American firms warn EU against drafting Integrated Product Policy that sets minimum recycling levels

The EU Committee of the American Chamber of Commerce has submitted its views on how the EU should design policy aimed at reducing the environmental impacts of manufactured goods. The Committee warns against basing policy on "a utopian set of objectives".


The EU Committee of the American Chamber of Commerce represents US firms, or firms of US parentage, that operate within the EU. Its position statement, sent to EU environment commissioner Margot Wallström, states that any plans to set minimum recycled content levels for goods could be in breach of World Trade Organisation (WTO) rules and that manufacturers should not be held solely responsible for environmental improvements – consumers should have responsibility as well.

The Committee makes the following suggestions for European Commission officials drafting Integrated Product Policy (IPP):

  • “it is important to differentiate between aspirational long-term goals, which may be suitable for certain preambles of international conventions, and concrete objectives against which the effectiveness of legislation should be measured”
  • “life cycle analysis is not yet sufficiently developed from a scientific point of view [and] implementation is extremely time consuming and data is frequently outdated and no longer relevant to an industrial activity by the time it is completed. More work to develop this tool is recommended”
  • “the EU Committee believes that it would be premature to push for a sector-based approach. Prioritsing some industries could create a negative effect among those selected, increasing the opposition to an IPP at EU level”
  • “IPP should assign responsibilities using the concept of shared responsibility, which is based on the idea that environmental impact should be minimised throughout the life-cycle of a product, including at the end of the cycle. Although producers play a fundamental role in reducing the impact on the environment of their products, it is not always possible for them to achieve this by acting in isolation”
  • “excessive emphasis on Type I ecolabels as described in ISO 14021, through binding requirements in public procurement or other mechanisms, would create barriers to innovation because these labels are based on existing products and they cannot anticipate how other products will develop. A prudent interpretation of the substitution principle is also needed in order to make sure that replacement products are equally efficient and, also in real-life, environmentally superior. Substance bans must be the last recourse for a particular environmental problem and must be based on sound science”
  • “the use of precautionary measures should also be dealt with within a scientific paradigm.

    Precautionary measures cannot be the basis for permanent legislation but rather a transitory instrument waiting for more accurate scientific answers”

  • “in the past, the Commission and Parliament have not been favourable to voluntary agreements. The EU Committee believes that a change in policy is needed”

Above all, the EU Committee of the American Chamber of Commerce is adamant that the EU’s Integrated Product Policy should not be used to introduce new product-based environmental legislation. “A European IPP must not be the source of a new wave of legislation in the environmental field, but rather a balanced combination of existing instruments and measures,” states the position statement. “IPP should be the framework in which existing measures should be re-tested and modified in case of conflict or low effectiveness. For example, in the area of waste, industry has been denouncing for a number of years the impossibility of creating a true recycling market when wastes, showing the same properties as raw materials, are subject to a more burdensome treatment. Introducing a more flexible approach to the definition of waste in Directive 75/442/EEC would help to maximise recycling.”

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