First circulated by the Commission's enterprise directive in May (ENDS Daily 2 May), the plan for a so-called "EEE" directive is intended to complement draft directives on waste E&E equipment (WEEE) and restrictions on dangerous substances used in E&E equipment (ROS) that were both formally proposed by the Commission in June (ENDS Daily 13 June).
"Orgalime believes that it will be counter-productive to require the use of a specific method such as life-cycle assessments," the position paper says. "There is no clear definition and no common understanding of LCAs: an internationally recommended method does not exist for the time being."
The criticism strikes at the heart of the EEE proposal which would oblige companies to complete an "internal design control" on their products or set up environmental management systems instead. The directive would introduce a set of "basic requirements" forcing companies to "avoid" certain components in a bid to "minimise" the impact of products.
"Orgalime does not agree with using the words "avoid," "minimise," and "control," the paper says. Instead, the association suggests using the phrase "continuous improvement" in product impact. "The manufacturer himself should define the factors of major environmental impact for the specific product."
Orgalime, tel: +32 2 706 8235,
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