Comments on Commission Consultation on Resource Efficiency Indicators

European Engineering industries are generally committed to the objectives of the EU Resource Efficiency Roadmap. We believe that developing indicators that are meaningful and appropriate needs to be based on a clear set of criteria, including the Commission’s suggested criteria of RACER (relevance, acceptability, credibility, easiness, robustness), but also on further criteria, such as data availability, fitness for purpose to guide regulators in their policy making, consistency, completeness or timeliness.

Orgalime wishes to raise the following core comments on the Commission consultation paper on resource efficiency indicators:

If indicators are to be developed, they need to be fully harmonised, shared, representative and based on robust data, with an appropriate methodology, which we believe is not the case for the moment being.

The existing lack of available data also interferes with the development of reliable indicators. European standardisation should be used to fill gaps where it is possible.

A very careful approach that embraces environmental and economic aspects alike should be adopted when assessing possible resource efficiency indicators. In this respect, we question the suggested methodology and structure proposed by the consultation document.

In our view, the proposed lead indicator of Domestic Material Consumption (DMC) shows considerable weaknesses in terms of its capacity to reflect all aspects of Resource Efficiency in an appropriate and reliable manner. This risks leading to misinterpretations in environmental and economic terms and should therefore not be applied.

Orgalime industries recommend abandoning the lead indicator, and to focus directly on the development of dashboard macro-indicators instead, which should in particular include the following indicators: economy, environment, technology and (environmental) policy implementation score.

As long as there are no robust and transparent indicators derived from representative data and methodologies, it is in our view inappropriate to progress with the setting of targets.