The sustainability of goods and services is of increasing public concern. No product or service is delivered without an environmental or social cost. Many consumers are beginning to base their purchasing decisions not only on quality, price and availability, but also on the environmental and social impacts associated with the product or service. Therefore, sustainability plays a significant role in consumer product policy and standards.

Work Areas:

1) Chemicals

The work programme of the Sustainability sector also includes the ANEC strategy on how to reduce exposure from hazardous chemicals in consumer products. In addition to the actions planned regarding sustainable consumption and production policies, ANEC has a specific interest in the EU strategy on Chemicals for sustainability to achieve a non-toxic environment.

Please see more on the Page on Chemicals.

2) Sustainable Consumption and Production

ANEC focuses on consumer and health related concerns with regards to the EU environment policy priorities, following the implementation of the seventh EU Environment Action Programme (7EAP) and the continuation of respective activities in the Eighth Action programme. Better application of existing technologies and more consideration of the environmental implications in the product design stage can make an enormous contribution to environmental protection. ANEC has long since focused on the consumer expectations from the European Sustainable Consumption and Production (SCP) policies.

Also, in light of the amount of information consumers are bombarded with when purchasing (green) products, consumer organisations warn that consumers should not be expected to take all the responsibility for overconsumption and consequent excess of waste. In our activities, we have advocated instead for an enhancement of the EU environmental related product regulation establishing performance requirements using synergies between different existing environmental instruments.

ANEC contributes its views in the debate on consumer challenges in the green transition in the context of the Circular Economy Action Plan and the implementation of the Green Deal.

ANEC keeps calling for the level of ambition of existing SCP policy tools such as Ecodesign, the Ecolabel and the Energy label to be maintained and enhanced, particularly as part of the recently announced Sustainable Product Initiative which aims at making products placed on the EU market more sustainable through a more ambitious Ecodesign Directive and additional legislative measures.

Ecodesign and Energy labelling

ANEC collaborates with BEUC, the mainstream European consumer organisation, in defending and representing the consumer perspective in the implementation of the Ecodesign Directive and the Energy labelling of consumer products.

ANEC also works with ECOS – the European Environmental Citizens’ Organisation for Standardisation – in a project to represent environmental and consumer NGOs in Ecodesign related standardisation.

To find out more about these projects, please visit ANEC website page on Energy and Ecodesign

Circular Economy

We all agree that resources are finite and sooner or later the limits to further growth of material and energy flows will be reached. ANEC calls for the EU actions on Circular Economy to contribute to the desperately needed fundamental change of direction associated with significantly reduced resource use, as opposed to a concept of infinite growth enriched with circular flows.

In ANEC position paper on Circular Economy, we stress the discussion on circular economy risks being misled from the onset if we lose the key aim of a strategy leading to sustainable development. The final objective remains socially acceptable reduction of the use of resources, and of environmental and human health impacts. There is also a need to develop measures based on meaningful, robust and verifiable indicators, and we believe policy measures should bring about changes in the foreseeable future. We call for a ‘resource-saving economy’ including circular elements, rather than reversing the order and going for a ‘circular economy’ in which resource saving is a mere side aspect.

3) Environmental labelling

Environment-related labelling schemes need to provide clear and unambiguous information if they are to support consumer choice. This is not the case at the moment where there is an overload of information on environment-related labelling schemes and where inconsistencies exist. It is also important to provide clear scales of comparison, as in the case of the EU Energy Label. In addition to LCA-based information, important additional environmental information from other sources should also be taken into account (such as the impact on human health, risk assessment, eco-label criteria and declaration of chemicals), and such information should be displayed in formats that clearly indicate the relative magnitude of the environmental impact of one product compared to another one.

ANEC has long been active in the ISO committee on environmental management standardisation ISO/TC 207. We are concerned that the enforcement of, and compliance with, environmental standards - and labelling schemes in particular - vary between Member States across the EU. This issue is of great importance to consumers because, without independent validation of manufacturer claims, the reliability of label information cannot be checked and the schemes are open to abuse. Furthermore, if the label is not displayed correctly, the consumer cannot make an informed choice.

Environmental Footprint


The European Commission carried out ‘Environmental Footprint (EF) pilots’ in view of having a harmonised methodology for the calculation of the environmental footprint of products, services and organisations based on a Life Cycle Assessment (LCA) approach. More than 20 pilots were carried out by groups of organisations, who volunteered to develop the rules for their product or sector having both Product EF pilots and Organisation EF pilots. Following the pilots, a transition phase started and the European Commission is investigating the use of the method to substantiate green claims and if and how elements of the EF methods can be integrated in Ecodesign and Ecolabel instruments.

ANEC, as well as industry stakeholders, strongly opposes the use of Product Environmental Footprint/Organisation Environmental Footprint as the basis for SCP instruments and environmental labelling schemes. Studies conducted by ANEC have highlighted the methodological constraints of the LCA approach such as lack of precision, limited comparability, difficulty to identify superior products or omission of relevant environmental aspects. For example, an ANEC study on environmental product indicators and benchmarks in the context of environmental labels and declarations, showed that indicators based on LCA methodology may not be the best option to suitably characterise and declare the environmental performance of a product. Life cycle assessment is a suitable tool for orientation at the onset of indicator development or regulatory requirement setting. However, suitable production, consumption or disposal indicators are typically more robust and in many ways, more meaningful or relevant, as well as cheaper. They can also be measured and are easier to verify.

In its position paper 'Environmental Assessment goes astray: A critique of environmental footprint methodology and its ingredients', ANEC criticised that many LCA indicators are used for advertising, but do not necessarily provide sound information to help consumers to choose an environmentally-friendly product. We confirmed that LCA methodology features fundamental shortcomings, including the dependency on numerous subjective choices, lack of adequate data and limited precision, and is not suited to adequately address certain environmental impacts. ANEC criticises Life Cycle Assessment (LCA) as a tool for the measurement of environmental impacts of products and organisations, and calls on the European Commission to re-think its approach to environmental assessment. ANEC put forward an alternative approach to that of the European Commission, also proposing a framework for the selection of environmental indicators. Although the critiques from ANEC and other stakeholders added delay, the Commission still published the package "Building the Single Market for Green Products”, encouraging private actors to use the environmental footprint methodologies on a voluntary basis. ANEC is following the European Commission ‘Environmental Footprint journey’ as it further discusses and explores potential future applications for the Environmental Footprint methods and use of Environmental Footprint Category Rules (PEFCRs) to substantiate green claims.

ANEC contributed to the EC IIA Roadmap for a Legislative Proposal on Substantiating Green Claims to address green washing and we shared concerns on the use of PEF for substantiating green claims.

ANEC welcomed the intention set in the Green Deal to tackle misleading green claims and that it recognises that consumers need reliable, comparable and verifiable information on the environmental performance of products and services. In our contribution to the Roadmap of the initiative, we expressed disagreement, however, that the substantiation of claims should be done using the PEF/OEF method. This is based on our critical analysis of the LCA and Product Environmental Footprint methods and their use in characterising and communicating the environmental performance of products and activities. We urge a different approach is taken.

In ANEC paper on substantiation of green claims initiative we put forward a suggestion for an alternative approach on how to substantiate green claims, with a regulation that could specify in detail the conditions and binding requirements for use of specific terms, based on the principles of ISO  14021 ‘Environmental labels and declarations —Self-declared  environmental claims (Type II environmental labelling).  

4) Sustainable Construction

Construction products should not pose a threat for the occupants of the building or the environment. Standardisation in construction facilitates the equal assessment of environmental, economic and social aspects of sustainability of construction products, buildings and services. Also, the communication to the consumer, preferably by labelling, plays an important role. The ambition of ANEC is to establish a harmonised and coordinated EU policy which leads to a significant reduction of all environmental burdens associated with buildings and takes into account the interests of both business and consumers.

ANEC highlights the need for a single European concept of sustainability in buildings, which would involve all relevant actors and include ongoing activities, in order to develop a suitable framework to address environmental issues in the construction sector using a broad range of instruments. We advocate work on European building-related specifications to establish criteria based on well-established national building schemes. These include European tools, such as the Green Public Procurement (GPP) Product Sheet Construction. The ANEC position paper ‘Sustainable construction - A building site without end. Alternatives to flawed standards’ gives further details on our standpoints.

ANEC submitted a Not-Favourable Opinion in the Formal Vote on FprEN 17672 ‘Sustainability of construction works - Environmental product declarations - Horizontal rules for business-to-consumer communication’. Disappointingly, the standard was adopted in 2022, despite this opposition from the consumer voice in standardisation.

We do not think the standard, drafted by CEN/TC 350 ‘Sustainability of construction works’, provides for provision of reliable, comparable or clear information to consumers. This follows our long-standing opposition to B2C communication based on Environmental Performance Declarations (EPDs), and builds on the ANEC commentary, ‘Sustainability in the construction sector. a consumer perspective on relevant standards and initiatives' (

European standardisation of sustainable construction (products)

For several years, ANEC was active in CEN/TC 350 ‘Sustainability of construction works’ and its Working Group 3 ‘Product level’. Considering the limited reflection of consumer concerns in the work over the years, we now only monitor the activities.

ANEC believes that the goal of standardisation work in TC 350 should be the equal assessment of the environmental, economic and social aspects of the sustainability of products, buildings and services, and its communication to the consumer (preferably by labelling). Specific stipulations that lead to comparable results are needed. The results of the standardisation work have been disappointing from a consumer perspective and, in particular, we believe EN 15804:2012 Sustainability of construction works. Environmental product declarations. Core rules for the product category of construction products unacceptable. We expressed our views in the ANEC paper: ‘Sustainable construction - A building site without end. Alternatives to flawed standards’.

Separately, ANEC was also involved in the development of Ecolabel criteria for buildings and EMAS - EU Eco-Management and Audit Scheme sectoral documents for buildings. ANEC has especially welcomed the latest draft of the EMAS Reference Document, 'Best environmental management practices' (BEMPs) in the construction sector, developed by the Institute for IPTS of the European Commission Joint Research Centre. The document takes into account the findings of the ANEC study on environmental & health-related criteria for buildings. It provides an overview of the common specific indicators for the construction sector and derived benchmarks. ANEC continues to collaborate on the issue of indoor air quality in the context of the Construction Products Regulation.

Environmental Performance of Buildings

In our position paper 'Laying the foundations for sustainable buildings', ANEC calls for a European strategy on sustainable construction, with the aim to achieve the reliable sustainable performance assessment of buildings, provision of meaningful measurement indicators, and dependable information to consumers and construction professionals. ANEC believes energy performance remains crucial for the overall environmental performance of buildings, as we highlighted in our contributions to the earlier Evaluation of the Energy Performance of Buildings Directive.

ANEC notes that a more consistent and harmonised methodology is required to improve the reliability of certificates for the energy performance of buildings. It is important to streamline the variety of calculation methods used in Member States, as well as the various indicators used in energy performance certificates. Such rationalisation should derive from an open discussion on the strategies, concepts, environmental indicators and benchmarks that should be pursued to achieve a truly sustainable buildings sector.

In the framework of the resource efficiency debate, we also outlined the consumer perspective in a paper on the common EU framework of core indicators for the environmental performance of buildings.

The European Green Deal has a strong focus on sustainable construction and foresees the assessment of national long-term renovation strategies under the Energy Performance of Buildings Directive (EPBD). ANEC sees the planned revision of the Energy Performance of Buildings Directive (EPBD) as an opportunity to promote truly sustainable construction. In our new position on the Revision of the Energy Performance of Buildings Directive – IIA Roadmap, we explain in which ways ANEC believes the revision of the EPBD can introduce improvements.

We focus on seven areas:

  • Update of the framework for Energy Performance Certificates
  • Phased introduction of mandatory minimum energy performance standards for different types of buildings
  • Introduction of Building Renovation Passports
  • Introduction of a ‘deep renovation’ standard
  • Resource efficiency and circularity principles
  • Reducing energy poverty
  • Facilitating sustainable mobility

Following the Communication on the European Green Deal, the Commission is also considering review of the Construction Products Regulation to ensure the design of buildings is in line with the needs of the circular economy, and specifically with a view to enforcing the legislation related to the energy performance of buildings. ANEC contributed its perspective both to the ‘Consultation on the Renovation Wave initiative for public and private buildings’ and the Commission consultation on “Future Options for the Review of the Construction Products Regulation (CPR)”.

Smart LivingEPC project – Next generation EPC scheme to decarbonise the European building stock

ANEC is a member of the SmartLiving EPC project, a three-year long European project that will ensure the next generation of energy performance assessment and certification schemes will help achieve climate neutrality of the building stock by 2050.

The consortium is funded by the European research programme, HORIZON 2021, as part of the call for “Efficient, sustainable and inclusive energy use”. The 16 partners of the consortium have started working together to deliver a new certificate scheme, based on existing European standards and standards to be developed. It will also extend the scope of the certificates to non-energy related aspects, such as water consumption and noise pollution. We believe it key that energy performance assessment and certification schemes work with non-energy performance data linked to the building’s life cycle, as together they can improve health and welfare.

ANEC participates in tasks relating to standardisation, coordinates exchanges with similar projects, and disseminates results to CEN-CENELEC and ETSI.

More details can be found on the related ANEC webpage.

5) Sustainability information of companies & products

Corporate Social Responsibility reporting

Current CSR reporting schemes are not fully comparable and often impeding reliable benchmarking. In our position paper on Corporate Social Responsibility (CSR) reporting, we argue that an ineffective reporting scheme can trigger greenwash or the advertising of pseudo-sustainable products and services.

ANEC believes a European approach to corporate accountability reporting should therefore commence with guidelines for non-financial reporting. A first set of requirements and indicators could be built upon, supported by more detailed and comprehensive reporting requirements and indicators later. The broad discussion needs to take place in a democratic multi-stakeholder platform. We also included our requests in our contribution to the Directive 2014/95/EU on disclosure of non-financial and diversity information by large companies and the related non-binding guidelines on methodology for reporting non-financial information, i.e. for disclosing environmental and social information.

Standard on sustainable and traceable cocoa

ANEC has been active in CEN TC 415 ‘Sustainable and Traceable cocoa’ / ISO TC 34 SC8 ‘Cocoa’ in order to promote the position that consumers have the right to make informed choices and that products claiming sustainability need to achieve a certain quality level regarding sustainability aspects. The committees aimed at developing three standards - one on sustainability, one on traceability and one on the requirements for the certification of sustainable and traceable cocoa. It addresses in addition human and labour rights issues such as empowerment and access to education and literacy/numeracy. This work could lead by example on new standards about sustainability claims in other (food) products.

Sustainable Finance

In light of our work on sustainability information, ANEC also follows the European institutions activities on sustainable finance that follow the Sustainable Finance strategy and the entry into force of the Taxonomy Regulation. This regulation aims at setting the conditions for creating the list of activities that will be considered as green and to which private investments should be directed to fund the transition to a greener and more sustainable economy.

In parallel ANEC participates in ISO TC 322 ‘Sustainable finance’ to monitor the development of international standards in the field of sustainable finance to integrate sustainability considerations including environmental, social and governance practices in the financing of economic activities.

6) Integration of Environmental Aspects in Product Standards

The CEN Strategic Advisory Body on Environment (SABE) plays an important role in the development of positions based on discussions with relevant stakeholders. Participating in SABE’s activities is therefore crucial for ANEC. The CEN SABE ENIS (‘Environmental Issues in Standardization’) team focusses in particular on addressing environmental aspects in the standards for products and services). Further to our participation in SABE, we have also been promoting the greening of standards in the committees and working groups to which we contribute.

ANEC Austrian member also led development of CEN Guide 16, Guide for addressing chemicals in standards for consumer-relevant products. A video prepared by ANEC member that summarises and gives tips to standardisers on its use is available on CEN YouTube Webpage.

 7) Resource efficiency and waste

Resource efficiency has become one of the key political priorities of the Commission in order to move toward a resource-efficient, low-carbon economy. The Commission has been looking into possibilities to develop indicators for measuring resource efficiency.

ANEC believes resource efficiency indicators should make resource inefficiency visible, thus allowing requirements to be set through Ecodesign or other policy instruments in order to help lower costs for consumers during the use phase. The waste hierarchy needs to be the guiding principle, hence preventing early failure of products and rampant consumerism. To give a first priority to waste prevention means not only to give political support to durable and repairable products but also to substitute - wherever feasible and useful - disposable by reusable products (e.g. to give strong support to reusable packaging and discourage one-way and oversized packaging). Then, with a view to enhancing trustworthy recycling, it is crucial to ensure that no hazardous chemicals are contained in products.

The EU Circular Economy strategy aims at “transforming Europe into a more competitive resource-efficient economy, addressing a range of economic sectors, including waste”. ANEC position paper on the interface between chemicals, products and waste legislation "Keeping hazards in the circle?" – stresses it is crucial for the EU institutions to address the interface between chemicals, products and waste legislation, as a basis to develop policies that can deliver a circular economy which truly responds to the objective of the socially-acceptable reduction of the use of resources, and of environmental and human health impacts. ANEC also addressed the problem of contamination of waste, and products made from waste products, being not just limited to "legacy substances" but also related to substances not restricted in virgin materials and the products made from them. In particular, as mentioned above, the paper further highlighted the need to address gaps in legislation for chemicals in consumer products when analysing the interface between chemicals, products and waste legislation.

ANEC has contributed to DG Environment consultations on resource efficiency indicatorsplastic waste reduction, and in particular plastic bags, and we bring forward consumer requirements in this area, asking for reduction targets from a perspective that considers other elements, such as the durability of appliances. ANEC supports the notion of mandatory requirements on packaging optimisation and minimisation by strengthening existing instruments, in particular the Packaging Waste Directive.

Packaging waste prevention

ANEC was pleased to see the plans for Review of the requirements for packaging and other measures to prevent packaging waste. The initiative would result in particular in the review of the essential requirements in Directive 94/62/EC on Packaging and Packaging Waste (the ‘Packaging Directive’) in 2021. The Commission’s review will include assessing how to tackle excessive packaging, reduce packaging waste, improve packaging design to promote reuse and recycling and increase recycled content in packaging. We provided ANEC position on the Review of the EU requirements for packaging and other measures to prevent packaging waste’. In the area of packaging waste prevention, we also reminded of a study that was carried out by one of our member organisations after the publication of the CEN Standards in support of the packaging directive. The study established a quantitative prevention criterion for an acceptable surface/volume ratio and demonstrated the applicability for various product groups.

PROMPT Project - independent testing programme on premature obsolescence

ANEC is member of a consortium that implements the Horizon 2020 project, “PROMPT”, an independent testing programme on premature obsolescence. PROMPT is a four-year contract started in May 2019 and has the ambition to help extend the useful lifetime of products and to contribute to the transition to a circular economy. It aims at boosting durable design, providing access to repair services, upgrades and disassembly options. Furthermore, it intends to help reducing resource depletion, prevent waste generation and mitigate associated societal and environmental impacts. ANEC is expected to communicate the outcomes of the testing to the standardisation community to consider in the drafting or revision of European standards. You can find more details on the related ANEC webpage, and the projects’ dedicated website,

Activities in the European & international standards bodies:

ANEC is represented in, or monitors, the work of various Technical Committees dealing with environmental issues at both the European and international level:

  • ISO TC 207 ‘Environmental management’ 
  • CEN TC 415 ‘Sustainable and traceable Cocoa’ and ISO TC 34 SC8 ‘Cocoa’ (work completed)
  • CEN-CLC/BT WG 16SABE ‘Strategic Advisory Body on Environment’
  • CEN-CLC/BT WG 16/SABE/ENIS - Environmental Issues in Standardisation
  • CEN-CLC/BT WG 16SABE Topic Group Circular Economy
  • ISO TC 229 ‘Nanotechnologies’
  • ISO TC 323 ‘Circular economy’
  • ISO TC 322 ‘Sustainable Finance’
  • ISO/TC 322 WG 1 ‘Sustainable finance framework’
  • CLC TC 111X ‘Environment’
  • CEN TC 350 ‘Sustainability of construction works’
  • CEN TC 261 ‘Packaging' SC4 ‘Environment’ 
  • CEN/CENELEC JTC 10 on Energy-related products - Material Efficiency Aspects for Ecodesign
  • CEN Environmental Helpdesk (CEN/EHD)
  • CEN TC 352 ‘Nanotechnologies’

Ecodesign and energy related technical bodies are mentioned under: the ANEC web page on Energy and Ecodesign

European Commission groups:

  • European Commission Joint Meeting of Member States Groups on Integrated Product Policy (IPP/SCP) and Resource Efficiency
  • European Commission Integrated Product Policy (IPP/SCP) subgroup on the Environmental Footprint Transitions phase
  • EC Integrated Product Policy (IPP/SCP) Regular Group



On 19 & 20 July, ANEC participated in the kick-off meeting of the SmartLivingEPC project, hosted in Thessaloniki, Greece. Spanning three years, the project will ensure that the next generation of energy performance assessment and certification schemes will help achieve climate neutrality of the building stock by 2050.

The consortium is funded by the European research programme, HORIZON 2021, as part of the call for Efficient, sustainable and inclusive energy use. The 16 partners of the consortium will work together to deliver a new certificate scheme, based on existing European standards and standards to be developed. It will also extend the scope of the certificates to non-energy related aspects, such as water consumption and noise pollution. We believe it key that energy performance assessment and certification schemes work with non-energy performance data linked to the building’s life cycle, as together they can improve health and welfare.

ANEC will participate in tasks relating to standardisation, coordinate exchanges with similar projects, and disseminate results to CEN-CENELEC and ETSI.

Proposal for revision of the EPBD

ANEC recognises some improvements have been made to the EC proposal for revision of the Energy Performance of Buildings Directive ( compared with the present legal text.

However, there are still several points where we believe more ambition is required to effectively boost renovation of buildings in the EU, lower CO2 emissions and achieve more energy savings.

There is a need to act urgently and boldly on climate change. Time is of the essence. This can be done by not only improving the energy efficiency of buildings, but also by phasing out the use of fossil fuels and encouraging the generation of renewable energies on site (e.g. with solar systems).  Against this background, the EU climate targets can be supported through the EPBD revision by boosting the renovation rates in a manner that is truly suitable for the environment and (vulnerable) consumers.

We addressed the key issues in our response to the EC public consultation in March and we give specific recommendations in our new ANEC Position Paper on the EC Proposal for a Revision of the Energy Performance of Buildings Directive ( 


To access position papers related to Sustainability please click the link, Position papers.