Products and the environment: an integrated approach to policy

European EnvironmentEur. Env. 9, 174–185 (1999)

PRODUCTS AND THEENVIRONMENT: ANINTEGRATED APPROACHTO POLICY

Frans Berkhout1* and Derek Smith2

1SPRU (Science and Technology Policy Research), University of Sussex, UK2Ernst & Young, London, UK

The European Commission has recentlybegun a process for considering anintegrated product policy (IPP), defined aspublic policy which explicitly aims to modifyand improve the environmental performanceof product systems. Three main factors havecombined to create a need for more effectivepolicies on products and the environment.First, many traditional process-orientedpolicies have been successful in reducingemissions from industrial productionactivities, while the environmental impactsof consumption are being increasinglyrecognized by governments and consumersalike. Second, a number of new analyticalapproaches (life cycle approaches) forunderstanding the environmental burdensof product systems have been developedand are being applied in policy decisions.Third, many existing product-orientedenvironmental polices are believed to havebeen ineffective.

CCC 0961-0405/99/050174–12 $17.50Copyright ? 1999 John Wiley & Sons, Ltd and ERP Environment.

An EU IPP will build on policy initiativesalready in train at the EU member statelevel, and on developments within firms toimprove the environmental profile of goodsand services. This paper reviewsproduct-related policy in member states,together with an assessment of productenvironmental management in five industrialsectors: chemicals; pulp and paper; food;electronic goods and consumer goods. Aframework for an IPP composed of five‘building blocks’, clusters of policies with acommon objective, is described. Thesebuilding blocks include policies related toconsumption waste management, greenproduct innovation, market creation forgreen products, environmental informationand the allocation of responsibility forproduct management. Some policy makersargue that we may be witnessing thebeginning of a general transition away fromprocess-oriented policies, and towardsproduct- and consumption-oriented policies.The paper illustrates some basic problemsfaced by an IPP, and proposes anincremental, phased approach to policydevelopment in the EU. Copyright ? 1999John Wiley & Sons, Ltd and ERPEnvironment.

*Correspondence to: Frans Berkhout, University of Sussex, Falmer,Brighton BN1 9RF, UK.Paper presented at the Advances in European EnvironmentalPolicy Conference, London School of Economics, London,15 September 1998. This paper is based on a report, IntegratedProduct Policy, produced for DGXI (Environment, Nuclear Safetyand Civil Protection) by Ernst & Young and SPRU in March 1998.

PRODUCTS AND THE ENVIRONMENT

INTRODUCTION

I ntegrated product policy is an emergent fieldof environmental policy, receiving increasingattention in several EU member states (the

Netherlands, Denmark and the United Kingdom),in the European Commission and in internationalorganizations (the OECD and the UN Commis-sion on Sustainable Development). IPP addressesthe whole life cycle of a product, and seeks toavoid shifting environmental problems from onephase of a product life cycle to another. A numberof factors have combined to create a need for aproduct-focused environmental policy.

First, there has been a growing awareness thatthe traditional focus on production processes mayno longer be appropriate in environmental policyand regulation. While industrial and energyproduction remains an important source of pol-lution and waste, the relative importance ofconsumption-related emissions and wastes hasbeen rising over the past two decades. Forinstance, an inventory of volatile organic com-pound (VOC) emissions in the Netherlands inthe late 1980s revealed that three-quarters ofemissions were consumption related, in particularin the application of paints and during vehiclerefuelling. Emission sources of several keygaseous pollutants, such as nitrogen dioxide andcarbon monoxide, arise primarily from the useof vehicles. The management of consumption-related solid wastes has also been an importantpolitical issue in many EU states since the 1980s.Moreover, in many sectors industrial pollutioncontrol measures may be reaching the limits ofcost-effectiveness. An imbalance may thereforeexist between the great efforts required to achievesmall incremental reductions in point source emis-sions, while the large-scale burdens associatedwith the consumption of finished or semi-finishedproducts are poorly controlled.

Second, as these practical policy issuesemerged, a number of new concepts were beingdeveloped that describe an integrated approach toanalysing product systems stretching from pro-duction through consumption. These ‘life cycleapproaches’ take explicitly into account the wholeproduct system from cradle to grave, includingthe extraction and processing of raw materials,the manufacture of products, their distribution,use and the management of the waste residuals

Copyright ? 1999 John Wiley & Sons, Ltd and ERP Environment.

along the product life cycle. Other importantconcepts have also emerged, such as eco-efficiency, which stress the importance of deliver-ing final goods and services with a reducedenvironmental burden. The framing of industrialenvironmental management and policy has there-fore been undergoing a slow transformation so asto become more holistic.

Policy salience and new analytical approacheshave brought the impact of products on theenvironment under greater scrutiny. There is awidely held perception that existing product-oriented environmental policies have had limitedsuccess because they have not fitted well intoprevailing environmental and technology policyregimes. Labelling schemes such as the EUEco-label have faced difficulties in modifying con-sumer demand and stimulating product inno-vation (see e.g. Mitchell, 1995; Morgan, 1996). Amore integrated approach, seeking to influenceactors across the life cycle of a product, not justthe final consumer, is now regarded as more likelyto achieve success. Instruments will be chosen towork together to achieve well defined environ-mental and competitiveness goals.

In this paper we present a framework for aEuropean IPP. We begin with an analysis of someof the difficulties of moving from an environ-mental policy predominantly concerned withindustrial processes to one that is mainly con-cerned with products and services. We thenpresent briefly results of a European survey ofpolicymakers, industrial producers and consumerorganizations on the general issue of products andthe environment. This leads to a proposal for anIPP framework composed of five ‘building blocks’,packages of policies focused around a commonobjective. We then present some recommenda-tions for the development of a European policyregime on products and the environment. Theresults are based on a major research studyconducted on behalf of the Directorate Generalfor Environment, Nuclear Safety and Civil Protec-tion (DGXI) of the European Commission whichreported in March 1998 (DGXI, 1998).

PRODUCTS AND ENVIRONMENTALPOLICYIn the 1990s, environmental policy makers andregulators in many industrialized countries were

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faced with a number of new questions: What arethe environmental impacts of products? How can‘green’ products be distinguished? What leversexist to influence the complex and integratedsystems of technologies, actors and practices thatproduce and consume products? What instru-ments will be effective? How can new responsi-bilities for products’ environmental impacts becreated? How effective can these policies be inchanging patterns of production and consumptionand making them more sustainable?

A transition towards product-oriented policiesfaces practical, political and legal obstacles. First isthe recognition that products are far from being akey focus for environmental policy in EU or widerinternational policy-making circles. There is agreat need for a clear framework for an integratedproduct-oriented environmental policy that canbe widely communicated and applied.

But a number of other deep-seated problemsalso exist. These are related to the issue ofconsumer sovereignty, the diversity of productsof the market, the diversity of actors engaged inproducing and consuming products, potential bar-riers to competition and free trade of productpolicies and the problem of reconciling differingsocial attitudes to environmental risks posed byproducts.

(i) Consumer sovereignty. The right to choosewhat to consume can be limited in moderndemocracies only where scientific and politi-cal agreement exists that a given productcauses harm, as with health and safetylegislation. Limiting the right to consumeproducts on environmental grounds is poss-ible when these impacts are widely acceptedas being significant (ozone-depleting sub-stances, for instance). It is far more diffi-cult where no social consensus exists.Governments traditionally committed tothe growth of consumption are wary ofintervening directly in the right to consume.

(ii) Product diversity. While sophisticated regis-tration, testing and certification schemesexist for many products, there are too manyproducts for public authorities to monitorand manage directly through policy, orthrough standard setting. The total numberof products available in European marketsis in the millions. Governments are not in


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a position to analyse the environmentalimpacts and to prescribe environmentalperformance criteria for each of these.

(iii) Stakeholder diversity. Many actors areinvolved in the production and consump-tion of products (including producers alonga supply chain, retailers, consumers, wastemanagers, lenders and insurers). The defi-nition of responsibility for environmentalimpacts along a product system is frag-mented, overlapping and shifting. Conceptssuch as product stewardship, extended pro-ducer responsibility and shared producerresponsibility are aimed at establishing howthe boundaries of responsibility of industryare being reshaped. Consumer buying andconsumption behaviour is also critical indetermining the environmental impact ofmany products.

(iv) Global product systems. Product systems areglobal in scope. Their resource commit-ments and environmental impacts crossnational and regional boundaries. Thereare tensions between trade rules that pro-hibit differential treatment of goods that aresimilar, and product policies that discrimi-nate between similar products on thebasis of process or waste managementmethods.

(v) Risk and diversity. The interactions betweenproduct systems and the environment arenumerous, complex and often poorly under-stood. Unlike an industrial productionfacility with a known site and characteristicsthat can be measured, products are mobile,and the characteristics of the lifecycle of agiven product can typically only be esti-mated. Even if the life cycle of an ‘average’product can be modelled a much wider setof environmental burdens typically need tobe considered than would be the case for anindustrial facility. Consequentially the prob-lem of appraising and valuing differentenvironmental burdens (ranging from thedepletion of fossil fuels to the risks ofeco-toxicity for instance) relative to eachother can also be expected to be greater.The social aspects of building a picture ofenvironmental burdens therefore becomesmore pronounced in the environmentalappraisal of products.

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These problems need to be considered in thedevelopment of product-oriented environmentalpolicies. They imply a transition from interveningdirectly in the frequently local environmentalimpacts of single sites with well known techno-logical and environmental characteristics operatedby single industrial firms, to influencing indirectlythe imprecisely known frequently regional andglobal environmental impacts of globally spreadproduct systems involving many stakeholdersdistributed across many countries. The fullimplications of this transition are enormous.

The transition from process- to product-focused policy is set out in Figure 1.

FRAMING AN IPP: POLICY-MAKINGEXPERIENCEProduct policy changes the focus, extends thescope and alters the means available to environ-mental policy. Product policy cannot be devisedand implemented in the same way as process-oriented policies. The focus of environmentalpolicy will shift, but so will the policy-making and


implementation process. A wider network ofpartnerships between national and internationalstakeholders must be created, with new rights andresponsibilities allocated to public authorities,producers and consumers. The policy processneeds to become more transparent, open, inter-active and co-operative, placing greater stress onvoluntary actions and market instruments, withpublic authorities taking the role more of facilita-tors and arbitrators, rather than merely enforcersof rules laid down in legislation. The role forconsumer – citizens in policy-making also needsto be reconsidered. Product policies will need tobe inherently ‘democratic’ and deliberative.

This new role is already recognizable inproduct-oriented environmental policies in Europeand the OECD during the early 1990s. Productpolicies have signalled a shift towards ‘softer’policies, stressing joint action (shared andextended producer responsibility), voluntaryactions (German and Swedish ‘closed loop’ legis-lation, and priority waste stream policies atnational and European level), technology pro-motion (Netherlands and Sweden), market

Figure 1. The transition from process-oriented to product-oriented environmental policy.

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instruments (ecotaxes in Belgium), product stan-dards (problem-oriented activities in Dutch prod-uct policy and chemicals control legislation inSweden) and information instruments (stressed inthe Netherlands and Austria, but a central featurein the main EU product policy instrument, the EUEco-label). The role of direct regulation (bans andtake-back obligations), though stressed by somecommentators, appears to be more limited(Oosterhuis et al., 1996).

A three level model of product policy in the EUwas identified (see Figure 2).

(i) At the European level no explicit policyframework related to products and theenvironment yet exists, although there isan intention to establish a broader policy.Several existing measures (the EU Eco-labeland the Packaging and Packaging WasteDirective) could form elements of aEuropean IPP.

(ii) At the member state level a few stateshave articulated comprehensive policies onproducts and the environment, notably the


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Netherlands and Denmark, with significantpolicy developments also taking place inSweden, Finland and Austria. There has alsobeen much interest in Germany, and morerecently in the UK. Most EU states do nothave explicit product policies. As always inthe emergence of a new field of environ-mental policy, there are leaders, followersand laggards. Nowhere do we see a fullydeveloped and effective IPP, while in muchof Europe little progress has been made inbeginning the process.

(iii) The third level of IPP consists of policyinstruments concerned with products andthe environment. A variety of thesemeasures are already in force in mostEU member states, some originating inCommunity policy.

The most direct experience gained in developingproduct policy has been at the national level.Several important issues and trends emerge froman analysis of these policies. First, two broadtendencies can be identified in the evolution of

Figure 2. Three levels of product policy in the EU.

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product-oriented policies within the EU: an incre-mental approach and a comprehensive approach. Inthe incremental approach, the aim is to set out apolicy framework, and then to develop incremen-tally a portfolio of more product-orientedenvironmental policies. In this approach, productpolicy becomes a new field of policy connectedto, but separated from other fields of policy(industrial pollution control, waste policy, chemi-cals policy and so on). In the comprehensiveapproach, products are seen as the lens throughwhich all environmental policies should eventu-ally be focused. Within this approach, the longer-term aim is to shift the basis of all environmentalpolicy towards a product orientation, in thecontext of securing sustainable production andconsumption. Different national policies reflectthese distinct emphases. For example, Dutchpolicy has chosen the more pragmatic incrementalapproach, while Danish policy has taken a moreradical and comprehensive approach (VROM,1994; Danish EPA, 1997).

Second, at member state level, IPP measureshave tended to develop backwards along theproduct system in a series of stages, graduallybecoming more inclusive in scope and compre-hensive in impact. The first phase of policydevelopment is characterized by policies for


managing visible product-related wastes (packag-ing and other priority waste streams). In thesecond phase, policies that aim to generate andmake accessible environmental information aboutproduct systems (eco-labels, product dossiers andadvice centres) to producers and consumers aredeveloped. In the third phase, policies specificallyaimed at stimulating innovation and marketcreation for green products are introduced. Inthe fourth, and as yet mostly uncharted, phaseproduct policy may operate across the whole lifecycle of products in a coherent, integrated way,shaping eco-efficiency and the environmentalimpact of products. This process of policy devel-opment may be described through a reverse chainmanagement model (see Figure 3). The schema isapplied in developing an evolutionary model forthe development of IPP.

Policy instruments that influence the environ-mental performance of products have been inexistence in EU member states for the last 20years or more. However, the development ofcoherent policy frameworks aimed at products isa much more recent phenomenon, and is still inthe process of emerging. Although evaluation ofimpact is typically one of the aims of these policydevelopments, formal evaluation has not takenplace of these instruments in EU member states.

Figure 3. The reverse chain management model.

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THE ROLES AND EXPERIENCE OFINDUSTRY AND CONSUMERS

European industry has played a leading role indefining many of the issues around products andthe environment. In taking this leading role,industry has responded to market pressures fromconsumers and competitors, and taken advantageof technological and market opportunities. Manyof the firms that have pioneered the adoption oflife cycle approaches have done so with the aim ofbringing more ‘balance’ to public debates aboutthe environmental burdens associated with theproducts they contribute to producing. Industry isalso responding to the increasing responsibilitiesthat are being placed on firms to manage andreduce environmental impacts across product lifecycles (producer responsibility and integratedchain management) through regulations andvoluntary agreements.

The results of interviews with leadingEuropean firms in the chemicals, pulp and paper,food, electronics and consumer durables industriesshow that firms think of themselves as providersof products, rather than services1. These sectorswere chosen as representative of different typesof industry including commodity, intermediategoods and final complex goods producers andretailers. The results of this survey are presentedin concise form in Table 1. Overall, no broadtrend away from the production of productstowards the provision of services can be detectedin EU manufacturing industry. Even forward-thinking firms such as Electrolux are only begin-ning to picture themselves as selling services,rather than units. Nor have we detected a genericshift towards the leasing concept, or other formsof collective goods that have been advocated bysome commentators.

Given the differing technological and marketcontexts in which firms operate, the attitudes andactions taken in managing the environmentalimpacts of product systems vary greatly acrossdifferent sectors, and within them. There is alsolittle clear pattern in specific actions taken.Environmental information is transmitted in avariety of ways, through labels, product dossiersand annual reports, for example. The level of


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involvement in recovery and recycling was lowerthan anticipated. Most firms agree that environ-mental performance plays a limited role in creat-ing new markets for products and services,although there are exceptions in specific niches.Basic ground rules and checklists have been devel-oped for product development and in many firmssome use is made of LCA-based tools. The mostintensive use of these tools in product innovationtends to be among final goods producers whereopportunities for making environmentally signifi-cant changes to product systems are greater.

In general the impact of existing product poli-cies has been minor in the industrial sectorssurveyed. The main impacts detected were frompackaging and take-back regulations in the foodand consumer goods sectors. Industry is in gen-eral suspicious of efforts by policy makers tomanage the environmental performance of prod-ucts. They fear that direct regulations will have animpact on their competitiveness, while not effec-tively improving environmental performance.There is also a widespread resistance to theconcept of extended producer responsibility and apreference for the alternative concept of sharedresponsibility2. The most consistent signal fromindustry is that it is supportive of risk-basedapproaches to reducing the environmental bur-dens associated with consumption. However itargues that this can be effective only if basicenvironmental objectives are clearly articulatedby policy makers, and if a ‘level playing field’exists, within the EU and globally.

Consumers can play an important role in influ-encing the environmental behaviour of manufac-turers, and do greatly influence the environmentalimpacts caused by patterns of consumption. Theconsumer’s influence is exerted through patternsof purchasing, use and product discard. The typesof consumer of particular relevance to the productpolicy context are individuals (acting as privateconsumers), professional or corporate consumers(often in the supply chain of manufacturers)and agencies of government who carry outpublic purchasing. However, a number of factors

1Interviews were conducted with a total of 24 large Europeancompanies: chemicals (four); paper (five); electronics (six); food(five) and consumer goods (four).

2Although extended producer responsibility has previously beenapplied only in specific waste management policies, the Swedishgovernment has recently proposed a generic producer responsi-bility. Under shared responsibility, costs and liability are spreadacross producers (and consumers) as in the UK Producer Responsi-bility Obligations (Packaging Waste) Regulation, 1997.

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combine to create obstacles to environmentallyconscious purchasing, use and product disposalamongst all three classes of consumer. Theseinclude lack of information/knowledge, percep-


tions of cost, legal constraints, additional com-plexity and inertia. The most important factor inall areas is the need for the sensible provision anduse of environmental information.

Table 1. Summary of findings from survey of EU business

Chemicals Pulp and paper Food Electronic goods Consumer goods

Is the output of the sector a‘product’ or ‘service’?

Product (sometechnicalservices)

Product Product Product (andone serviceprovider)

Product (someservices)

Who are the maincustomers?

Intermediateand finalproducers(some finalconsumers)

Intermediateand finalproducers(some finalconsumers)

Retailers andfinal consumers

Private andpublic sectorcustomers andfinal consumers

Final consumer

What product managementactions are firms taking?

ResponsibleCare andProductStewardship

ISO 14000becomingindustrystandard

Mixed picture,some PMSadoption

ISO 14000becomingindustrystandard

Mixed picture,some in-housePMS*

How is environmentalinformation transmitted tostakeholders?

Product datasheets,environmentreports,responses toinquiries

Product datasheets andsomeeco-labels

Contents andpackaginglabelling

Environmentreports,responses toinquiries

Product labels,eco-labels,environmentreport,marketing

What product wastemanagement do firms do?

Minoractivities inpolymers

Plant levelrecycling,recoveryinfrastructurepartner,recycled brands

Packagingwaste recovery

Take-back ofsome items

Pilotingtake-back ofsome items

Do ‘green’ productsrepresent significant newmarkets?

Environmentimportant insome niches

Environmenthas littleimpact in themarket

Environmenthas limitedimpact in somemarkets

Environment haslimited impact

Environmentplays some rolein creating newmarkets

Are life cycleenvironmental burdensconsidered in productinnovation?

Wide use ofLCA-basedtools in finalproductdevelopment

No clearpattern

Environments adriver ofpackagingdesign-adoptionof LCA tools

Some use ofLCA-basedtools

Environment adriver, some useof LCA-basedtools

What is the perceived scopeof firms’ responsibility forproducts environmentalburdens?

Productionphase

Productionphase andsome recycling

Production andpackagingrecycling

Productionphase

Varied – onlyproductionphase to totallife cycle

What is the impact ofexisting product policies?

Minor Minor Yes, packagingdirective

Minor Yes, take-backand energystandards

What are the mainexpectations of futureproduct policies?

Common rulesandenvironmentalobjectives

Paper recoveryinfrastructuredevelopment

Packagingrecyclinginfrastructuredevelopment

Common rulesand sharedresponsibility

Consistentenvironmentalobjectives

*PMS – Product Management System.

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A FRAMEWORK FOR IPP

Against the background of existing literature(Oosterhuis, et al., 1996) and the results fromempirical research for this study, a limited defini-tion of IPP is proposed as a basis for EU policy.By limited we mean that we believe a ‘product’policy should in the first instance be concernedwith products or artefacts, rather than the broadernotion of the services provided by those prod-ucts. The global objective of IPP is to improvethe resource efficiency and reduce the environ-mental impact of the final consumption of goodsand services. A more specific definition of IPPwould be

Public policy that explicitly aims to modify andimprove the environmental performance of productsystems

The key aims of this definition are that IPP relatesto

(i) Products: that is, artefacts rather than ‘ser-vices’. The debate over ‘products’ and ‘ser-vices’ is not yet sufficiently mature forconclusions to be drawn about the environ-mental or other benefits of, a generic shiftfrom products to services. Moreover, the‘sustainable consumption’ concept is not yetwell enough defined to form the basis ofEU policy action. The wider issue of con-sumption is therefore not included in thisdefinition.

(ii) The environment: policies must be explicitlyconcerned with resource efficiency orenvironmental impacts of products. Theintroduction of implicit environmentalimpacts of policies makes it impossible todraw a clear enough boundary betweenwhat is and is not IPP.

(iii) The whole life cycle of the product: policiesmust be ‘integrated’. They must be con-cerned with resource efficiency or environ-mental impacts across more than a singlestage of the product life cycle. Ideally policymeasures would be concerned with reduc-ing the environmental burdens across thelife cycle of a product in a systematic way.Improvement opportunities across the lifecycle would be judged according to theireffectiveness in terms of the final product.


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This limited definition is proposed as a way ofestablishing clarity about the objectives andinstruments of IPP. A strong, coherent and effec-tive EU IPP will depend partly on a definition thatis limited and clear. A new field of policy mustbe defined that is as distinct as possible fromexisting fields of policy. Without this, politicalsupport and targeted actions will be more diffi-cult to achieve. While there is an active debateabout the broader problem of sustainable con-sumption, we do not believe that this conceptcan yet be applied in the development of practi-cal policy (OECD, 1997a, 1997b; Royal Society,1997; Ministry of the Environment (Norway)/IIED, 1998; WBCSD, 1999).

The ‘Building Blocks’ of Integrated ProductPolicy

From an analysis of existing product policies, fivecore packages of measures, or IPP building blocks,are common to all contexts. These policy buildingblocks are made up of specific policy instruments.Taken together specific measures organizedwithin building blocks would form an IPP. Eachbuilding block is a cluster of policies that sharea common objective. The following five IPPbuilding blocks were identified.

(i) Measures aimed at reducing and managingwastes generated by the consumption of products.Waste is broadly defined to include‘dissipative wastes’ (wastes generated in‘using up’ a product) and ‘non-dissipativewastes’ (wastes that may be recoveredand reused or recycled). Measures in thiscategory may currently be classified aschemicals or waste policies.

(ii) Measures to encourage innovation of moreenvironmentally sound products. These willinclude measures aimed at stimulatingresearch and development of technologiesand products and measures to encour-age the environmental management ofproducts.

(iii) Measures to create markets for more environ-mentally sound products. These will bemeasures that encourage the adoption ofenvironmentally friendly products onto themarket, both in the private and publicsectors.

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(iv) Measures for transmitting information up anddown the product chain. These will be measuresthat provide information and encouragegreater transparency about the environ-mental burdens and full environmental costsof product systems. These informational andprice signals will serve to alter customerbehaviour across the product system.

(v) Measures that allocate responsibility for manag-ing the environmental burdens of product sys-tems. These will be measures that allocatelegal and financial liability for product-system environmental burdens. This wouldinclude potential burdens (related to thedesign of the product), and actual burdens(related to the actual use and discarding ofproducts).

A wide variety of measures can be consideredwithin the IPP building blocks, some very productspecific (take-back regulations), others cross-cutting and general (a generic producer responsi-bility policy). All are related in being aimed atimproving the environmental performance ofproduct systems. Effective product policy is likelyto require all these measures and building blocksto be integrated, that is, designed to be mutuallycompatible and reinforcing. For instance, producerresponsibility obligations should be supported byresearch and technology development (RTD)policies that enable firms to respond efficiently.Likewise, RTD policies should be supportedthrough market-creation and information policiesthat encourage the more rapid uptake of new‘greener’ products. Experience in the past hasshown that policy measures implemented in iso-lation have little impact on the behaviour ofproducers and consumers alike. The overall aim ofan IPP composed of measures structured withinintegrated building blocks would be to createa policy regime pushing at several points toencourage changes in behaviour.

Set in the context of the reverse chain manage-ment model of policy development in some EUmember states (see above), we propose a modelfor the development of IPP that provides a‘road-map’ for policy evolution at national or EUlevel (see Table 2). The model takes as a startingpoint the need for a strategic perspective, withpolicy measures being accumulated incrementallyover time as a full-scale policy regime unfolds.


THE RATIONALE FOR AN EUINTEGRATED PRODUCT POLICY

Through the EU Eco-label and a number ofconsumption waste-related initiatives (onpackaging and electronic goods) the EuropeanCommission has already begun developingproduct-related environmental policies. At thesame time, product policies and product manage-ment strategies have emerged in several EUmember states and in business strategy in largeEuropean firms. Overall however, the pictureacross the EU is patchy and incoherent. Thevariety of national approaches creates some fam-iliar arguments in support of EC intervention.First, barriers to trade could emerge if differentapproaches develop across the EU, creating afragmented product policy context. Second, thedifferentiated picture will widen gaps and dis-parities across member states. National policymakers recognize this, and some have expressed awish to combine their experiences and effortsin order to build a consistent European policy.Third, impacts on the internal market wouldresult, distorting patterns of trade, production andconsumption. Industry might also suffer from thelack of a level playing field. Several firms haveexpressed the wish that the EC take action tointroduce a coherent framework across the EU.And fourth, on a more positive note, promotingenvironmentally superior products in industrymay enhance Europe’s international competitive-ness. Product policies can play a positive role instimulating innovation and competitiveness, par-ticularly as firms plan their strategies and developtheir technologies in a Community-wide context.

An additional argument for an EC IPP is thatthe range of issues associated with products isimportant in the context of developing strategiesfor sustainable development. A way forward forsustainable development that does not incorpor-ate actions related to products is likely, in itself, tobe unsustainable in economic, environmental andpolitical terms.

ROLE OF THE EUROPEANCOMMISSION

Given the potential risks of inaction at EU level,and the capacity for the EU to play a positive

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enabling role, we propose that the EuropeanCommission has an important role to play inthe development of IPP. We believe that theEuropean Commission may take four roles in IPP.First, to define a common understanding of IPP, andto articulate a common vision of what it is settingout to achieve. Clear objectives need to be set.Second, to encourage the diffusion of best policypractice beyond the ‘heartland’ of member statesthat have already taken concerted action, and soto harmonize the ‘product policy context’ acrossthe EU. Third, to support the effective implementationof product policies through the integration ofproduct policy aims in EU policy more generally.


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Fourth, to develop specific IPP measures where actionat an EU level is justified, taking into accountinternal market provisions and the principle ofsubsidiarity.

This policy approach may be characterized asenabling, primarily concerned with capacity build-ing, encouraging convergence between policies ata national level and supporting national policies towork more effectively. It is not an approach relianton traditional directive policy mechanisms. It iswell attuned to the fragmented nature of currentnational activity and also to the principle ofsubsidiarity. In some cases it may imply a recon-sideration of existing EU policy. For instance, the

Table 2. An evolutionary model of IPP

Policyphase

Characteristicpolicy

Elements ofbuilding block

Mandatoryor voluntary

Access toinformation

Scope of producerresponsibility

Pre-IPP Integrated pollutioncontrol

Site-based emissionscontrolEco-auditEnvironmentalManagementSystemsEnergy audit

Mandatoryand voluntaryapproaches

Environmentalinformation heldby producer andregulator

Production site

Phase 1 Post-consumer wastemanagement—non-dissipative—dissipative

Waste hierarchy inwaste managementPriority waste streamsChemicals control ofproducts onenvironmentalgrounds

Mandatoryand voluntaryapproaches

Product-relatedenvironmentalinformationgenerated andshared betweenproducers andregulators

Production siteand key post-consumerwaste streams

Phase 2 Informationinstruments

Eco-labelEnvironmentaldeclarationsGuidelines andcriteria for greenprocurements (publicand private sector)

Mainlyvoluntaryapproaches

More product-relatedenvironmentalinformationgenerated andshared acrossproduct chain

Productionsite, keyproductsduring usephase, morepost-consumerwaste streams

Phase 3 Green productinnovation anddiffusion

Support for tools forgreen innovationFinancial support for‘ecodesign’Product ManagementSystems

Voluntary Routinegeneration of lifecycleinformation formany products,shared acrossproduct chain

Total life cycle(‘weak’producerresponsibility)

Phase 4 Integratedproduct policy

EcotaxesPublic informationSupport for eco-servicesEnvironmentalbudgets

Mandatoryand voluntary

Routinegeneration of lifecycleinformation

Total life cycle(‘strong’producerresponsibility)

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goal of establishing a unitary EU-wide eco-labelmay need to be sacrificed if more effective nationalschemes exist, or are being created.

In considering the four roles described above,we consider that there is a sensible order ofpriority the Commission should follow. It isclearly of prime importance to establish a com-mon understanding of product policy, and toarticulate that in a product policy ‘vision’. Thisvisioning activity needs to set out clear objec-tives. Diffusing best policy practice and sup-porting policy implementation can be seen assecond-tier activities, which can only occur onceclearly articulated definitions and objectives havebeen accepted. All of these areas of activity needto be built upon a foundation of specific measures.

CONCLUSION

In the longer term the development of IPPrequires the systematic accumulation of measuresthat change the behaviour of firms and consumers.The broad aim should be to act across the fullrange of products, however defined, rather thanfor policy to be confined to the particularism ofmany current policies directed at products and theenvironment. We therefore consider that the EUneeds to be working along many fronts at thesame time, encouraging the development ofpolicies in each of the five building blocks. It isimportant that measures are planned, developedand implemented in an integrated framework. Alesson from experience of the European Eco-labelis that the introduction of a single isolated instru-ment lessens its chance of becoming effectivepolicy. IPP needs to be seen as an integratedfamily of connected measures that also harnessprivate sector and civil society activities. Weconsider that the EU should be actively encour-aging member states to adopt this frameworkand recommending that they develop measureswhich flow from it as well. This will ensure not


only consistency, but that there is dynamism ina process moving towards an overall objective,and burgeoning constituencies of interest in itssuccess.

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Products and the environment: an integrated approach to policy