Waste is the oldest environmental Environmental policy finds its

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UNION EUROPEENNE DE L’ARTISANAT ET DES PETITES ET MOYENNES ENTREPRISES
EUROPÄISCHE UNION DES HANDWERKS UND DER KLEIN- UND MITTELBETRIEBE
EUROPEAN ASSOCIATON OF CRAFT, SMALL AND MEDIUM-SIZED ENTERPRISES
UNIONE EUROPEA DELL’ ARTIGIANATO E DELLE PICCOLE E MEDIE IMPRESE
UEAPME’s response to the October 2003
draft eco-label criteria for refrigerators
The latest draft criteria for refrigerators dated October 2003 are in line with our previous
comments of August 2003 and our answers to the short questionnaire sent out in September
2003. Therefore, UEAPME can support this latest version.
However, UEAPME would like to underline that it disapproves of the decision to include two
new criteria, on electrical cables and packaging, a few days before the vote. This is all the
more regrettable that these criteria relate to the very controversial issue of PVC.
UEAPME would like to, once again, clarify its position regarding PVC. Until a substitute for
PVC is accepted by all on the basis of scientific evidence, UEAPME cannot support the
exclusion of PVC from the eco-label scheme.
The EU eco-label is already very difficult to obtain and in particular for SMEs. The addition
of these two new criteria is placing unnecessary burdens on businesses, in particular since the
overall environmental impact of electrical cables and packaging in refrigerators is negligible.
Brussels, 3 December 2003
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