The Norwegian Seafood Federation
NSF
The Norwegian Seafood Federation represents the interests of approximately 800 member companies.
ID: 481502038401-67
Lobbying Activity
Response to Environmental claims based on environmental footprint methods
31 Aug 2020
The Norwegian Seafood Federation welcomes the Commission's initiative on legislative proposal on substantiating green claims.
The Norwegian Seafood Federation (NSA) represents the interests of approximately 680 member companies. Our member companies represent the entire supply chain from sea to dinner table in the fisheries and aquaculture sectors in Norway.
The Norwegian Seafood Federation is affiliated with the Confederation of Norwegian Enterprise (NHO). NHO is the main representative body for Norwegian employers with a current membership of over 28.000 companies ranging from small family-owned businesses to multinational companies.
The members of the Norwegian Seafood Federation experience increased demand for documentation of environmental performances from the customers, the consumers as well as the financial institutions and the stock markets.
The major challenge is that the accounting system for environmental performances is not standardized and it is difficult to compare the various documentations and reports.
Whenever quantitative information on environmental performance of a product is used (ie., communicated, required…) by an actor of a product supply chain or a related stakeholder (including or required for public purchase) in the EU market, the Product Environmental Footprint method (PEF) (Com. Rec. (2013/179/EU)) should be the reference methodology to calculate such data/quantitative information.
The use of the PEF in the context described above must be standardised in an EU policy framework.
The policy framework based on the PEF should be developed with the support of interested industry stakeholders.
The policy framework must ensure that the use of data/quantitative information following the PEF methodology is verifiable, credible, scientifically reliable, comprehensive, clear, not misleading, and transparent, be it linked to a PEFCR (Product Environmental Footprint Category Rules) or not.
Whenever quantitative information on environmental performance of a product is communicated or required for public purchase, the correct use of the PEF methodology according to the policy framework and provision of data according to the PEF methodology shall be controlled by the relevant market surveillance authority at national level in a full and transparent way .
The policy framework should support the use of PEF as a diagnostic tool for identifying hotspots, promoting continuous improvement or provide product information to consumers
The policy framework should always take into account and promote innovation to improve the performance of products, including their environmental performance along the life-cycle.
The policy framework should provide a level playing field for competing based on environmental performance for all products sold on the EU markets.
Recognizing the fact that for the majority of product categories it will take time to develop relevant PEFCRs, the NSF consider that Option 3 as described in the Inception impact assessment – document (Ares(2020)3820384), should be the chosen objective in a medium/long term perspective.
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