- The Consumer Council welcomes the opportunity to provide its comments in response to a consultation paper issued by the Environment, Transport and Works Bureau (ETWB) on a 'Proposed Scheme to Require Mandatory Registration and Labelling of the Contents of Volatile Organic Compounds in Specified Products'.
OVERVIEWS
- Given the smog problem and the potential health implication arising from VOC emissions, the Council fully supports the Government's policy objective of improving the environment and human health through reducing VOC emissions in Hong Kong. In order to ensure that the implementation process of the proposed scheme is viable and manageable to the economy as a whole, the Council is of the view that
- the regulation for consumer products could be prioritized according their respective contribution to the total VOC emissions as products with higher VOC content would have higher potential for achieving the objective of reducing VOC emissions in Hong Kong;
- it may be necessary to prescribe the labelling requirement and VOC content limits for consumer products with high-VOC contents; and
- the regulation on other consumer products with lower VOC emissions could be implemented at a later stage, subject to the effectiveness of VOC emissions reduction involving products with high-VOC contents.
- With regard to the practicality of the proposed registration and labelling scheme, the Council has suggestions on the following aspects for further deliberation of the Government.
- Coverage of the regulatory scheme - it may be necessary to establish selection criteria for prioritizing product categories to be covered in the selection of consumer products to be targeted for VOC emission reductions, for reason that some products without or of low-VOC contents might not significantly help to achieve VOC reduction goals.
- Effectiveness of the labeling requirement - the success of reducing VOC emissions by means of labelling scheme depends on whether it can bring about a change in the purchasing behaviour of consumers. It is therefore necessary to enhance the level of public awareness about environmental impacts of VOC and generate active consumer interest in changing their purchasing behaviour.
- Economic effects of the scheme - the cost effectiveness of the regulatory requirements and a competitive market are important safeguards against onerous cost being passed on to the consumers.
SPECIFIC COMMENTS & SUGGESTIONS
(i) Selection of consumer products for regulation
- Under the proposed regulatory scheme, all selected consumer product categories are required to register with the Environmental Protection Department (EPD) the VOC contents that they carry. The scope of the categories is very broad and includes not only products with VOC but also those without or of low-VOC contents.
- By adopting an "all-embracing" approach, the Council believes that potential for reducing VOC emissions from the consumer products sector in Hong Kong exists. However, it is uncertain if it would be cost-effective to include products posing small sources of VOC. The Council is of the view that the regulation of consumer products should be prioritized according to their respective contribution to the total VOC emissions with reference to the overall atmospheric loadings of VOC and the associated ozone problem.
- Establish selection criteria for prioritizing product categories
- Given the broad universe of consumer products involving many different brands from various sources, the Council considers it essential to have some criteria for determining which product categories should be selected for regulation. The Government would be able to develop a more effective regulatory scheme based on established selection criteria.
- Reference can be drawn to the US selection criteria for products, including utility, health and safety functions, emissions of highly reactive VOC, availability of alternative products, cost-effectiveness of controls, magnitude of annual VOC emissions, and regulatory efficiency.
- The Council suggests that the regulation of consumer products can then be expedited by using a prioritized list as a starting point, to ensure manageable changes. That is, higher priority for VOC control, in terms of labelling and content limits, should be on high-VOC content/reactivity products.
(ii) Facilitating consumer awareness of VOC label
- The Council supports the introduction of mandatory VOC labelling on high-VOC content products as a label provides more information on the products, and this can help consumers to make informed choices of products to buy. If all selected products within the retail sector are required to display a label, it will be easy for consumers to identify products with lower VOC contents.
- Perhaps more significantly such scheme could have substantial market transformation effect by influencing retailer procurement policies thereby driving aggregate environmental improvements across a business sector. The environment would benefit from an increase in the market share of less harmful products.
- Whilst welcoming a labelling scheme, the Council considers that the mere existence of an information label would not lead to environmental improvement. The impact of the labelling scheme on the market is directly linked to the level of environmental awareness and consequently the consumer demand for greener products (i.e. low VOC content products) and changes in producer and retailer behaviour towards greener products.
- A lot of consumers will be happy to do their bit, but they need to be better informed if they are to use less environmental harmful products. In this respect, the Government and industry are key players in promoting sustainable consumption by consumers.
- The Council believes that the involvement of environmental bodies, consumer organizations and the media may help to increase the level of consumer awareness of environmentally-preferred products. In this regard, the Council is willing to offer its publicity and information dissemination services to assist the Government to educate consumers to make informed choice when purchasing products with VOC contents and to encourage consumers to use products with low or no VOC contents.
- The Council considers a package of mutually reinforcing measures - for example, in raising general awareness - is much more likely to achieve significant results than an information scheme on its own. To empower consumers to make a difference in their choice, the Council suggests that the Government should take the following measures to make the public better informed.
- Enhance public understanding of environmental impacts of VOC
- The Council as a consumer advocate expects to see measures developed and implemented to facilitate public understanding of implication of VOC emissions to the environment and human health in order that consumers can take on their citizens' responsibility by buying and using low or no VOC content products in their daily life.
- Make information available to help consumers choose
- With regard to the inventory which will include information on VOC content of each individual product, the Council suggests that certain types of information in the inventory should be made publicly available on a dedicated website. The website would enable members of the public to readily identify the comprehensive range of consumer products with VOC content limits so that they can effectively participate in greener purchase and use less VOC emissions products.
- Reference can be made to the EU's database ( www.eco-abel.com/SearchProduct.asp ) which provides details on eco-labelled products.
- Provide clear and reliable information to consumers
- Good quality information about products plays an important part in achieving environmental objectives. Consumers need to be able to trust that the label information they receive is accurate, reliable and unbiased. The Council therefore supports that the proposed labeling should be of quantified product information. The Council further supports making it an offence for submitting false information.
- A common label design would also make it easier for consumers to find out information about the VOC content of the products - thereby enabling consumers to play their part by making environmentally-friendly choices.
- Give guidance on the alternative ways of meeting consumer needs in using low-VOC content products
- There is a common perception that many consumer products of higher VOC content have better performance and are therefore of superior quality. Consumers using low-VOC content products may feel the need to use twice as much product (such as cleansing) to achieve the same result. It is therefore important to make clear messages or communications to the public to contain the effect of any misunderstanding.
- The Council also cautions that the important public health function of some products (such as disinfectants) could be forgotten in the pursuit of VOC reductions. It is therefore important for the Government to provide advice on alternative ways of meeting consumer needs for using without or low VOC content products.
- Disseminate the results of reduction evaluation periodically
- It is noted that the consultation paper has not mentioned anticipated VOC emission reductions from implementing the proposed regulation. The Council is of the view that it will be useful for the public to have information on anticipated reduction in VOC emissions from the selected consumer products.
- The public should be kept informed of the progress (or the success) of VOC reductions achieved as a consequence of actions implemented. The Council suggests that the Government should provide a yearly report on the progress of VOC reduction from consumer products.
(iii) Cost implications to consumers
- Regulation of household and personal care products will immediately and directly impact the public.
- The Council considers that compliance with the regulatory requirements for VOC products as proposed might have cost implications for the affected consumer products. Some of these costs could be passed on to consumers in the form of higher prices. Also, the effect of some products being removed from the market due to unwillingness to invest extra costs will likely lead to changes in prices and quantities of products in the market. In this regard, the Council considers the cost-effectiveness of the regulatory requirement and a competitive market are important safeguards against onerous costs being passed on to the consumers.
CONCLUSION
- The Council believes that the success of a policy requires not only drafting of a good regulation but also public consensus on the way forward. This requires all stakeholders from manufacturers to consumers to have a proper understanding of their respective responsibility and to play their part. The Government should actively assist or encourage all stakeholders to play their part.
