete

actions, this is definitely bound to stay at a very

low level or ultimately to die. Everybody should

be very clear and honest about this.”

3 c) Should Member States be obliged to promote the scheme nationally?

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• Most stakeholders indicate that more effort and resources on marketing, advertising and promotion are needed to attract more applicants to the scheme.

• Other possibilities mentioned were:• Partnership strategy• More product groups• Lower bureaucracy• Reasonable overall cost• Direct meetings with possible applicants• Reduced VAT• Link with public procurement and other tools

“More resources to marketing, both at

the EU level as well as at the national

levels”

“Work on consumers, so that

they will demand the labelled products.”

3 d) What could be done to attract more applicants to the scheme?

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• Most stakeholders are against the use of a graded label, for the following key reasons:

• Too complicated to operate• Too confusing for consumers• Not attractive for potential license holders

• Those in favour, mention as key reasons:• Attractive for SMEs• Stimulates innovation• More flexibility• Allows licensees to show improvement

over time• Potential to provide more accurate

information to consumers

“We are very sceptical about a graded label

because we think the consumers will be

confused.”

“A graded eco-label could be useful for

SMEs, particularly the ones which would like

to improve their environmental impact and/or have a kind of

green image, but cannot afford the

costs of all compliance tests

and/or are not able to comply with the whole

set of criteria.”

3 e) Do you think a graded label could contribute to attracting more applicants?

27


• Most stakeholders indicate that this is necessary but some believe that any stakeholder involvement takes time to be seen as credible

• Possible solutions mentioned were:• By adopting a clearer vision, principles and scope• Commitment by EUEB members throughout the

criteria development process and not just at the end• Avoid discussion of ‘divisive’ issues• Follow the Nordic Swan ‘top 3 criteria’ example• Make public or abolish ISC• Agree upfront approach to ‘divisive’ issues• Establish clear mandate for ‘best in class’ criteria

“Efforts should focus on trying to reach a better and faster consensus

regarding the development and

adoption of criteria.”

Question 4: Is it necessary to improve the criteria development and decision-making procedures of the scheme?

yesnono response

28


• A majority of stakeholders indicate that this would be possible

• Possible solutions mentioned were:• A clearer goal for each product group before

the criteria development work is started• The period of criteria development should also

be used to gain market interest for the new criteria

• Spend more resources on a feasibility study before we decide to develop criteria

• Use existing national criteria as a starting point for EU Eco-label criteria development

“Yes, we must eliminate the bottle

necks in current system and make

the procedures more streamlined.”

“No. In fact the current system is already breaking

down over aspects such as setting

realistic standards and testing that the

published criteria have been achieved.”

4 a) Is significant improvement possible within the current institutional set-up?

29


• Most stakeholders indicate that it would be very difficult or impossible to reduce the time for criteria development in the current set-up for reasons of:

• Credibility and stakeholder involvement• Complexity of some product groups

• Those indicating this would be possible mainly believe reducing the number of criteria (e.g. by focusing on key issues) is the way forward.

“No - credibility reasons do not

allow this, although it might be possible

to use the criteria work in other areas,

e.g. environmental product

declarations”

“Yes – by opting for a simpler approach; focus on key issues

and not on every conceivable

impact.”

4 b) Is it possible to reduce the time for criteria development ?

30


• Most stakeholders indicate that this would be a good idea provided

• Stakeholder involvement is ensured• It is applied only to certain products i.e. where

national criteria exist or where there is a clear environmental improvement

• There is support from all stakeholders, including industry

• Competent Bodies cooperate and are transparent about their opinions

• The life cycle approach of the label is kept in mind

“Yes, if there are already national

criteria; if the majority of the

EUEB supports this and with the

support of the industry in that

sector.”

“Fast track might work if a product

group is very simple (e.g. pencils)

or national ecolabels exist and

it is possible to draw upon their

experience.”

4 c) Would it be a good idea to introduce a ‘fast-track’ procedure for certain product groups?

31


• Stakeholders are almost evenly divided on this issue.

• Those in favour indicate that it would increase ownership of the scheme and would be necessary to achieve significant growth in the number of product groups.

• Those against state the voluntary nature of Member State involvement and the need to ensure quality of the criteria as key reasons.

“Development of the criteria by

Member States should be

undertaken voluntarily.”

“Yes, if we want to develop more than 1 or 2 new product group

criteria per year.”

4 d) Should Member States be obliged to develop product group criteria?

32


• Overall, stakeholders see the need for a mandate only if

• If it would become more precise; or• If it would be used in the context of a

different set up of the scheme (e.g. for instructing a (semi) independent organisation on criteria development)

• Others believe it is still important for ‘ensuring’ the link between the Competent Bodies and the Commission

“Yes, under present arrangements, as in

practice it doesn’t add much. In a

different set-up it could be important”

“No, as this is the guarantee of some

sort of coordination between the EC and

the Competent Bodies.”

4 e) Should the mandate from the EC to Competent Bodies for developing product group criteria be eliminated?

33


• Several stakeholders indicate that the Member States should be in charge (e.g. via the EUEB or a board) with a coordinating or oversight role for the Commission

• Others envisage an independent organisation, working under direction (e.g. a mandate) from the Member States and the Commission

• Other suggestions include:• Stronger involvement of the NGOs (e.g. by

giving them voting rights)• Participation of industry should be

guaranteed

“A board (= EUEB) who has a chairman

and a secretariat and who works

under procedures set up by the

Commission. ”

“An independent organisation would be a good idea, so competent bodies

will gain time to sell the ecolabel.”

4 f) Who should be responsible for the criteria setting process?

34


• Most stakeholders indicate that a clear vision (based on specific goals) is necessary but not sufficient to solve the existing problems

• Other possibilities mentioned were:• Active participation by all Member States and

closer cooperation with the Commission• A horizontal approach to ‘divisive’ issues• Changing the participating industry ‘voice’ from

most conservative to most proactive• Be confident that criteria corresponding to

NGO demands are ‘worth it’ due to the advantages gained from the active promotion possibilities this could open up

“No. The more countries and stakeholders involved, the

more difficult it becomes to

reach an agreement.”

“The vision would not be

sufficient, but it could contribute

positively towards an

agreement.”

4 g) Would having a clear vision be sufficient to solve problems regarding the reaching of an agreement on product group criteria?

35


• Most stakeholders indicate that they would not be in favour of such a move.

“No - the ownership of the member states is

essential, and will not be ensured by an Advisory

Committee.”

“If this would mean losing the Member

States’ obligation to attend, this could be

destructive in terms of the EU ‘ness of the

label. However, if it also means that Commission

inter-service-consultation can be avoided it might be useful to consider”

4 h) Would you be in favour of replacing the Regulatory Committee with an Advisory Committee?

36


• Most respondents indicate that it would be necessary to improve these procedures. Key considerations are:

• Competent Bodies need to apply the same assessment procedures and criteria

• The cost and complexity of applying for the label needs to be reduced, especially to attract more SMEs

“It is very important that the Competent

Bodies have the same approach

towards applicants.”

“Yes. It is currently impossible for a micro-enterprise

and for most SMEs to obtain an eco-label without any

external help.”

Question 5: Is it necessary to improve the application procedures of the scheme?

37


• Most respondents indicate that this is possible provided there is a willingness to modify these procedures.

• There should be as much harmonisation as possible, for example via the establishment of a task force to address interpretation issues.

“Yes. It is more a matter of allocating

resources and a willingness to have

common procedures than a problem with the institutional set

up.”

“We have to discuss interpretation

questions more thoroughly and

change application procedures to

harmonise them more.”

5 a) and b) Is significant improvement possible within the current institutional set-up and should there be more harmonisation?

38


• Most respondents indicate that they do not believe this is necessary, both because in some Member States this is not possible for the time being, as well as because of the costs

• However, working as much as possible according to the standard should be something to strive for.

“No - though they could be

recommended to meet the principles

of this standard.”

“Yes, but the main problem is the

organisation of some competent

bodies. Moreover, the certification is

paid for each product group and is very expensive.”

5 c) Should the Competent Bodies be certified according to EN45011?

39


• A majority of respondents believe that there should be national contact points for potential licensees.

• Nevertheless, some envisage a ‘behind the scenes’ structure where different countries are experts for different sets of criteria and answer interpretation questions for all Member States.

“It is important that companies have an

entity to discuss with that is present

in their own country and who speaks

their own language.”

“Yes. Centralise by product group. So

for 2 years say, Belgium deals with

all application issues associated with dishwashers,

Sweden –detergents, UK –

fridges, etc.”

5 d) Should the application procedures be centralised?

40


• Respondents are divided on this issue.

• While some believe that important elements (such as criteria development and decision making) should not be outsourced, others have no major problems with this.

• Several respondents are in favour of using ‘expert’ help on a case by case basis (e.g. for criteria development or marketing).

“A possibility could be to outsource criteria

development to individual consultants

as is being done now.”

“Outsourcing of elements now in the

hand of the Commission however, does not seem to be a

good idea. We need the Commission to

give the scheme credibility and to keep

up the interest and activity in Member

States and with other stakeholders.”

Question 6: Is it necessary or desirable to outsource certain elements of the EU Eco-label scheme?

41


• There is limited enthusiasm for outsourcing the criteria development process. One of the arguments mentioned is that Competent Bodies need good knowledge of the criteria to communicate and promote them to various stakeholders, not least industry.

• Those in favour of outsourcing indicate that the Member States and the Commission should maintain oversight and all stakeholders should be allowed to input into the process.

“Yes, technical criteria development

because the profound know-how for different product

groups does not exist within the EU

Ecolabelling Board.”

“Only if the cooperation between the

competent bodies and the external organisation of

experts will be on high level.”

6 a) Would you be in favour of outsourcing the criteria development process?

42


• A majority of respondents indicate that the decision making and application processes should not be outsourced.

“No For credibility reasons this should

lay within the EUEB.”

“No, not at the moment. However,

a goal can be to outsource the

product certification to

accredited institutions..”

6 b) and c) Would you be in favour of outsourcing the decision making or application process?

43


• Most respondents see outsourcing as an option.

• However, some believe that Competent Bodies and other stakeholders still need to be fairly closely involved because of their specific expertise.

“Yes, it could be most beneficial to outsource

and create a central marketing and

promotional unit of e.g. 10 people who will plan campaigns, make

contacts to companies, hunt

forerunners to make the EU Ecolabel visible in every member state

with the help of national competent

bodies.”

“Yes, so that the label could be marketed as a

global brand.”

6 d) Would you be in favour of outsourcing the awareness raising and marketing activities?

44


• A majority of stakeholders is not in favour of outsourcing the entire scheme, especially if it would mean no Commission involvement.

“It is very risky to outsource the entire

running of the scheme.

Transparency, democracy and the

full involvement of all stakeholders must be

guaranteed for the scheme to be

supported by all. The eco-label is also a

political instrument, the objective of which

cannot be fully guaranteed if the

running of the scheme is

outsourced.”

6 e) Would you be in favour of outsourcing the entire running of the EU Eco-label scheme?

45


• A majority of stakeholders indicate that the financial structure should be changed.

• Those in favour of change provided the following elaboration:

• The fee from applicants should cover the total work on the application side

• Criteria development is seen as a “public task” and should thus be covered by the EU and Member States

• Cost for marketing, awareness raising etc. should be covered by public money at the start. At a later stage (where the label has more momentum) part of or all of this could be covered by the licensing fees.

“Perhaps we ought to be more creative

with fees – as a commercial entity

would be. Have ‘sales’, ‘special offers’, ‘ 2 for 1’

deals etc.”

Question 7: Is it necessary to change the financial structure of the EU Eco-label scheme?

yesnono response

46


• Several respondents indicate that the fee structure should reflect the real cost to Competent Bodies (see also previous slide).

“The application fee should reflect the

true average cost of an application

excluding verification costs.”

“Until the scheme is better recognised and accepted by all,

it is not advisable to modify the fee

structure of the scheme.”

7 a) Would you be in favour of changing the fee structure?

47


• A majority of respondents indicate that the Member States and/or the Commission should pay for criteria development. Key reasons mentioned are:

• Credibility of the criteria• Industry already pays for the

application and testing

“Should be funded centrally as part of

the resources for the body running

the scheme.”

“The Commission are paying most of this today, and this

should be maintained.”

7 b) Who should pay for the criteria development process?

48


• Overwhelmingly, respondents indicate that the industry (i.e. the applying company) should pay for the application process.

• Some believe there is a role for Member States to ‘subsidise’ the application process, specifically for small businesses.

“Part MS, part industry (it should

be government subsidised to make it less expensive –

especially to smaller business).”

“The application process should be

paid by the business applying

for the eco-label.

7 c) Who should pay for the application process ?

49


• Overall, respondents see a role for the Commission, the Member States as well as industry in these activities, although most believe that the EC and/or Member States should bear most of these costs.

“An annual fee should still be

considered but only to be used for

marketing.”

“All stakeholders, but more of these

costs must be covered by the

Member State.”

7 d) Who should pay for awareness raising and marketing activities?

50


• Most respondents do not see the need for a separate legal entity to be set up.

• Some indicate that if there would be a separate body running the scheme, it would have to be financially accountable for its activities.

“Not appropriate as far as we can see. ”

“If a separate body is set up it would

manage its own budget but would be answerable to

the Commission –the ecolabel is

unlikely to become self-financing for

sometime (if ever) so the Commission

will continue to invest in the

scheme.”

7 e) Should there be a separate legal entity to manage the financial resources of the scheme?

51


• Most respondents indicate that this is impossible, or at least very difficult, to answer.

“Impossible to give an answer. Maybe we

can get a rough estimate by looking at

the Nordic Swan and multiplying it.”

“Several millions of euros. A back-of-the-envelope calculation suggests that costs

associated with preparing and

agreeing 6 criteria sets is of the order of

1 million euros (includes stakeholder

time etc).”

7 f) How much money do you think is necessary on a yearly basis to properly manage and grow the scheme?

impossible to answerestimate givenno response


4. Conclusions

53


Generic conclusions

• Overall, most respondents believe that a continuation of the EU Eco-label scheme, under its current set-up, is desirable.

• Most respondents also indicate that several (relatively minor) changes could be made to improve the running of the scheme.

• Only a few respondents believe that the establishment of an independent body, with oversight from the Commission and stakeholders, would be the preferred way forward.

54


Some contradictions in the results

• More product groups but• No more resources• No limit on the number of criteria (see slide 21)• No obligation on Member States to develop criteria

(see slide 31)• More marketing efforts but

• No more resources• No obligation on Member States to promote the

scheme (slide 24)

55


Some contradictions in the results

• More streamlined criteria development and decision making procedures, but

• No limit on the number of criteria (see slide 21)• Difficult to reduce the time for criteria development

(see slide 29)• Fast track procedure circumscribed with demands

(see slide 30)• Regulatory Committee and Inter Service

Consultation will remain (see slide 35)• Outsourcing is not seen as a solution (see slides

41 and 42)

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