FUND FOR RESEARCH INTO INDUSTRIAL DEVELOPMENT, GROWTH & EQUITY

Global Review of Eco-Labels: Implications for South Africa

PHASE ONE REPORT

4. Specific Analysis of the EU Experience with Eco-Labelling

This chapter provides a more detailed review and assessment of the implications of the EU scheme for South Africa that that provided in chapter 2, noting in particular the potential impact of the scheme on the competitiveness of South African products within the EU market. (Note: It had been anticipated that this chapter would use the recent FRIDGE study on non-tariff barriers as a point of departure, but unfortunately this study was not made available to the consultants during the course of Phase I. This report will be used in Phase II of the study).

4.1 Environment and the EU

The legal basis for the EU's environmental policy is found in the Treaty on European Union, articles 100a, and 100r to 130t. Although the Treaty leaves scope for member states to introduce more stringent environmental measures than agreed upon at Union level, the express intention of EU policy is to:

• Preserve, protect and improve the quality of the environment;
• Ensure a prudent and rational use of natural resources;
• Protect human health; and
• Promote measures at international level to deal with regional or international environmental problems.

The EU's environmental policy has evolved since the 1970s, where environmental legislation was left predominantly up to the individual countries in Europe. Environmental policy was concerned principally with setting limits on emissions of specific pollutants, such as discharges into water systems and air emissions. By the 1990s these strategies broadened somewhat, and related to the regulation of consumption of natural resources, covering many environmentally sensitive activities. Individual member states were granted a certain amount of flexibility with regard to the implementation of such directives.

A EU Community Action Program, entitled Towards Sustainability, was devised for the period 1992-2000. It marked a significant shift for policy development, as it complemented legislation with the use of market-based instruments. The program also sought to integrate environmental considerations into a broad range of policy areas, its intention being to develop partnerships with shared responsibilities between government, business and consumers. The five key sectors that were targeted were industry, energy, transport, agriculture and tourism.

Key instruments of the EU's environmental policy include the following:

• Environmental Impact Assessments (EIAs): Directive that lays down the systematic procedure to be followed in the assessment of potential environmental damage of individual projects, and requiring public consultation in the process.
• Free Access to Information on Environmental Pollution: Directive that requires national authorities to make information on the environment available to all interested parties on request, without such party having to prove a direct interest.
• Eco-Labelling for Environmentally Friendly Products: regulation that enables a manufacturer or importer of a product to apply for an eco-label to the relevant Competent Body, which may be granted after a thorough assessment of the product.
• Eco-Audit: A voluntary environmental auditing scheme that is co-ordinated by Member States. It requires participating companies to incorporate environmental protection standards into their production processes.
• The LIFE Regulation. This programme is designed to provide financial incentives for EU priority projects in the environmental field.

4.2 History of the EU Eco-Labelling Schemes

Experiences with the growth of eco-labelling in the EU have been varied. The German national eco-label, the Blue Angel, is the oldest of all eco-labels, having been founded in 1977. It has achieved wide-spread success in its home country, with a total of over 3.500 products having obtained the relevant certification. It also covers over 80 product lines from 11 product categories, which is by far the widest product range of all the European eco-labels. Its only exclusion is food and pharmaceuticals. As such, it has achieved significant consumer uptake and awareness in the home market. The mark is entirely voluntary and has increased environmental awareness of both producers and consumers. Uptake of the Blue Angel is predominantly by German applicants, although a significant number (approximately 15% of the total) of foreign produced products have obtained the eco-label.

The European Union eco-label is in many instances similar to Germany's Blue Angel, having been introduced 15 years later, in 1992. This follows the increasingly close co-operation and the systematic alignment of the policies of the European Union member countries. As intra-regional trade barriers within the Union were removed, the individual markets effectively grew into a single market of some 340 million consumers. It no longer made sense to only have the numerous different National eco-labels, rather, a common EU-wide eco-label was called for.

Initially, the uptake of the EU label was very slow, due to the fact that progress was slow in developing ecological criteria for various product groups. A year after the establishment of the EU eco-label, ecological criteria had only been drawn up for one product category, namely dishwashers (1 company awarded label by 1992). A year thereafter, only a further 3 product categories were established (paper kitchen rolls, soil improvers and toilet paper).

To date, Denmark has the largest number of companies that are using the EU eco-label (22), closely followed by France (20). Italy (18), Spain (13) Greece (9) and Sweden (8) have a fair number, although in the wider context, this numbers are indeed very low. It is interesting to note that the uptake of the EU eco-label by German (2) and Dutch (2) applicants still lags far behind. However, this can probably be explained that both these countries have well-known and successful National eco-labelling programs, which themselves have achieved wide-scale national (and even Europe-wide) recognition. The strength of this label is certainly its European dimension, though. Since it can be used throughout the EU, it eliminates costly and redundant multiple applications.

4.3 Eco-Labelling and Government Procurement

In the EU, the first directives on public procurement were adopted in the 1970s, and were aimed at increasing transparency and non-discrimination in the tendering procedures of the Member States. The specification of technical characteristics of goods and services to be procured by public institutions and governments are an integral part of any tendering process. Such specifications may include quality characteristics, performance, packaging, safety aspects, marking and labelling. These "technical specifications" thus include environmental characteristics that are used to determine environmentally preferable products.

According to a 1999 OECD document on trade issues and the "greening" of public procurement, environmental criteria may in future become increasingly important co-determinants for government procurement exercises. Since "greener" goods for public procurement purposes have been mostly defined by their use or disposal characteristics, rather than production characteristics (e.g. stipulating maximum allowable energy consumption levels), they should not give rise to any serious trade effects.

Currently, where procuring authorities have been attracted to eco-labels, they appear to be more inclined to adopt certain of the label's ecological criteria, rather than relying on the labels themselves. The use of eco-labels to designate environmentally preferable products for public procurement is not (yet) particularly widespread. There is concern, though, that this situation may change in the near future, and eco-labels becoming part of the public procurement process (especially as more and more eco-label product categories are drawn up). This could favour domestic firms over foreign enterprises, and larger firms over SMEs, in the process.

EU public procurement rules require the use of European standards, or in their absence, national standards. Only under limited circumstances may contracting parties depart from European standards, for example where the use of European Standards would necessitate the contracting entity to acquire supplies that are incompatible with equipment currently in use, at disproportionately high cost.

4.4 Operation of the EU Flower

4.4.1 Overview of Legislative Arrangements to Implement the EU Eco-Label

The EU eco-label (also known as the EU Flower, or EU "Daisy") was established in 1992 by Council Regulation (EEC) No. 880/92 of 23 March 1992. In 2000, this regulation was revised significantly, with a new Regulation (EC No 1980/2000) significantly extending the original scope of the scheme. The new Regulation streamlined the scheme and introduced services into the fold of categories that can obtain the EU eco-label. It also revised the fee structure for applicants (announcing a reduction in fees), and increased the Scheme's transparency through greater stakeholder involvement. Provision was made for a review of the EU eco-labelling scheme before September 2005.

Specifically, the new Regulation deals with the objectives of the EU eco-label, its administrative structures and fees of the label. Its salient features are:

• Widening the scope to cover services as well as products.
• Reinforced stakeholder participation, in particular in developing the environmental criteria.
• The creation of the EU Eco-labelling Board, comprising of the Eco-label Competent Bodies and interest groups, whose main role is to develop the Eco-label criteria.
• Reduced fees for SMEs and developing countries.
• Introduction of a ceiling on the annual fee.
• Reinforced transparency and methodology.
• Renewed emphasis on the promotion of the scheme.
• Reinforced co-operation and co-ordination with the national Eco-label schemes.
• More information on the label.
• Possibility for traders and retailers to apply directly for their own brand products.
• Possibility for non-EU producers to apply directly (to the Competent Body of their choice, where a product is to be marketed in more than one country).

4.4.2 Existing Eco-Labelling Product Categories and Categories under Development

The Working Plan drawn up by the European Union Eco-Labelling Board foresees that ecological criteria for a further 25-35 product groups will be developed within the next 3 years. According to the EU this would form a sufficiently complete and manageable range of products to attract new stakeholders. The scheme has so far established ecological criteria for 17 major product groups (including textiles and footwear, several detergent groups, several household appliances, several paper products, paints and varnishes and soil improvers and growing media). The largest number of applicants are from the textile industry (37), followed by manufacturers of indoor paints and varnishes (27), and tissue paper (8). Judging by the progress made so far, and the process involved (including wide stakeholder consultation), this would appear to be an overly ambitious target.

All of the existing product categories of the EU eco-label consist of either household items or office equipment. They include items of a personal nature (e.g. tissue paper, cleaners for sanitary equipment), household cleaning agents (laundry and dishwasher detergents), household equipment (washing machines, refrigerators) and office equipment (personal computers, photocopiers). A comprehensive list of all product categories for which eco-labels have been awarded is provided in Appendix 1. Product groups for which the ecological criteria are currently under development, include both household items and services.

Product Group	Status
Hard floor coverings	Ecological criteria under development
Vacuum cleaners	Ecological criteria under development
Tourist accommodation	Ecological criteria under development
Furniture	Ecological criteria under development
Tyres	Feasibility study completed
Rubbish bags	Study completed
Converted paper products	Study completed, work suspended
Batteries for consumer Goods	Study completed, work suspended

According to the Commission Decision 2002/18/EC, which established the EU eco-label Working Plan, the following new product groups will initially be considered for the development of ecological criteria. In most cases they continue to be consumer goods with much relevance, in addition to them being product categories where the combined environmental impact may indeed be significant. Most notably, though, they follow the trend set by the Germany's Blue Angel in that they increasingly include service sectors. By expanding and broadening their coverage, the product categories also appear to be increasingly encroaching on industries with high international trade volumes, including the automotive industry, toys and games, and fashion accessories.

Table 2 - New Product Groups Planned for the EU Eco-Label (as per European Commission Decision 2002/18/EC of December 2001)
Printing paper	Printed paper products
Converted paper products, stationary	Wallpaper
Rubbish bags / plastic bags	Shopping bags - carrier bags
Writing implements	Telephones
Copiers	Small household electrical equipment
Fashion accessories	Gloves
Leather products	Sports equipment
Toys and games	Packaging
Do-it-yourself products	Air conditioners
Heating systems	Water-heating systems
Insulation	Building components
Building services	Retail services
Dry cleaners	Financial services
Transportation services	Delivery services
Vehicle repair services	Cars
Kitchenware, household fittings etc.	Sanitary products (towels and napkins, etc.)
Shampoo and soap

4.4.3 How are the Product Group Criteria developed?

• The functioning the Eco-label scheme consists of distinct phases. Preparatory work and the establishment of new criteria generally lie with one or two so-called "Lead" Competent Bodies, although the initiative for selecting product groups and individual products is taken either by the European Commission, or by the European Union Eco-labelling Board (EUEB). The actual decision whether to award the label lies with the relevant Competent Body, as per Article 7 of Regulation 1980/2000 of the European Parliament.
• The EUEB is the central governing body of the EU eco-label, and was established pursuant to the above-mentioned directive (EC 1980/2000). It consists of the Competent Bodies, as well as various stakeholders from industry, environmental NGOs and consumer bodies (which make up the Consultation Forum). Criticism by EU Member States and interest groups for greater consistency in the choice of product groups and development of ecological criteria has lead to key interest groups (industry, SMEs, retailers, consumer organisation, trade unions, environmental protection agencies) being consulted more extensively in the drawing up of a "Working Plan". The Working Plan spells out the choice of future product groups, and envisages developing approximately 30 additional product categories over the next 3 years. As decisive stakeholders of the EUEB, they are thus invited to continue to play an increasingly active role in promoting and developing the EU eco-label.

The following procedure is followed in the development of criteria for a new product group:

• The Commission provides the European Union Eco-labelling Board (EUEB) with the mandate to develop the ecological criteria for a particular product group. An Ad-Hoc Working Group (AHWG) involving the relevant interested parties (retailers, industry and consumers) and the Competent Bodies is set up for this purpose within the EUEB.
• One or two of the Competent Bodies, which make up the EUEB, are chosen as Lead Competent Bodies to leads this process. The AHWG drafts the ecological criteria for the proposed eco-label, taking into account the results of the preparatory work completed by the Lead Competent Body. These results are obtained from:
• A feasibility and market study: This study is carried out to collate data on the following aspects: the market structure and the various types of product groups in the EU market, the opinions of interested parties, key environmental impacts and key elements relating to the product's fitness for use, an inventory of eco-labels, standards, test methods and studies.  Consumer perceptions, functional differences between types of products and the need for identifying subgroups will also be assessed. 
• A report on the relevant life cycle considerations
• An environmental improvement analysis
• The draft ecological criteria and necessary compliance criteria are then discussed with the entire EUEB, ensuring transparency.
• The Commission is informed of the draft criteria and decides whether the mandate has been fulfilled or whether the work should continue.
• Once the final draft criteria is ready, it is presented to a Regulatory Committee of experts from the Member States for its approval.
• The approved criteria are adopted as a Commission Decision by the European Commission and published in the L series of the Official Journal.

Since these procedures are intended to ensure that all the environmental considerations have been taken into account, and that all the relevant stakeholders have participated, they can take several months to complete. The Eco-Label Competent Bodies, which are considered independent and neutral, have been designated by the Member States to implement the Community Eco-label scheme at national level or regional level once the ecological criteria have been developed.

4.4.4 Harmonisation Activities in the EU

The removal of technical barriers to trade (TBTs) is an important pre-condition for the successful functioning of the European internal market. In 1985, the EU adopted a new approach towards technical harmonisation of European industry standards in the different areas covered by EU technical legislation. This new approach recognises the importance of using harmonised standards as a guarantee of quality, especially with regard to the essential safety requirements established by the 'Directives'. Up until 1985, technical harmonisation activities were based on a case-by-case approach, frequently containing very detailed specifications with approval procedures that were difficult to implement. It was the responsibility of the individual EU Member States to issue certificates of conformity; often, the results obtained were unsatisfactory and recognition thereof depended largely on the confidence that the various national authorities were able to show in each other.

The new approach formulated in 1985 - the most fundamental elements of which relate to the essential requirements and procedures necessary for assessing conformity - has enabled the previously mentioned difficulties to be overcome. The new EU legislation is now restricted to the establishment of minimum requirements that have to be met by the various product groups. Technical specifications meeting these essential requirements are thus developed on the basis of the new approach to technical harmonisation and standardisation set out in the applicable EU directive (Directive 83/189/EEC). Harmonisation certification procedures and the associated rules governing their use are set out in EU Decision 93/465/EEC.

The function of drawing up harmonised standards (that define the technical specifications needed by manufacturers in this context) is entrusted to the EU standardisation organisations. These are CEN (European Committee for Standardisation), CENELEC (European Committee for Electrotechnical Standardization) and ETSI (European Telecommunications Standards Institute). While standards are voluntary, (unlike other essential requirements), products manufactured in accordance with them are assumed to comply with the essential requirements of the Directives. National standardisation authorities (present in the various Member States) are required to confer the status of a national standard to the adopted harmonised standards. Also, national standardisation authorities are required to withdraw any conflicting national standards. The national standardisation authorities, as well as the Official Journal of the EC, publish a reference list of harmonised standards. The reference list to harmonised standards currently contains 18 Directives.

The existence of various national eco-labels in Europe (such as Germany's Blue Angel, the Nordic countries' Nordic Swan and the Dutch Stichting Milieukeur) - in parallel to the development and existence of the EU-wide eco-label, has raised various issues with regard to their consistency, comparability and compatibility. This is especially so since the national eco-labels surpass the EU label in terms of product coverage, uptake and levels of consumer awareness (particularly in their respective home markets).

In terms of Paragraph 16 of the EU Regulation 1980/2000, which substantially revised the EU eco-labelling program in 2000, specific mention is made of co-ordination between the EU eco-label and the various national programs:

"While existing as well as new eco-label schemes in the Member States may continue to exist, provision should be made to ensure co-ordination between the Community eco-label and other eco-label schemes in the (European) Community, in order to promote the common objectives of sustainable consumption."

Since the progress towards a single market in the EU, which was to a significant extent achieved with monetary union early in 2002, this has increased the need for a common eco-label that prevents confusion amongst consumers and manufacturers. The underlying idea behind the creation of the EU eco-label was to ensure consistency in the application of environmental criteria across Member States. The EU eco-label, being the result of a common EU policy, is thus intended to become the environmental reference with regard to consumer products. As per Paragraph 16 (cited above), this does not mean that national eco-labels and the EU eco-label cannot co-exist; however the regulation requests Member States and the European Commission to ensure co-ordination between the EU eco-label and other national schemes, particularly in the selection of product groups and the development and revision of the criteria. Where a product has been awarded both with a national and the EU eco-label, both such logos will be displayed side by side on the product.

4.4.5 Nature of Marketing and Promotional Activities of the EU Eco-Label

The EU eco-label has not achieved the success in terms of market penetration as envisaged when it was created in 1992. A general lack of awareness of the scheme, the prominence of some national eco-labelling programs and other factors contributed to this. Even today, the scheme has not been an unqualified success, notwithstanding the fact that a fair number of product categories have by now been developed. There certainly has not been a stampede of manufacturers, retailers and importers applying for the right to apply the EU eco-label.

However this situation appears to be changing, judging by the rising levels of awareness (especially throughout the EU) of the label, and the rapidly increasing number of successful applications for a EU eco-labels in 2001. During this year, the number of manufacturers using EU eco-labels doubled to over 100 companies (103 companies as of May 2002), comprising over 400 products. According to the EU Eco-Label Secretariat, approximately 17 million products (with an ex-factory value of 38 million Euros) bearing the EU eco-label were sold in 2000. This is due to a number of reasons, including the fact that the range of product categories for which ecological criteria have been developed have increased, and marketing efforts and awareness campaigns accelerated.

A comprehensive work plan has been drawn up for the EU eco-label, enforcing and co-ordinating all the marketing efforts of the individual EU Eco-Labelling Board (EUEB) stakeholders. During 2000, the budget for marketing activities of the label was approximately 40% (1 million Euros / R10 million) of the total budget of approximately 2.5 million Euros. The individual countries Competent Bodies contribute approximately 70% to the total.

Marketing activities undertaken by the European Commission and the individual Competent Bodies are undertaken on various levels, and aim to promote the scheme and significantly enhance both producer and consumer awareness. In 2000, a total number of 37 persons were working fulltime for the EU eco-label, 7 at the European commission level, and 30 for the Competent Bodies.

These marketing activities include:

• Publication of the info-kit (15 product fact sheets for producers, 9 product leaflets for consumers, application guide, consumer guide, business fact-sheet) aimed at producers and consumers.
• General Information brochure "The European Eco-Label at a Glance" in all the official European languages.
• The "Flower News" (every four months).
• Publications in the European Environment Newsletter
• Publications in different magazines.
• Production of different promotional materials, including posters, pins, shopping bags, T-shirts and mouse pads for the different promotion activities in the 14 Member States.
• Installation and financing of the eco-label "Helpdesk" which has the task of answering the inquiries and supports the European Commission in their promotional activities. While most enquiries to the Helpdesk have originated inside the EU, numerous information enquiries were also received from outside the EU, including South Africa, USA, India, Malaysia, South Korea, Sri Lanka, Mexico, Pakistan and Indonesia.
• Installation and updating of the website (http://europa.eu.int/comm/environment/ecolabel) that provides full information on the EU eco-label. This site currently receives approximately 60.000 visits a month.
• Presentations at public occasions and special events ("Green Week", Environmental Award Ceremony etc.)
• Launching and Financing of marketing campaigns in the Member States (the latest in Greece and Spain).
• The Competent Bodies are in charge of the promotion of the scheme at the national level. For example, Denmark recently launched a campaign to promote both the EU eco-label as well as the Nordic Swan (which enjoys wide coverage in the Nordic countries). Some Member States provide subsidies to producers to help them apply for an eco-label. This happens in, for example, the Netherlands and Catalonia (Spain). Some Competent Bodies have their own website for the promotion of the scheme.

On 21 December 2001 the European Commission (2002/18/EC) established the EU eco-label "Working Plan", in which it formally spelt out its marketing and promotion plan for the upcoming years. It deals with issues such as increased visibility of the label, stakeholder involvement, general and co-ordinated marketing activities, and its targets for levels of consumer awareness across the EU.

Table 3 - EU Marketing and Promotion Objectives

	Implementation Measures
Marketing & Promotion Objectives	2002	2003	2004
Co-ordinate marketing efforts and develop and implement joint actions	Form a permanent marketing management group. EUEB to meet twice a year to discuss marketing, promotion and strategic development of the scheme (Presidential meetings).	Identify the different key target groups and define and implement a strategy for each.	Continue.

Marketing & Promotion Objectives	Implementation Measures
	2002	2003	2004
Annual increase of at least 25% of eco-labelled articles Achieve a minimum level of visibility in two thirds of the Member States. Continuously inform all stakeholders about the eco-label and its developments. In parallel, seek feedback from stakeholders. All relevant manufacturers and retailers should be aware of the eco-label. More than half of European consumers should recognise the EU eco-label logo as a label of environmental excellence.	Undertake promotion. In each Member State, identify and focus marketing efforts on key product groups. In each Member State, identify and focus marketing efforts on key product groups. Update and improve design of the eco-label website. Organise and co-ordinate the development and distribution of brochures and other printed material. Draw up list of events where eco-label should be presented. Inform potential applicants about application procedures and costs. Set up reporting mechanisms to establish annual statistics for tracing market penetration. Develop the criterion for a minimum level of visibility of the eco-label, evaluate in which countries this has been achieved.	Undertake promotion Continue updating website, distributing brochures, attending events and informing about costs, etc. Develop a strategy and actions for SME support networks and strategic partnerships with retailers. Develop a cost-effective methodology for monitoring consumer recognition of the EU eco-label logo, and develop cost-effective actions for progressively increasing this.	Undertake promotion Continue updating website, distributing brochures, attending events and informing about costs, etc. Resources devoted to promotion should be at least 50% of those devoted to product group development.

4.5 The EU Product Categories - Implications for South Africa

In order to gauge the potential implications of the EU eco-label's product categories on South Africa, it needs to be estimated what the market access implications for South African-produced products could be. Since the "coverage" of the EU eco-label is the European Union, its impact on countries such as South Africa is only likely to be of consequence where the label could have an impact on trade relations between South Africa and the EU. Trade flows between countries have been increasing significantly over the past decade, and those between the EU and South Africa are no exception. The following sub-section therefore provide a general overview of general trade between South Africa and the EU over the period 1999-2001, and then follows with a more specific analysis of South Africa's trade performance with the EU of the EU eco-label equivalent South African manufacturing sectors. Those EU countries, which have been the destination of South African-produced products in the equivalent sectors over the 1999-2001 period, are identified and ranked.

4.5.1 Nature of Trade between South Africa and the EU

The European Union is South Africa's most important trade partner. In 2001, the EU accounted for approximately 37% of all exports leaving South Africa, while being the source of 41% of South Africa's imports. Of the 14 EU Member States, South Africa's most important export markets (in decreasing order) are the United Kingdom, Germany, The Netherlands, Belgium, Italy, France and Spain, which together are the destination of approximately 95% of all exports to the EU.

An overview of trade between the EU and South Africa is provided in Appendix 3. Closer analysis of South Africa's exports to the EU reveals that approximately 25% of these exports consist of coal (HS27 category) and gold, diamonds, platinum (HS71 category). For the purpose of this analysis, the category definitions of the HS (Harmonised Commodity Description and Coding System) were used. The (HS) of the Customs Co-operation Council (CCC) is used worldwide as a reference for classifications of external trade statistics and for customs tariffs. The third largest export category consists of machinery (including those for household use) and parts thereof, a category falling under manufactured exports. Motor vehicles (and parts thereof) contribute approximately 9% of total exports. Other important manufacturing / industrial sector categories (as opposed to mining and agriculture) include electrical motors (HS85), paper and related articles (HS48), organic (HS29) and inorganic chemicals (HS28), articles of iron or steel (HS73) and fertilisers (HS31).

Overall, manufactured exports account for over 60% of South Africa's exports to the EU. Exports to the EU thus play a highly important role from the perspective of South Africa, since a relatively large proportion consists of products other than minerals and agricultural products. Manufactured products typically have higher value-added than other output. The trade statistics also indicate that South Africa's exports to the EU grew by 50% (nominal) between 1999 and 2001, proof that South Africa is making significant progress in terms of export market penetration. In terms of the SA/EU Trade Protocol, tariff-based trade barriers will continue to be downscaled over the next decade, although the potential clearly exists that technical trade barriers (including eco-labels) could in future restrict export growth.

4.5.2 Specific Analysis of SA-EU Trade in the EU Eco-Label Equivalent Sectors

In order to obtain a better impression of the potential impact that the EU eco-label could have on South Africa, trade between South Africa and the EU in the product categories for which an EU eco-label exists was analysed. For this purpose, the statistical HS codes for the relevant products were determined, and it was found that in most cases the generic description of the 18 product categories (for which ecological criteria have been developed) could be closely matched with one (or more) HS 4-digit codes. In the case of textile products, which refer to products made of textiles (i.e. garments), the entire HS63 category (i.e. knitted and woven clothing) was used for purposes of analysis.

As can be seen in the table, the results show that, with the exception of "Tissue Products", every eco-label "equivalent" product category manufactured in South Africa is exported to the EU. The category with the highest volume of South African exports, namely "Textile Products", is exported to over half of the EU Member States, including the UK, Italy, France, Germany and The Netherlands. It should be noted that the EU eco-label has been awarded most often within this particular product category, as well as the fact that French and Italian producers form the largest group of successful EU eco-label applicants.

For most product categories, the equivalent South African-manufactured product is exported to at least four or more EU Member States. In two examples, namely "Light Bulbs" and "Bed Mattresses", a large proportion of South Africa's total exports of that product category go to the EU. In the case of "Bed Mattresses" and "Light Bulbs", the UK is South Africa's single largest export destination, accounting for 25% and 40% respectively.

Although only a portion is sold to the EU, the total value of exports of the equivalent product categories for which the EU eco-label criteria have been defined, amounted to R 6,126 billion in 2001 (significantly, this is a 50% increase from 1999).

Table 4 - Analysis of Trade Between SA and EU in EU Eco-Label Equivalent Sectors

EU Eco-label Product Categories	Number of Labelled Products with EU Eco-label	Trade: Equivalent HS Chapter coverage	Trade: Equivalent HS 4-digit code coverage	South Africa's Worldwide Exports inEquivalent Categories (R'000)			EU Importers of Equivalent South African-producedexports
				1999	2000	2001
Tissue Paper Products	8	48	4803	52,401	55,925	62,144	none to EU
Textile Products	37	62-63	6200-6310	1,027,037	1,455,339	1,929,412	UK, Italy, France, Germany, Netherlands, Belgium, Ireland, Austria
Dishwashers	1	84	8422	68,587	93,701	90,025	Belgium, UK, Netherlands, Germany
Soil Improvers	7	31	3101-3105	948,362	928,382	1,078,843	France, UK
Footwear	4	64	6401-6406	115,275	119,950	111,376	UK, France, Portugal, Germany, Netherlands
Bed Mattresses	4	94	9404	32,426	29,429	39,758	UK (note: 25% of world total in 2001)
Indoor Paints & Varnishes	27	32	3208-3210	80,425	75,667	104,015	Netherlands, UK, Greece, France, Germany
Laundry Detergents	3	34	3402	125,932	119,367	146,513	UK, Netherlands, Portugal, Greece
Light Bulbs	1	70	7011	626	2,106	3,421	UK (note: 40% of world total in 2001)
Detergents for Dishwashers	6	34	3402	125,932	119,367	146,513	UK, Netherlands, Portugal, Greece
Copying Paper	2	48	4802	586,330	582,991	701,995	Belgium, UK, Germany
Refrigerators	2	84	8418	174,101	216,003	235,649	Denmark, Netherlands, UK, Greece
Hand Dishwashing Detergents	1	34	3402	125,932	119,367	146,513	UK, Netherlands, Portugal, Greece
Televisions	0	85	8528	91,670	140,695	209,395	UK, Netherlands, France, Germany
All Purpose Cleaners and Cleaners for Sanitary Facilities	0	34	3401	153,072	199,394	314,148	Belgium, Netherlands, UK, Greece, France
Washing Machines	0	84	8450	7,075	5,655	7,525	UK
Portable Computers	0	84	8471	296,131	364,305	454,998
Personal Computers	0	84	8471	296,131	364,305	454,998
TOTAL (excl. double counted categories)				4,133,113	4,968,606	6,126,599
Source: DTI Trade Statistics Database / Department of Customs & Excise (2002)