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An appeal from the United Nations Environment Programme (UNEP) to the European Commission (EC) to
propose and implement the reduction of tariff and
non-tariff barriers (NTBs) on environmental goods and
services

As the leading global environmental authority, UNEP sees it as its prime responsibility to ensure it is promoting and working towards initiatives that are
sustainable for the environment, international trade and the people of the
world. For 15 years, we, along with other multilateral environmental agreements (MEA) Secretariats, have taken part in negotiations with the WTO in an
attempt to table and implement trade policies which future generations will be
able to perpetuate. Whilst we acknowledge the progress which has been made,
we also appreciate that the road to global market sustainability is a long one.
The negotiations among members of the WTO regarding the possible reduction of tariff and non-tariff barriers have sparked controversy and resulted in
rather narrow agreements, yet, the need for reform on trade barriers is imminent. UNEP places hope in the ability of the European Union (EU), as the
unmatched actor it has shown to be with regard to the regional and international debates around environmental conservation, to lead the way for
non-EU countries to follow. The UNEP brief below provides some reasoning
and recommendations for your consideration.

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BACKGROUND
Recognising that environmental protection and international trade policy are
inextricably linked1 (Skilton, 1993), negotiations on trade and the environment
within the Doha Development Agenda were launched at the Fourth World
Trade Organisation (WTO) Ministerial Conference in Doha in November
2001. The overarching aim has been to further strengthen the mutual support
of trade and environmental policies. The negotiations which have and are still
taking place, thrive for the reach a common objective which is to achieve sustainable development through the implementation of policies promoting and
sustaining trade, the environment, and development (Clancy and Kerwien,
2011). Subsequently, these negotiations have gravitated around three key points:
(a) the nexus between the WTO and MEAs; (b) the collaboration between the
WTO and MEA secretariats; and finally (c) the reduction and/or withdrawal of
tariff and non-tarrif barriers on environmental goods and services (ibid).
Deeply concerned by the urgent need for WTO member states to come to
agreements in the light of the imminent environmental crisis, consequent to
the unsubdued population growth, increasing resources scarcities and the shortcomings of political institutions (Hardin 1998, p.35), UNEP turns to the European Commission to take a step in the latter objective (c) as the great economic,
political and normative power which it is.

IMPORTANCE FOR THE EUROPEAN COMMISSION

We argue for the reduction and ideally the elimination of tariff and non-tariff trade barriers
for the following reasons:

It goes without saying that, whilst anti-dumping measures are sometimes open
to protectionist abuse (Davis, 2009), most of them show to have played in the
EUs economic interests, such as in the case of silicon and steel trade with China (www.debatingeurope.eu, 2015). In the situation currently being faced, it is
NTBs which seem to be causing controversy and divergences in negotiations at
1

The relationship between environmental preservation and trade policy manifests itself in
numerous different ways. International agreements have often resorted to trade measures to
protect global commons. In the past couple of years, policy research has tended to target the
question of international competitiveness, as it seems countries are increasingly concerned
that environmental standards of a certain level might harm their domestic industries within
international trade. (ibid)

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the international level. In the case of environmental goods and services, UNEP
(as well as the WTO) recognises three categories of NTBs: (a) the ones imposed
on imports (import quotas, import prohibitions, import licensing, and customs
procedures and administration fees); (b) the ones imposed on exports (export
taxes, export subsidies, export quotas, export prohibition, and voluntary export
restraints); and lastly (c) the ones which are imposed internally in the domestic
economy (health, technical, product, labor, environmental standards, internal
taxes and charges, and domestic subsidies) (www.wto.org, 2011). They are an
obstacle to free trade and consequently undermine the desired effectiveness of already existing EU policies, including the ones comprising
elements for the protection of the environment such as the implementation of
new sustainability criteria for biofuels post 2020 and the Water Framework Directive.

Liberalising trade in environmental goods and service would promote the use of environmental technologies, which, in turn, would
embolden innovation and technology transfer. At stake today is not one
domestic economy, but the worlds. Indeed, as world economies become more
interconnected by the day, the collapse of just one of them would without a
doubt have dramatic repercussions on the world market. The policy proposed
by the WTO and which we invite the European Commission to propose to both
the European Parliament and the European Council is of crucial importance
for the global EU economy. Domestic purchasers (which include both small and
big business, as well as governments at all levels) would be in a position where
they are able to easily acquire environmental technologies at lower costs
(www.edie.net, 2014). Whilst some EU countries have already implemented
green subsidies and carbon taxes, alleviating overall costs, especially for small
and medium-sized enterprises (MSEs) would allow for better competitiveness
both on the national and the international markets, whilst sparing EU citizens
purchasing power (Dechezleprtre and Sato, 2014). This, we believe, is a key
aspect of the policy to take into consideration amidst the financial crisis recovery process.

On top of this, we note the colossal benefit that preserving the environment
represents, as the EU as (re)asserted in numerous of its policies and directives
such as the Birds Directive and the Habitats Directive (Hey, n.d.). UNEP acknowledges the tremendous role the EU plays in international environmental
negotiations, which it has recently reasserted when hosting the Cop21 in Paris

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in late 2015. Withdrawing tariff and non-tariff barriers is a step

which would directly better the quality of life for EU citizens as it
would be providing a cleaner environment and allowing for better
access to clean energy. The air would be purer, and citizens would witness a
drastic change in the way in which water waste management - which, although
widespread across more economically developed countries (MEDCs), remains a
relatively expensive process for local authorities to finance - is conducted. Furthermore, as the European Environment Agency (EEA) rightfully highlights, a
significant proportion of Europes population live in areas, especially cities,
where exceedances of air quality standards occur (2016). We appreciate and
take into consideration the fact that the healthcare systems of EU states are
among the best in the world: EU members are the rare exceptions of countries
of which the annual health expenditure tops 10% of their GDP (www.data.worldbank.org). The policy presented throughout this brief has the potential to
greatly reduce the cost of these on the long run, without negatively impacting
the healthcare services available to your citizens.

Last but not least, tariff and non-tariff trade barriers undermine the
ability for developing countries to access the necessary tools to address key environmental policies as part of their ongoing development strategies (wto.org). On an environmental level, the European Union
financially supports not only the developing world, but also neighbouring countries and countries preparing to join the EU. It spent a grand total of 6 billion
euros on international environmental initiatives in 2015 only. The 2013 Government Spending Watch Report suggests that stricter policies would optimise
the potential of this budget greatly. As of today, more than three million people
a year are killed prematurely by outdoor air pollution: that is more than malaria
and HIV/AIDS combined. A recently published report on outdoor air pollution sources conducted by Lelieveld et al. (2015) suggests that the number of
deaths is likely to double by 2050. We place faith in the EUs long existing, intrinsic ethical-normative responsibility it feels it holds. Whilst it is true that great
controversy and debate were raised at the call of MEDCs to enforce stricter environmental standards upon poorer countries (McCulloch, et al. 2001), UNEP
intimately believes in the moral as well as political ability and ambition of the
EU to take a step, encourage other Western states to follow, as well as lead the
way for the rest of the world to engage in more fruitful negotiations with regard
to reforming international trade policies in a way which does not harm the environment and human lives subsequently.

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RECOMMENDATIONS
We urge the European Commission to table the elimination of tariff and non-tariff barriers
on environmental goods and services for adoption by the European Parliament and the European Council by:

Reaching out to relevant stakeholders and collecting their views on what the
formulation and implementation of the withdrawal of tariff and non-tariff
barriers in this European Union would and should entail fpr the benefits of all
concerned parties. The discussion with non-institutional and public parties
could take the form of a Public Consultation, a participatory instrument that
has proved increasingly useful to European policy and legislation for helping to
the design of efficient and equitable regulatory frameworks.
This public consultation should be addressed to the following target
group:
Non-governmental organisations (NGOs) thriving for the protection
of the environment. In particular, we strongly recommend to collect
the views of the International Monetary Fund (IMF), Earth System
Governance Project (ESGP) and the UN-initiated Intergovernmental
Panel on Climate Change (IPCC). In addition to environment agencies, the public consultation should aim at gathering the contribution
of other public stakeholders interested and active in the policy and
academic discussion of environmental issues. For this purpose, we
recommend that the European Commission compile the perspectives
of associations at EU and national levels, such as the the Environmental and Resource Economists (EAERE). Please note that this list
of stakeholders relevant for outreach is not exhaustive.

Designing a EU-wide informational campaign in order to advertise

the beneficial implications of the withdrawal of tariff and non-tariff
barriers on the European economy,, the environment as well as the
health and general well-being of EU citizens. This media outreach,
especially relevant on social media platforms, should notably focus
the business, economic, social and environmental opportunities resulting from such initiative. While this media activity would help to
the particular cause of the elimination of tariff-related barriers on

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environmental products, it could also significantly help in better informing stakeholders on the impact and process of implementing
new environmental policies, a subject that is still clearly the subject
important misconceptions, especially in regards to its effects on business competitiveness. A round table with relevant stakeholders could
also be organised by the European Parliament so to convey and discuss these considerations.

Promoting common rules for trade facilitation and transparency in

your relationship with developing countries (especially China) to (a)
encourage them to actively take part in negotiations and the drafting
of the trade barriers reform; (b) entail a change of perception and
mentality in regard to the assumptions about the environment-trade
nexus; (c) further extend your normative, non-mercantilist morals; as
well as (d) ensure strong, reliable trade deals which will be be beneficial for all parties.

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BIBLIOGRAPHY

"Air Pollution European Environment Agency". Eea.europa.eu. N.p., 2016.

Web. 2 May 2016.
Clancy, John and Antonie Kerwien. WTO Trade Negotiations: Facts And Figures On The Doha Development Agenda. Brussels: N.p., 2011. Web. 3 May
2016.
Davis, Lucy. "Ten Years Of Anti-Dumping In The EU: Economic And Political
Targeting". European Centre for International Political Economy 2 (2016): n.
pag. Web. 3 May 2016.
Dechezleprtre, Antoine and Misato Sato. "The Impacts Of Environmental
Regulations On Competitiveness". Global Green Growth Institute (2014): n.
pag. Web. 2 May 2016.
"Financial Barriers Continue To Block Green Innovation, Says EEA". edie.net.
N.p., 2016. Web. 31 Apr. 2016.
Hardin, C.L. In Defence Of Convergent Realism. 1998. Print.
"Health Expenditure, Total (% Of GDP) | Data | Table". Data.worldbank.org.
N.p., 2016. Web. 1 May 2016.
Hey, Christian. "EU Environmental Policies: A Short History Of The Policy
Strategies". EU Environmental Policy Handbook n. pag. Web. 1 May 2016.
Lelieveld, J. et al. "The Contribution Of Outdoor Air Pollution Sources To
Premature Mortality On A Global Scale". NATURE; Macmillan Publishers
Limited 525 (2015): n. pag. Print.
McCulloch, Neil, Alan Winters, and Xavier Cirera. Trade Liberalisation And
Poverty: A Handbook. Centre for Economic Policy Research, 2001. Print.
"Putting Progress At Risk?". Development Finance International (DFI) and
OXFAM (2013): n. pag. Web. 1 May 2016.

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"Should The EU Sign A Free Trade Agreement With China? - Debating Europe". Debating Europe. N.p., 2015. Web. 1 May 2016.
Skilton, Thomas. "GATT And The Environment In Conflict: The Tuna-Dolphin Dispute And The Quest For An International Conservation Strategy".
Cornell International Law Journal 26.2 (1993): n. pag. Web. 2 May 2016.
"WTO | Environment - Negotiations: Environmental Goods And Services".
Wto.org. N.p., 2016. Web. 31 Apr. 2016.
"WTO | Environment - Negotiations: Meas". Wto.org. N.p., 2016. Web. 4 May
2016.