Introduction
1. The Government welcomes the Select Committee's report. It comes at a timely point in the development of a policy area which has moved forward quickly over the last year or so.
2. Until last year much of the policy focus on this subject, in this country and at EU level, had concerned itself with ecolabelling (i.e. voluntary award schemes for "greener" products). This was a focus on a single means, which sometimes distracted attention from the policy end. But there is now a wider appreciation of the bigger picture, in which it is recognised that (a) progress towards more sustainable goods and services is a crucial element in the policy aim of achieving sustainable development; (b) good information for purchasers is one of many tools that is needed; and (c) ecolabelling is one form of information which can sometimes help. The challenge is now seen as the joining up of a much wider range of approaches, able to deliver a substantial contribution to reducing key environmental impacts.
3. Towards the end of last year, and not long before the Select Committee's inquiry got under way, the Government began consulting on this new emphasis. The DETR paper Consumer Products and the Environment reviewed earlier developments and offered some new thinking about a more integrated approach. Since the Select Committee gathered its evidence, there have been two main developments which have helped inform this Government response. Firstly, there is the collection of views from the organisations (about 100) which responded to the ideas and options in the DETR consultation paper. Secondly, there has been the consideration of the whole theme of "Integrated Product Policy" (IPP) by EU Environment Ministers at their Informal Council meeting in May 1999. (Sources of further information on these and other matters referred to in this response are given below in terms of locations on the Internet. Copies of documents are also available from DETR, Environment Business & Consumers Division, 123 Victoria Street, London SWIE 6DE, telephone 020 7944 3167.)
4. Over the coming year, there are two other factors which will influence the progress that is made. At a national level the new Advisory Committee on Consumer Products and the Environment, which has now been appointed, will begin its work of recommending priorities and actions within the UK market. At EU level, the European Commission is due this autumn to produce a Green Paper on how to take forward the IPP initiative on a wider front.
5. This response is therefore set in a context which has already changed and can be expected to develop further over the next couple of years. It is helpful that the Select Committee's recommendations deal with issues which will need to be addressed on that kind of timescale. The following detailed responses focus on the action which is already under way and the additional steps the Government will take or accepts it will need to consider further.
Consumer awareness and education
Recommendation (a):
We believe that the "Are You Doing Your Bit?" campaign is inadequate in scale, coverage and public profile. We urge that it be given substantially increased resources and political backing to start tackling the major problems of public understanding of environmental issues and, critically, the impact of people's actions upon those environmental problems. Further, we recommend that the Government monitor the effectiveness of this campaign by setting a target, in consultation with consumer groups such as the National Consumer Council, for increasing the percentage of consumers who opt for "greener" products. (Paragraph 9)6. The resources devoted to the Are You Doing Your Bit? campaign have been increased significantly. The budget for its first two years, 1997/99, was £3.7 million. This is being raised to £7 million in the current financial year and £9 million in each of the next two. The Government believes that this will address the problems of scale, coverage, and public profile identified by the Committee.
7. The Government agrees that people's understanding of environmental issues, and how their actions impact on the environment, is fundamental to building a more sustainable economy. The Are You Doing Your Bit? campaign therefore sets out to raise awareness of sustainable development issues by showing the public how simple actions can have a major influence on their local and global environment.
8. At present the campaign focuses on the issues of climate change and home energy use; transport and its links to air quality and health; waste; and water. The effect of the campaign on levels of awareness, and as an influence over people's actions in these areas, will be carefully monitored.
9. At this stage the campaign does not deal directly with consumer products. This is partly because of the difficulties which the Select Committee itself has identified - the lack of reliable information in the market about genuinely "greener" product choices, and the confusing background noise generated by unhelpful claims and logos (issues which are addressed later in this response). A first step now being considered is to promote advice to consumers on "what to look out for in green product claims" - specific guidance on what kind of information is reliable and useful; how to spot vague, marginal or misleading claims; and what consumers can do to challenge and debunk claims and symbols which tell them nothing.
10. The Government expects to cover consumer product issues under the Are You Doing Your Bit? campaign once the ground has been better cleared. As with the current elements of the campaign, this would certainly involve proper monitoring and measures of effectiveness in influencing public awareness and actions.
Recommendation (b):
We urge local authorities to pursue consumer education programmes on environmental matters (within the context of Local Agenda 21) to complement the action which we expect central Government to take. (Paragraph 10)11. The Government agrees that local authorities have an important role to play in informing consumers about environmental issues. In January 1998, the DETR and the Local Government Association jointly issued Sustainable local communities for the 21st century, which contained guidance stressing the importance of education and awareness, and the potential for local authorities to take a lead in promoting more sustainable awareness and actions under Local Agenda 21. Recent survey data indicated that over 80% of local authority respondents had held awareness-raising events in relation to sustainability issues and 65% had secured local media coverage for these activities.
12. Concerns have been raised, by the National Consumer Council and others, that people are confused by environmental messages being presented under too many different campaign banners. The Government is therefore encouraging authorities to reinforce the Are You Doing Your Bit? campaign brand and messages in their local activity.
Policy framework
Recommendation (c):
To date, the Government has failed to provide the necessary leadership in attempts to reduce the environmental impact of consumer products. We believe that a coherent framework of policy measures must be put in place to encourage more environmentally responsible actions from consumers, retailers and manufacturers. (Paragraph 17)13. Until quite recently, in this country and at EU level, disproportionate policy attention was being focused on a single voluntary instrument for promoting improved products, the EU ecolabelling scheme. However, as noted in the introduction above, things have moved on in a positive way. Since 1997 the Government has established a more strategic policy approach at a national level, and has actively promoted this view at EU level.
14. Within the UK, the Government initially set out views on developing more sustainable goods and services in its consultation paper, Sustainable Business (March 1998). This thinking was developed in more detail in the further consultation paper, Consumer Products and the Environment (October 1998). The Government's strategy for sustainable development, A Better Quality of Life (May 1999), has now set out a high-level vision for achieving a more sustainable economy and society, in which the sustainability of goods and services is a key feature. The strategy envisages a range of measures, including better information for consumers, actions to raise awareness, promotion of best practice, support for research and innovation, and where necessary the use of minimum standards, regulatory and fiscal instruments.
15. At EU level, the Government has actively encouraged the development of a similar strategic view about consumer goods and services. The UK Presidency held an orientation debate in the Environment Council (June 1998) to help draw out the need for a more integrated approach. This was followed up in workshops and meetings with the European Commission, member states and stakeholder groups, leading to the important Informal Council debate on Integrated Product Policy in Weimar (May 1999). A strong consensus has now been formed to address the key environmental impacts of consumer goods and services in a more systematic and structured way, calling on a wider range of policy and market instruments.
16. The Government now plans to build on these advances in strategic thinking. It expects that the new Advisory Committee on Consumer Products and the Environment will make an active contribution, with practical views on priorities for future action and the most effective choice of measures.
Ecolabelling schemes
Recommendation (d):
In the absence of a credible EU scheme, and in line with our predecessor Committee's recommendation in 1991, we believe that the UK Government should develop a national ecolabelling scheme. The scheme should be publicly funded to ensure that the cost of products does not increase and the label achieves maximum take-up. (Paragraph 20)Recommendation (e):
We recommend that the national ecolabelling scheme should include a generic label based upon the whole life-cycle of a product. Given the need for prompt action in this area, we urge that such a scheme be launched within the lifetime of this Parliament. (Paragraph 22)Recommendation (f):
In addition to introducing a generic ecolabelling scheme, we recommend that the new Government advisory panel should consider which product areas would be suitable for labelling according to specific product attributes or environmental issues. Such an approach will only be appropriate in a limited number of instances where the issue, or the need for information, is clear-cut and straightforward. (Paragraph 28)17. The Government believes that environmental labelling or award schemes can have a useful role in stimulating the market for products which are less damaging to the environment. The right environmental information - used in conjunction with other measures which suit the particular product sector - can bring benefits all along the supply chain. Consumers are given the information they need to compare products and make a "greener" choice, producers and retailers can gain a commercial advantage from bringing better products to the market, and there is an overall environmental gain through lower consumption of other products which are more harmful to the environment.
18. The Government initiated a debate about labelling issues in its Consumer Products consultation paper at the end of last year. This discussed the factors which can shape the best approach to product information - factors which range from the size and complexity of the product's environmental impact, through to the size of purchase and the level of consumer awareness about the environmental considerations involved. For some products, a "multi-criteria" approach, which tries to address several impacts across the life cycle, will be the most appropriate. For others, where an entire class of products has an acknowledged environmental advantage, or where a single environmental issue stands out, a simpler, more targeted labelling measure may be more effective. The Government believes that any new national initiative should have the flexibility to embrace both types of approach, to ensure that the right information measure for the job can be selected in each product sector.
19. Whatever the information type selected, the Government intends to look carefully at how in practice a new scheme could be introduced effectively in the UK market. It shares the Select Committee's view, as did many respondents to the consultation paper, that there are some essential ingredients for achieving a successful new voluntary labelling scheme, including the right selection of product areas, the need for a clear and recognisable message, and consumer confidence and credibility. On top of that, and before any significant resources are committed, there needs to be a good business case that a new scheme could actually achieve sufficient take-up and presence in the national market to be economically viable and environmentally worthwhile. The responses to the consultation paper have not been particularly encouraging on this point - a summary can be found on the DETR website.
20. As a first step, the Government is inviting further ideas, from respondents who expressed some interest, for initiatives on labelling or awards which could operate at a national level. The DETR will commission feasibility studies on the practical lessons from schemes which have had some success in different markets. It will take the views of the new Advisory Committee on the results of these studies, and on the possibility of some market testing in selected product areas.
Green Claims
Recommendation (g):
We recommend that, as a matter of priority, the Government should provide the Green Claims Code and any successor codes with statutory backing. (Paragraph 34)Recommendation (h):
We are disappointed that no real progress has been made on the issue of fair trading as it relates to green claims, despite widespread acceptance of the problem. In his evidence to us, the Minister assured us that there was no disagreement between the Department of the Environment, Transport and the Regions and the Department of Trade and Industry on this matter. We welcome this statement but emphasise that action should be taken within the lifetime of this Parliament and must precede the introduction of a national ecolabelling scheme. (Paragraph 35)21. The Government agrees with the Select Committee that the standard of information given to consumers about the environmental performance of products needs to be improved. In particular, the problem of misleading green claims has persisted for too long. It represents a missed opportunity both for the environment and for fair competition in the market. If an effective solution can be found, there will be all-round benefits - it will help responsible businesses, encourage more efficient competition, enable consumers to exercise informed choice and promote sustainable development.
22. As a first step, early in 1998, the Government issued the Green Claims Code, in the form of voluntary guidance. It has since commissioned the National Consumer Council (NCC) to survey the market over the first full year of the Code's operation, to see how effective the guidance has been and to identify the main problem areas. The Government will use the NCC's report to inform further action.
23. Since the Select Committee held its inquiry, the draft international standard on environmental declarations, ISO 14021, has proceeded to a final vote and is likely to be formally adopted before the autumn. In addition, the European Commission (DG XXIV) has recently begun consultation on ways of improving the quality of green claims across the single market. The main possibilities identified include the use of the new ISO standard, of interpretative guidance, and of the EU regulatory framework on misleading advertising.
24. With regard to statutory backing at a national level, the Government made clear when it launched the Green Claims Code that it wanted to ensure that legislation in this area was indeed effective in deterring misleading claims. The Government has now issued the White Paper, Modern Markets: Confident Consumers (July 1999), which addresses the issue of green claims in the wider context of empowering consumers to exercise well-informed choice. To follow this up, the DTI and the DETR will work with the Office of Fair Trading and the trading standards service to see whether the Director General of Fair Trading's powers under the Control of Misleading Advertising Regulations can be used more effectively to combat misleading on-pack claims, especially green claims. As the White Paper makes clear, however, if these and the other developments mentioned above do not look like succeeding, the Government will need to consider whether further regulatory action would be appropriate.
Market Transformation
Recommendation (i):
We believe that an ambitious but focused "market transformation" approach should be capable of achieving "across-the-board" improvement in the environmental performance of particular products. (Paragraph 38)25. The Government agrees that the "market transformation" approach has great potential for promoting environmental improvement in priority product sectors. The examples of cars, lighting and domestic appliances have shown how valuable contributions to climate change targets can be advanced using this approach. There is certainly scope to apply similar techniques in other product sectors, particularly those where there is one predominant environmental issue to be addressed.
Recommendation (j):
We recommend that the "life-cycle" approach be adopted when defining the specifics of "market transformation" measures, so as to ensure that environmental gains in one area are not cancelled out by losses in another.(Paragraph 40)26. The Government agrees that policies for goods and services need to be based on an understanding of environmental impacts across the whole of the life cycle. Where there are a few main environmental impacts associated with a product, these can be addressed as part of a broad market transformation programme, such as those for washing machines and dishwashers (which deal with product performance on both energy and water consumption). Alternatively, some impacts may be addressed more directly through specific measures or standards (as with the coolant substances used in refrigerators; or the sulphur content of fuels; or the emissions of hydrocarbons, carbon monoxide and oxides of nitrogen from cars).
Recommendation (k):
We strongly urge the Government to assess the likely effects of "market transformation" measures on the less well-off in society prior to their introduction and, where necessary, to develop complementary measures to ensure that such people are not disadvantaged. (Paragraph 41)27. The Government is keen to ensure that measures to promote more sustainable goods and services should not disadvantage low-income households. For some types of product, where resource consumption in use is a big feature, more efficient products represent a benefit to all consumers in terms of lower life-time costs. And it is by no means axiomatic that a more fuel-efficient product has a higher up-front cost - there is wide variety in the car market, for example; and, in the case of fridges and freezers, research in 1997 found no correlation between purchase price and energy efficiency.
28. The Government is particularly interested in "greener product" initiatives where low-income households can get the dual benefit of better goods or services and better value for money. We have worked with the Energy Saving Trust on trade-in schemes for fridges, for example, and will pursue other schemes which can produce all-round benefits of this kind.
Green procurement
Recommendation (l):
We recommend that the Government examine what additional steps can be taken to enable "green" procurement practices to be adopted within central and local government. Clear guidance should be provided to authorities on this matter. (Paragraph 42)29. Central and local government are required to operate within a regulatory and policy framework for public procurement which flows from directives agreed at EU level. For central government, these allow environmental considerations to be included in specifications for goods and services, as part of the objective of securing best value for money through "the optimum combination of whole life cost and quality to meet the customer's requirement". The European Commission is currently working on an interpretative document under the procurement directives, to set out how sustainable development issues can be taken into account within the existing framework. When that new guidance is available, the Government will see that it is disseminated widely to purchasers throughout the public sector.
30. EU Environment Ministers, when they met in the Informal Council in Weimar (May 1999) to discuss Integrated Product Policy, considered the scope for taking environmental aspects more systematically into account in public procurement procedures; and the possibility, if necessary, of amending the EU procurement directives to widen the scope for action. This issue is likely to feature in the Commission's follow-up work on IPP and in the process for integration of sustainable development in the work of the Internal Market Council.
31. The Government has been active, meanwhile, in producing guidance for use at national level. The DETR and the Treasury issued a joint note on Environmental Issues in Purchasing for public sector purchasing officers (April 1999). The DETR has also issued a Green Guide for Buyers. (December 1997 and February 1998), which covers policy and practice to help buyers specify environmentally preferable goods and services. Other guidance for procurement officers includes Towards more sustainable construction: green guide for managers on the government estate (April 1999) and a Guide for choosing environmentally preferable IT equipment (June 1998). Further details can be found on the DETR website.
32. The Government's plans for greening its operations, including procurement, have been set out in the Green Ministers' first annual report (July 1999). In the local government sector, the new "best value" regime will be implemented from April 2000. This will enable local authorities to reflect environmental considerations in all aspects of service delivery, through their incorporation in performance plans and targets.
Services
Recommendation (m):
We urge the Government to monitor the results of research into the environmental gains which could be achieved by moving from a purchase towards a leasing-based economy, with a view to assisting its development if appropriate. (Paragraph 45)33. The Government believes there are potential gains for the environment in moving away from the direct consumption of certain goods and towards the use of services which meet the same need. It is keen to capture these gains, and will monitor and contribute to research in this area as it develops.
34. At the Informal Council in Weimar, EU Environment Ministers and the European Commission agreed to consider the opportunities emerging in the service sector, as part of the development and implementation of product-related environmental policy. This issue is likely to be developed further in the Green Paper on Integrated Product Policy currently being prepared by the Commission. It is also being addressed in the proposed revision of the regulation governing the EU ecolabelling scheme, which now includes a provision to extend the ecolabel to services as well as goods.
Integrated Product Policy (IPP)
Recommendation (n):
We believe that Integrated Product Policy has potential advantages over the "traditional" approaches to environmental policy. However, it is too early to judge whether those potential advantages will be converted into real environmental gains. The success of IPP will depend upon a number of factors, not least common-sense application and political backing throughout the EU. (Paragraph 48)35. The Government welcomes the Select Committee's general support for the IPP approach. The impacts associated with consumer products are an increasingly important challenge within the sustainable development agenda, as the scale of consumption and the diffusion of impact sources grow. IPP offers a new policy framework to help address this challenge in a practical and effective way.
36. The Government agrees that the success of the approach will depend on good sense in its implementation and on clear political backing and leadership at EU level. It therefore particularly welcomes the positive conclusions reached at the Informal Environment Council in Weimar. The EU Environment Ministers agreed on a pragmatic set of principles for taking IPP forward, and gave strong support for the next formal step, a European Commission Green Paper to be issued before the end of 1999. They also suggested some initial actions that could be taken now or included in the Green Paper.
Recommendation (o):
We recommend that the full potential of ecological taxation reform within the context of IPP be exploited. Such reform, designed to encourage the most appropriate use of products and services, would give the strongest possible signal to consumers. (Paragraph 53)37. The Government is committed to exploring the scope for using economic instruments, such as taxes and charges, to deliver a more dynamic economy and a cleaner environment. The 1999 Budget included the biggest ever package of tax reforms to protect the environment, as part of the Government's policy to shift, over time, taxes from "goods" such as employment towards "bads" such as pollution. We recognise the strong signals which such measures can send to producers and consumers alike, and will consider using them wherever they are likely to be an effective tool within an integrated programme of product-related measures.
Recommendation (p):
We believe that target setting and the monitoring of progress towards those targets must form a critical component of IPP. Only in this way can the success of individual policies be assessed and failures learnt from. (Paragraph 54)38. One of the attractions of the IPP approach is its potential for better delivery of high-level objectives on sustainable development, by making the link between these strategic objectives (for example, on reducing CO2 emissions) and the particular product markets where there is scope to make a significant contribution. The Government therefore believes that key principles of IPP should be a close integration with sustainable development policies and a direct link with quantifiable targets, where they exist. We have helped to build the framework for this in the set of sustainable development indicators published in A Better Quality of Life, which help to measure the overall trends in consumption, waste production, and environmental quality which Government policy seeks to influence.
39. The establishment of improvement targets, and frequent reviews of progress, are already an integral part of the EU market transformation programme. Our aim is to incorporate these principles at the outset when strategies are extended to other product groups.
Recommendation (q):
We recommend that the Government integrate the aim of reducing total resource consumption into its policies for consumer products. Further, we urge the Government to take a lead within the EU in pressing for this aim to be explicitly recognised by the European Commission as it develops Integrated Product Policy. (Paragraph 55)40. Reducing resource consumption is very much a part of the overall goal of IPP, which is about reducing the environmental impacts of products throughout their life. The Informal Council in Weimar agreed on "the need to lower the consumption of resources by ... economies in general and especially by products" - and this will continue to be at the heart of the future development of IPP.
41. In A Better Quality of Life the Government recognised the importance of reducing total resource consumption as a necessary part of sustainable development. One of the four main aims of the strategy is the prudent use of natural resources; and the new headline indicator on waste will help to show the progress that is made.
Life-cycle assessment
Recommendation (r):
It is our conclusion that life-cycle analysis should be used with an understanding that it is only a means to an end: that end being the identification of the priorities for action towards more sustainable patterns of consumption. As such, it may be appropriate to use simplified versions of the approach for products where the environmental characteristics or implications are clear-cut. (Paragraph 57)42. The Government shares the Select Committee's view that life-cycle analysis must be used with common sense. This view was also supported by many of the respondents to the Consumer Products and the Environment consultation paper. There has in fact been some general movement away from regarding this field as a precise science of "analysis", which it can rarely be; and towards a form of life-cycle "assessment" or life-cycle "thinking", which serves to inform policy decisions and help identify priorities for action. For example, the proposed new version of the EU regulation on ecolabelling now talks in terms of life-cycle "considerations".
43. The Government agrees that there should be a wider understanding of this approach, so that it is more accessible and attractive to business. It has commissioned a new guide for business, which will give an overview of LCA and how it can be used by manufacturing and service companies to reduce costs and minimise environmental impacts. The guide will also explain the benefit of simplified, streamlined life-cycle assessments and the circumstances in which they might be more appropriate. It will be published later this year as part of the Environmental Technology Best Practice Programme series on cleaner technology.
Recommendation (s):
We recommend that, wherever possible, details of life-cycle assessments be made publicly available. (Paragraph 58)44. The Government agrees that assessments of product impacts should be disseminated wherever possible. But there is naturally a distinction here between (a) LCAs carried out privately by individual manufacturers to inform their internal operations, which may include commercially sensitive information, and (b) those used to gauge the characteristic impacts of a product type (e.g. for public schemes such as the EU ecolabel) where such considerations do not apply.
45. There are clear benefits from making these latter, product "type" assessments more widely available - and indeed the European Commission is making good progress in developing its website to include the results of LCAs carried out for the product groups covered by the EU ecolabelling scheme. Until then, summaries of LCA findings can be found on the European Commission website.
Social and ethical factors
Recommendation (t):
We commend the inclusion of a note on "social and ethical dimensions" in the Government's consultation paper on consumer products and the environment. We further hope that these issues will be directly addressed within the context of policies on consumer products. (Paragraph 59)46. The Government set out in A Better Quality of Life its strategy for integrating all aspects of sustainable development. Although policies on consumer products are concentrating for the present on more effective ways to tackle the environmental impacts of goods and services, the Government expects that, as these approaches develop and gain acceptance, many of the ideas and principles could helpfully be drawn through into other aspects of sustainable development.
47. In seeking to advance the broader aspects of sustainable development, the Government is now sponsoring work by Forum for the Future and the British Standards Institution on the evolution of "sustainability management systems" for business, building on the existing framework for environmental management systems. This work could have a positive influence, in due course, over the way that goods and services are provided.
The new Advisory Committee
Recommendation (u):
We recommend that the level of funding for the Government's advisory panel be reviewed. This area of policy is in need of new impetus and this is unlikely to occur if the panel is not adequately resourced in its initial stages. (Paragraph 62)48. The Government agrees with the Select Committee that the new Advisory Committee should have the resources to do its job properly. As it will not have any executive functions, and its members will be unpaid, the Advisory Committee will not have a dedicated budget of its own (the figure of £20,000 which has been referred to is for incidental costs such as travel and subsistence). But it will have secretariat and policy support provided from within the Environment, Business and Consumers Division in DETR. More importantly, as the Committee's role will be to help steer policy initiatives and research in this area, it will be able to recommend how the relevant DETR programme and research budgets should be applied.
Recommendation (v):
We believe that the Government's advisory panel should not be given the task of dealing with "green claims". The panel should have a more strategic role and "green claims" are better dealt with through the mechanisms we have detailed in other recommendations. (Paragraph 63)49. The Government agrees that the Advisory Committee's role should be a strategic one. In the area of "green claims", the Government agrees with the Select Committee's view, which was shared by respondents to the Consumer Products consultation paper, that the Committee should not have a role in adjudicating on individual claims. Its initial terms of reference make clear that its role in this area will be to advise on best practice in providing environmental information to consumers, and on measures for promoting best practice in the market.
Recommendation (w):
We recommend that the chair of the Government's advisory panel is held alternately by industry and by consumer / environment representatives, to ensure that it commands confidence from all parties. (Paragraph 64)50. The Government believes that an important strength of the Advisory Committee will be in bringing together expertise covering all phases in the life-cycle of consumer products. To that end, appointments to the Committee are being made on the basis of personal expertise and experience in the different stakeholder areas, rather than direct representation from particular organisations. The initial appointments, including those to the positions of Chair and Deputy Chair, reflect the balance of business, consumer and environmental backgrounds which the Government agrees is important in establishing general confidence. The Select Committee's recommendation about future appointments is noted.
Published 25 August 1999
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