Having reviewed the Draft Commission Recommendation on the use of Product Environmental Footprint (PEF) and the Organisation Environmental Footprint (OEF) methods, both Orgalime and ANEC are extremely disappointed that, notwithstanding their joint opposition to the draft proposal, the Commission should once again have opted for yet more big brother ‘voluntary’ regulation.
Orgalime sees this proposal as representing an unreliable tool for creating demand for better and greener  products in the EU, while it risks exposing companies to unfair competition and to market distortion as consumers would base their buying decisions on misleading information.
ANEC too has been a persistent critic of the value of environmental footprint information, whether from a methodological perspective, or the perspective of consumer understanding, and maintains that information to consumers based on the LCA approach - at the centre of PEF/OEF methodologies - should be rejected and neither supported nor promoted by the European Commission or member states.
Although principles such as clarity, credibility and reliability, identified in the Commission Communication, are values shared by consumer organisations and the engineering industry, the proposed methodologies cannot serve to apply these principles. Information to consumers should be based on robust, measurable and verifiable indicators, elaborated product group by product group, in collaboration with stakeholders.
ANEC Secretary-General, Stephen Russell, commented: “Environmental Product Declarations are useless for consumers as they do not allow for the reliable identification of environmentally-superior products. They are based on questionable methods and lack meaningful benchmarks and rating scales. Real world cases of LCA studies – such as nappies and packaging - have already shown that the results of an environmental assessment based on LCA depend on subjective choices. Moreover, statistical uncertainties inherent in the data are likely to make the identification of superior products almost impossible anyway”.
Concluded Adrian Harris, Orgalime’s Director General: “It never ceases to astound me how the institutions can one day adopt proposals aimed at enticing manufacturing industry to invest in Europe and to contribute to much needed re-industrialisation, and the next come up with yet more bureaucratic proposals, which will be prohibitively heavy to apply for our small companies and no doubt achieve the opposite result. It really is time to snap out of this business as usual mode”.

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Notes for Editors:
Orgalime, the European Engineering Industries Association, speaks for 39 trade federations representing some 130,000 companies in
the mechanical, electrical, electronic, metalworking & metal articles industries of 23 European countries. The industry employs some
10.2 million people in the EU and in 2011 accounted for some €1,666 billion of annual output. The industry not only represents some
28% of the output of manufactured products but also a third of the manufactured exports of the European Union.
http://www.orgalime.org
ANEC is the European consumer voice in standardisation, defending consumer interests in the processes of technical standardisation
and conformity assessment as well as related legislation and public policies. ANEC was established in 1995 as an international nonprofit
association under Belgian law and represents consumer organisations from 33 European countries. ANEC is funded by the
European Union and EFTA, with national consumer organisations contributing in kind. Its Secretariat is based in Brussels.
http://www.anec.eu