Proposal of the European Commission for a 7th Environment Action Programme (EAP)

VCI assessment: 7th UAP may not restrict competitiveness of industry

By the end of 2012, the European Commission has published its proposal for a seventh Environment Action Programme (EAP). In its assessment, VCI judges the plan as too ambitious: It contains long-term goals and strategies although the tasks arising under the predecessor programme are far away from being implemented.

7th EAP: VCI urges to keep in view the competitiveness of industry. © Inga Nielsen -
7th EAP: VCI urges to keep in view the competitiveness of industry. © Inga Nielsen -

In its proposal for a seventh Environment Action Programme (EAP) the Commission sets highly ambitious, partly long-term goals and strategies, even before the Commission and the Member States have implemented the tasks arising under the predecessor programme. A glance back at the 6th EAP shows that the chemical industry is strongly impacted by many of the initiatives triggered there and by subsequent legislation. For this reason, the VCI is taking part in the political debate about the 7th EAP – with this VCI assessment paper. Here are VCI's conclusions in a nutshell:

  • In order to avoid duplicate legislation, initially existing pieces of legislation should be examined as to whether they can achieve the desired goal, e.g. through consistent implementation in the Member States. Only where this is not the case should a second step be taken by, first of all, making additions to existing law wherever this is possible – before proposing new legislative initiatives.
  • In principle, the internalisation of external effects can enhance the prosperity of society. However, an internalisation presupposes a sound scientific basis from we are still a long way away. When using existing instruments, the economic effects need to be examined regularly. Here, politicians need to apply the most cost-efficient internalisation measures. Such internalisation measures in their entirety must not result in extra burdens on companies, i.e. relief needs to be provided elsewhere so that the competitiveness and performance of companies are not put at risk.
  • The 7th EAP wants to integrate environmental protection and the sustainable use of resources in all policies. However, policies must not one-sidedly focus on environmental and climate targets. If measures are demanded to achieve goals, such measures need to equally take into account the economic components (including international competitiveness) as well as social components.

    Political measures and instruments need to be examined carefully as to their future impacts on economic activities and the competitiveness of companies. Here, the “competitiveness check” – as proposed by the Commission within its industrial policy – makes a good basis. This examination is complex and must comprise the whole value chains. The measures in various political fields need to be attuned to each other; their impacts need to be reviewed consistently.
  • More environmental and climate protection calls for more innovation and investment, especially by private actors. For years, industry has been working – already in its own interest – on more resource-efficient processes and climate protection technologies. But investment and research spending need to be economically viable. First of all, the companies must earn the funds needed for investment. Companies cannot be resorted to for financing ever new public spending programmes; this puts businesses under an excessive strain. Public households, too, must do their part with infrastructure investment.
  • With their innovative products and solutions, the European chemical, pharmaceutical and biotechnology industries make an important contribution to the sustainable use of natural resources. This contribution needs to be recognized. Biodiversity is an essential basis for economic activities and innovation with which the above industries can open up new resources and use existing biological resources more efficiently (renewable raw materials, genetic and biological resources). Today, the production – inter alia, of foods and feedstuffs, renewables and medicines – is hardly conceivable without the use of these resources.

In the 7th EAP the Commission reiterates very many elements from its earlier commu­nications. The detailed VCI positions on these Commission communications continue to apply.

You will find the full VCI assessment with detailed comments on the "priority objectives" of the proposal in the download sector at the top of this page. (PDF, 26 pages).

For questions or suggestions, please feel free to contact us.


Dr. Thomas Kullick