Foundation for Environmental Education
FEE
We believe in the power of change and that the best gift we can give to future generations, the most valuable legacy we can leave behind us, is a world of educated and environmentally conscious people equipped with the sustainable attitude which is so sorely lacking in today's society.
ID: 257350623646-63
Lobbying Activity
Response to Environmental claims based on environmental footprint methods
20 Jul 2023
The Foundation for Environmental Education (FEE), is a leading CSO in Education for Sustainable Development and Sustainable Tourism, representing over 100 member organisations in 80 countries. We have members in all EU member states except Hungary, as well as in most EU candidate countries. Thus, we play a significant role in implementing Education for Sustainability and sustainable tourism mechanisms at the European level and strongly promote implementation of EU acquis. Three of our flagship programmes include processes leading to environmental certification and awards in the EU: Blue Flag (3,787 sites), Green Key (3,721 establishments), and Eco-Schools (17,844 schools). 2,101 more participating sites are in EU candidate countries, underscoring our potential for impact in future EU development and growth. The Directive is designed for consumer goods and transactions on a perspective of products and not for programmes, therefore, only focuses on the concept of a certification made by an entity accredited by the EU or a member state. In reality, this approach does not address the programme structure, where the evaluation also continuously assesses the progress in the direction of a certain and pre-defined goal. It is also crucial for the EC to acknowledge that the scope of the Directive extends far beyond products. The Directive should recognise the valuable work carried out by the civil society sector in advancing sustainability and supporting the green transition for many decades. Further, its requirements should be inclusive and affordable, ensuring that successful programmes are not eradicated and businesses remain motivated and able to participate in programmes that have consistently enhanced sustainable practices. In this context we would like to propose that the Directive: Recognises the difference between products and programmes in Article 8, through the addition of a new paragraph stating: In case of environmental programmes, a labelling scheme means the recognition of achievement of proposed goals for a specific period of time. Recognises the need of programmes for long-term assessment, through an addition to Article 8.2 (f): labelling scheme has a system of permanent monitoring and assessment, and sets out. In this paragraph we further recommend removal of flagrant and persistent regarding non-compliance, because they introduce a subjective element, open to interpretation. Recognises that national and international committees/juries, comprised of diverse external, independent and qualified experts and/or organizations should be recognised as valid "verifiers", through an addition to Article 11.1: Regulation (EC) 756/2008, or a jury or committee formed with a majority of third parties, not related to the labelling organization. Furthermore: If third-party companies are utilized as verifiers, we advocate for inclusivity and openness to small and medium-sized enterprises (SMEs) and/or competent individuals or entities fulfilling the requirements. We emphasize the importance of maintaining relationships between environmental labelling scheme owners, national operators, and certified entities for educational, support, and training purposes, and advocate that this should be recognised in the Directive. We emphasize the role of education and awareness raising in achieving the environmental labelling objectives, and advocate that the Directive clearly recognises that educational elements of labels, where applicable, are accepted as important and necessary at the EU level. We firmly believe that our collective knowledge and expertise can significantly contribute to the ongoing discussions on the Directive that we wholeheartedly support, while also ensuring that it does not unintentionally hinder our ongoing work or undermine the effectiveness of our programmes. On behalf of FEE and supporting members organisations (see attached list), Daniel Schaffer, CEO
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