-  Positions

• The CIAA recognises the potential value of defining an integrated product-oriented policy approach at European level. We fully support IPP if IPP is a public policy, which aims at or is suitable for continuous improvement in the environmental performance of products and services within a life cycle context.
• The food and drink industry is committed to continuously raising its environmental performance to ensure sustainable development. The protection of the environment and the wish to meet consumer needs in a sustainable manner is a high priority for us.
• An IPP should not aim at classifying and making some discrimination between so called "greener" products and non-green products. Such a distinction would create market distortions. Public authorities should respect existing market forces and not try to artificially create markets for "greener products". As food and drink industries do not compete for the safety of the foodstuffs, we do not want to compete for the environment.
  
• Our industry has already taken steps to improve all aspects of our environmental behaviour, including support for sustainable agriculture, adoption of cleaner production, minimisation of packaging and optimisation of transport. Resource efficiency and eco-efficiency are among our main objectives, together with safety and quality of our products.

IPP: An instrument of sustainable development

• IPP is often presented as an instrument of sustainable development. The link between IPP and sustainable development is expressly recognised in the introduction of the IPP Green Paper. However, the Green Paper focuses mainly on the environmental pillar, and the economic and social pillars are neglected.
• IPP should contribute to achieve the objectives set by the sustainable development. To do so, there is clearly a need for a definition of related priority objectives. So far, in the absence of clear objectives, the proposed tools in the IPP Green Paper tend to become the targets. Such confusion should be avoided.
• Moreover, once these objectives are set, companies should be able to choose the most effective means to achieve these results. This pre-supposes that the IPP framework is flexible. This flexibility is particularly needed to optimise processes, packaging and transport, minimise environmental impact and allow innovations.

IPP: Already a reality for food products

IPP is already a reality for food products because environmental considerations are taken care of throughout the supply chain.

- Sustainable Agriculture
As the quality of our food products depends on the quality of raw materials, which come from nature and depend on a clean environment, food companies support sustainable agriculture practices. Traceability systems across the supply chain have also been established to help ensure the efficient management of food safety issues. In order to ensure that the raw materials that we buy meet required quality, they are rigorously controlled before their processing.

- The food and drink industry conforms to legal requirements as a minimum standard.

• As food safety is our prime concern, food and drink products are already controlled by very detailed and comprehensive legislation starting at the farm gate and ending on the dinner plate. It covers food safety (contaminants, pesticide residues, quality of water intended for food consumption, …), food hygiene (general rules, health rules), food composition (additives, flavourings, GMOs), consumer info (general labelling rules, quantitative ingredient declaration, …), nutrition, ionisation, organic production and more.

• Our food and drink products are a result of production processes. Both agricultural and industrial production processes are in most cases involved.Europe's food and drink manufacturers fully endorse the principles underpinning the IPPC Directive. Food and drink installations already apply Best Available Techniques (BATs) whenever it is technically feasible and economically viable. As an example, waste minimisation is ensured by various means of process control and operational procedures. Indeed, most of our companies reduce the loss of materials on their sites through good housekeeping measures. Operating practices, process optimisation and methods to contain emissions are prevalent. Techniques for reuse/recovery as well as end of pipe treatment technologies are also very common. All these measures represent BAT solutions when implemented in the appropriate circumstances that depend on plant scale, materials used, nature of the products made, number of different products produced, etc. We therefore believe that there should be flexibility in pollution control techniques to take into account the wide range of activities used within the food and drink industry. With regard to IPPC, the CIAA actively co-operates with the Commission in drawing up a reference list of the BATs in our sector so that adequate guidelines for permitting will exist.

• As packaging users, we consider that the packaging and packaging waste issues are heavily regulated by evolving EU rules incorporating challenging recovery and recycling targets. It is an area where great progress has already been achieved, especially in terms of prevention and recovery. Food and drink companies always seek to improve their packaging through the minimisation of the packaging weight and the use of materials that are ecologically and economically rational. However, demands for less packaging have to be considered against social and demographic trends, such as smaller households and increased demands for convenience foods. Moreover, minimising packaging further could endanger the safety and/or quality of our products.
  It is not possible to look at packaging in isolation from food products, as it is essential to preserve and protect against handling damage, spoilage and contamination. It is also an important communication tool conveying essential information to the consumer (ingredients, nutritional information, etc). In addition, packaged foods generate less total waste than fresh foods. Our industry is fully supportive of the CEN standards on packaging EN 13427-13432 as they allow companies to comply with the essential requirements of the packaging directive. These standards notably offer the required flexibility to encourage innovation and enable packaging to be adapted to consumer needs. They also fit in with the environmental and quality systems within companies, while encouraging constant efforts to improve the environmental performance of packaging. IPP should not introduce stringent obligation with regard to packaging as it could trigger additional costs or even trade restrictions such as packaging reuse quotas or can bans.

• Further to a high level of regulatory compliance we have also taken many voluntary initiatives in order to minimise the environmental impact of our activities. At national level, many types of agreements exist to which food companies are committed. Also, to assess and reduce energy and water consumption and waste production, environmental management tools have been adopted by a large part or our industry (audits, environmental indicators, ISO 14001). Many of our sites are also certified EMAS or have an internal environmental management system. Many companies have already been using eco-design guides for the design of their packaging.

We can conclude that the Integrated Product Policy is already a reality for a large part of food products. The CIAA would therefore support voluntary actions instead of a heavy-handed regulatory approach.

Life cycle approach

The CIAA recognises the life cycle approach as a valuable tool to assess environmental effects of different options in a specific context and thus to continuously improve the environmental performance of products. Whilst the life cycle approach to a single product might be a useful tool in some cases, its positive application to the food and drink industry is less apparent. Life cycle assessments of packaging are now well mastered and they are a useful tool for eco-design of products, but their interpretation should be cautiously made. The RDC report itself expresses inadequacies and uncertainties of LCA as one of its constraints. In fact, LCA often involves subjective decisions on system boundaries and functional unit and the data used can be inaccurate or irrelevant. In other words, it is highly difficult to extrapolate from case-by-case LCA and use LCA in policy making.

Shared responsibility

Producers should not bear alone the sole responsibility for what happens to a product from the cradle to the grave. If producer responsibility was to be extended to new areas of Community legislation, the concept needs to be clearly defined to comprise responsibility throughout the product chain stretching from agriculture to retail and consumers.

Economic instruments

Before promoting economic instruments, clear objectives and coherent criteria for the practical use of these instruments should be established. The design of economic instruments must be based on solid and complete data and sound science, taking into account cost-effectiveness, but also uncertainties and alternatives. The use of an economic instrument should particularly be justified by real environmental objectives and should not lead to arbitrary discrimination between products or materials. Economic instruments like ecotaxes should neither lead to the creation of trade barriers nor disrupt international trade and WTO agreements. The principle of proportionality should also be respected when governments use instruments such ecotaxes. Use of economic instruments must allow industry to continue to be innovative while addressing environmental protection.
The CIAA supports an integrated approach to environment and economic objectives, in which Member States agree on a coherent framework that combines regulation with market-based instruments with mechanisms such as voluntary and negotiated agreements.

Eco-labels

We recognise that there is an increasing demand from consumers for detailed information so that they can make informed choices. Lots of labels and certificates exist already for food and drink products informing consumers on the origin of the product (e.g. organic), its ingredients, its composition, its nutrition, whether or not it contains GMOs, etc.
So far, due to the special nature of food and drink products, they fall outside the scope of the EU Regulation on eco-labels. We welcome this decision and believe that new eco-labels on our products would create confusion and misunderstanding on the part of consumers.
Moreover, we believe that the right IPP approach should be to secure continuous improvement of all food and drink products rather than classifying them as either "good" or "bad" through the eco-labelling.

Conclusion

The European food and drink industry is on the right track to ensure a sustainable environment and produce sustainable products. Our industry has now taken steps to take environment into account in a global manner, all along the food chain, with a specific attention to the upstream part of the life cycle of products.
We strongly believe that IPP should be more an approach to initiate a positive dialogue with the other stakeholders, especially with consumers, media and NGOs than a tool for imposing new regulations or substitute instruments such as taxes and charges.