Orgalime response to: Evaluation of the Implementation of the EU Ecolabel Survey

The European Engineering Industries represented by Orgalime are committed to the continuous improvement of the environmental performance of the products manufactured by this industry.  The sector is the main target industry of the Ecodesign and Energy Labelling Directives, for which implementation is ongoing for some 46 different product groups. The Ecolabel Regulation, which is to establish “a voluntary ecolabel award scheme intended to promote products with a reduced environmental impact during their entire life cycle and to provide consumers with accurate, science-based information on the environmental impact of products”, applies as a complementary tool on our sector. ORGALIME considers the voluntary nature of the eco label scheme important both for consumers and enterprises, the latter of which can choose to adopt the scheme if it indeed has the capacity to do so. 

To date, the relevance of the EU Ecolabel in our sector remains limited. This is primarily due to:

1. The lack of international recognition – the EU Ecolabel is not always known or recognised on the international scene. Given that our sectors act on global markets, many companies prefer to adopt well established international standards, such as ISO or IEC, rather than the EU Ecolabel.

2. The lack of competitive advantages – public procurement in EU Member States insufficiently ties in with the EU Ecolabel, as well as with the Ecodesign and Energy Labelling requirements.

Indeed, so far the EU Ecolabel only applies to a selected number of product groups of our sector, such as heating/cooling systems, personal and notebook computers or light bulbs.

Orgalime believes that the EU Ecolabel should remain a scientifically-based, voluntary instrument. The label criteria should be set at a level that allows preferably 20% but at least 10% of the market to reach the level. Moreover, the EU Ecolabel should not hamper the activities that are already taking place under the Ecodesign and Energy Labelling directives, but strive for consistency.