Orgalime contribution to the Consultation on Delivering more Sustainable Consumption and Production

Published: 5 April 2012

Policies & Issues: Environment

Orgalime welcomes the consultation “Delivering more Sustainable Consumption and Production” and the opportunity to comment.

However, the format considered appears to us as inappropriate as it pre-indicates certain choices (i.e. extension of the Eco design Directive to further products and further parameters), which Orgalime strongly object to, as we do not believe that consultation should lead to foregone conclusions on the way forward, in particular when these suggest yet more modifications of the legal framework. Such an approach is clearly not in line with Better Regulation and transparent policy and regulatory approach.

Therefore, we raise our comments by this means taking into account the background document and the questionnaire and we would like to contribute to the ongoing consultation, especially on the three following issues:


* Sustainable Consumption and Production (SCP) and Sustainable Industrial policy (SIP)
* Product Environmental Footprint (PEF)
* Environmental Footprint of Organisations (OEF)

Related Position Papers

Environment: Orgalim response to the public consultation on the RoHS evaluation [6 December 2019]

Environment: Evaluation of Directive 2011/65/EU (“RoHS”): Improving implementation in a Circular Economy context [6 December 2019]

Environment: The European technology industries’ priorities for the sustainable use and management of water in Europe [14 November 2019]

Environment: Orgalim's response to a public consultation on sustainability requirements for batteries [27 August 2019]

Waste policy: Joint industry comments on modulating producers’ financial contributions for Waste Electrical and Electronic Equipment [26 July 2019]

Eunomia study in support of developing Guidance for Extended Producer Responsibility (EPR) Schemes: Comments on modulation of producers’ financial contributions [12 March 2019]

Orgalim response: Consultation by Technical Expert Group on Sustainable Finance [25 February 2019]

Feedback on the usability of the taxonomy - Orgalim response [25 February 2019]

Orgalime response to consultation on RoHS Substance Review Methodology [21 December 2018]