Throwing out the baby with the bathwater?

Abstract

Given that the Commission acknowledges that IPP will contribute to meeting the goals of the 6th Environment Action Programme, it is not surprising that there are no quantifiable targets stated within the overarching objective of IPP. Unfortunate ly, this positioning of IPP is not clearly articulated in the Communication, which perhaps leads to unnecessary criticism with respect to quantifiable targets for the policy. Similarly, IPP is positioned to contribute towards the implementation of EU Sustainable Development Strategy and constitutes a major input to the tenyear framework of programmes on sustainable production and consumption. Figure 1 graphically illustrates the positioning of IPP in this respect. Although IPP is recognised as an important component to achieve the objectives of these overarching programmes, the relative contribution expected from IPP is not specified. More importantly, since IPP strongly advocates a process of first identifying and then optimising actions to reduce life cycle impacts of products, it is expected that this would involve various other environmental policy areas such as waste, chemical and energy, for example. However, very little attention is paid to clarifying the position of IPP with respect to these areas. One of the key critiques against the current IPP Communication is that it is rather vague. COM (2003)302 begins by presenting the rationale for a product-oriented approach to policy making. This is followed by a description of the IPP Approach, based on five guiding principles, which essentially form the 'ideology' behind the policy.Although found relatively deep in the document, the stated primary aim of IPP is "to reduce the environmental impacts from products throughout their life cycle, harnessing, where possible, a market driven approach". In terms of implementation, the EU IPP strategy is divided into two streams of action. The first, "Establishing the Framework Conditions for Continuous Improvements", could be better described as a description of the policy tools that the Commission sees relevant within IPP. The second stream "Developing a Focus on Specific Products" outlines the envisioned pilot projects and the process to develop a methodology to target specific product groups, with which to apply the IPP approach at the EU level. For each of the policy instruments listed in the first action stream of the strategy, the Commission also outlines the specific actions it intends to pursue in order to develop and expand the "toolbox". These actions are primarily information or research related, and in many instances they are also rather vaguely described. The specific actions under the second stream of activity in the strategy are more explicit and clear, however the process of identifying priority product groups is scheduled to last up to 3 to 4 years. The following table provides an overview of the main action items found in the Communication and categorises them by date. key problem issuesA thorough reading of the latest Communication on IPP is likely to leave t...