- WEB EXCLUSIVE
- PE COFFEEHAUS
On Sept. 16, 2010, the EPA published a Federal Register notice seeking individual stakeholder input regarding the agency’s role in the “green” or sustainable products movement. EPA will consider the information gathered from the notice and other sources as it works to define its role and develop a strategy that identifies how the EPA “can make a meaningful contribution to the development, manufacture, designation and use of sustainable products.” Comments are due Oct. 19, 2010.
The EPA states more specifically that it would appreciate comments responding to the following questions:
- What do you see as the major policy and research challenges, opportunities, and trends impacting the development, manufacture, designation, and use of sustainable products?
- What do you see as the EPA’s overall role in addressing these challenges and opportunities?
- In particular, how do you see the EPA’s role in:
Given the currently widespread marketing emphasis on green products, EPA encouragement, if not endorsement, will be seen as a potentially valuable marketing tool. At the same time, the EPA (or any federal agency) involvement might rapidly devolve into less desirable agency interference in marketplace competition. As the EPA defines what is “sustainable,” the temptation for regulating or otherwise impeding those things “not sustainable” will be increased.
Past attempts to define “environmentally preferable products” have typically had difficulty in weighing or balancing different criteria (e.g., is lower energy consumption more important than disposal impacts?). Regarding government procurement preferences, competing priorities also come into play (e.g., environmental criteria vs. small business set-asides). Even something as simple as government purchasing of cleaning products ran into such difficulties.
Public comments on the current notice will help inform the EPA about the various trade-offs and possible unintended consequences of current and future sustainability initiatives.