AEC Association of European Consumers
socially and environmentaly aware
AEC's response to the European Commission's Green Paper
"Promoting a European framework for corporate social
AEC Opinion Paper
CORPORATE SOCIAL RESPONSIBILITY (CSR)
AEC'S COMMENTS ON THE GREEN PAPER: "PROMOTING
A EUROPEAN FRAMEWORK FOR CORPORATE SOCIAL RESPONSIBILITY",
PUBLISHED BY THE EUROPEAN COMMISSION (18.7.2001)
The acronym AEC designates the Association of European
Consumers, socially and environmentally aware. It was
the intention of national associations who are members of
AEC to underline through the very name of their association
its European dimension and the fundamental nature of the commitment
they want to assume and sustain through their activities.
Papers already published by the AEC include
the position paper "Consommation Responsable" ("Responsible
Consumption") published in October 2001; it defines what
the AEC means by "responsible consumer" and
presents demands relative to this position. A number of comments
on the Commission's CSR Green Paper are briefly anticipated
in this document: here the AEC returns to the subject
in order to better contribute to the present debate.
Previously in July 2001, the AEC published the opinion
paper "AEC's Comments on the EU Commission's Green
Paper on Integrated Product Policy", which includes
a number of themes also present in the CSR Green Paper. The
AEC does not wish to go back over this but notes with
some satisfaction that a number of suggestions contained in
this document, particularly on the subject of the integration
of the ethical qualities of products, were taken on board
by the Commission.
The Green Paper is aimed at businesses;
comments by the AEC will only present their views on general
matters concerning their part in the process, and on processes
regulating the interaction between consumers and businesses.
The AEC is happy, together with the Commission, to
address itself directly and openly to businesses by stressing
A reminder is necessary in this area because
too much socially and environmentally bad practice has been
justified on the basis of a so-called "consumer choice"
on the market. In practice the various actors in the chain
(producer, manufacturer, distributor) share a global
responsibility and everyone, in the area of social responsibility
as in others, must be responsible for all.
Nevertheless it has to be pointed out that true consumer
choice is totally dependent on information which is both extensive
and reliable: when this is lacking, consumers will
naturally think that correct production processes have taken
place in good faith before the product has reached the market,
either in relation to the work itself or to the environment,
because this is the normal assumption to make. Strong
reactions by consumers when malpractice by businesses is discovered
demonstrate their feelings of betrayal. It is precisely
in order to prevent such abuses that responsible consumers,
members of the NGOs or of any other association (religious,
trade unions or privately as is more and more the case), have
been the first to initiate the current debate.
AEC agrees with the Green Paper (#2) about the nature
of CSR. Points 20-25 go over principles which AEC sees
as fundamental, such as: need "to go beyond" legal
compliance without taking the place of the proper authorities;
important role of SMEs (Small and Medium Enterprises) and
appreciation of innovative practices introduced by the "Third
Sector" (even if it is not identifed by the Green Paper);
reference to indirect responsibility, etc.
AEC supports the aim expressed in point 26 "to
develop a better knowledge of the impact of social responsibility
measures by businesses on their economic performance"
but notes that the NGOs are not mentioned among those that
could carry out "new joint research programmes"
(companies, public authorities, universities).
This is paradoxical because not only the NGOs' major
contribution to economic thinking is now unquestioned but
also because the Green Paper itself (#3 and 3.1 passim), on
the subject of CSR policies, talks about the need to retrain
company staff at all levels and recognises weaknesses in traditional
training and by extension in the institutions which provide
it. Furthermore, research is one area where diversity in expertise
can be clear and fruitful without creating conflict through
Consumers ask from businesses that they assume with courage
and creativity their basic role, i.e that of intelligent
link between resources and needs: that, through their
organisational capacities they accumulate an intellectual,
financial and technical capital capable of finding sustainable
solutions to the practical problems of people in any part
of the world, while commiting themselvest to change unsustainable
modes of consumption.
In fact, in the area of price transparency, everything
remains to be done: here common initiatives must be encouraged
and the responsibility of all must be stressed, research
being specifically relevant to these objectives.
Consumers are confronted with prices at the retailers level
but price transparency is not a problem which can be solved
only in relation to them nor is it their sole responsibility.
Prices are supposed to represent the value of the product:
in fact they comprise (1) cost and benefits incurred
by the parties who are directly involved (2) in the
part (3) of the life cycle of the product preceding
its arrival on the market. Fiscal policies cannot counterbalance
any more this threefold limitation to the capacity of consumers
to evaluate through prices the global value of goods
and services in order to reach the solution which will
improve their wellbeing. This a very complex area
for whoever wants to go beyond the mere acquisition of general
but sufficiently reliable information, but the main obstacle
resides maybe in the fact that data and necessary information
are to be obtained from a multiplicity of parties with conflicting
interests: furthermore, this information is presently studied
through methods dependent on classification and an
institutional organisation which remains fragmented.
AEC calls for a strong political
will to manifest itself; it must be able to sustain detailed
economic studies which will inform consumers of the true implications
of their choices, i.e. on the market and in the lifestyles
they are able to adopt.
Consumers will not be placated by palliatives for their
consciences: they know the connection between income and
purchasing power, survival and resources, quality of life
and environment, identity and culture. They also know that
with globalisation bad practices are exported and imported
like everything else, from one end of the planet to the other
and in any direction: through solidarity, but also in order
to protect themselves, their aim is to get rid of these
wherever possible, starting from the worst instances but not
stopping there. Furthermore, the advantages gained
by these practices are becoming obvious to everyone and are
particularly relevant in the case of private organisations
more and more unaccountable to national communities of any
In the area of social behaviour, all consequences for human
groups affected through the life cycle of the product
are at stake: not only "workers" within factories
who are also "consumers", but also all those "consumers"
who are their dependents. We are talking about salaries and
also about any other systems liable to improve life-style
without taking the place of existing institutions. This is
about taxation of course but also about any intervention which,
through respectful dialogue with the relevant participants,
will be seen as desirable and useful by those it will affect.
The diverse qualities of products are
not interchangeable; there is at present a demand for
higher quality and on the basis of the respect for
what has already been gained, well informed consumers can
make choices which involve retaining the current quality of
products or services or favouring changes without affecting
AEC warns not to repeat the costly mistakes made in
the area of corporate social responsibility through
"ecological" claims; there is a need to transfer
experience acquired and appropriate tools of communication.
The disastrous problems encountered when information on the
environmental performance of products was first made available,
led to mistrust among consumers with regard to environmental
claims on products. Such episodes interfere with the
proper operation of the market to the detriment of consumers
themselves: there are known examples of Ecolabel products,
which, were it not for the distrust which is attached to them,
could be sold at very competitive prices. The BSE and dioxin
disasters also prove that disappointment is long term.
Reliable claims are particularly important in the
context of a globalisation process dependent on transport
and more and more on communication. Several of the
tools which have been developed require participation and
control by NGOs and consumer organisations and try to ensure
that communication be complete, relevant and truthful;
they have to be put into practice even though it is too early
to stop some choices.
The problems created by ecological claims proved also that
consumers no longer apply the simplistic concept of value
for money and that they do not accept trade off between qualities.
At the same time this experience has increased enormously
consumers' capacity to recognise different qualities
in products, to take into account production processes and
to think in terms of lifecycles: this also applies
to social claims.
There is a risk that a hasty reaction to consumers' ethical
expectations will produce a false response distinguishing
between a market for "the rich" and one for "the
poor". AEC will do its best to stop this happening;
nothing would be less ethical in itself and more wrong
The Green Paper chapter on labelling (#3.4) introduces
key points towards good understanding between consumers and
companies. In general terms AEC considers that global
production and trade require that all important aspects
of the product and its production process be communicated
to consumers before purchase: on the global market
presuppositions (which are always linked to a specific culture)
must be banished. Yet, informing the consumer is not necessarily
synonymous with the attribution of labels to each company.
Eco-labels have revealed furthermore that sustainable
development will never have the support of the majority of
consumers unless they are given reliable ways to confront
their economic effort (which they measure in proportion
to their income) to benefits whose extent and recipients
A number of surveys have noted the gap between
environmental and social "worries" and "good
intentions" of the majority of consumers and the "green
or ethical" purchases of a very small minority. Most
of these surveys draw conclusions which are hardly flattering
about the consistency of consumer behaviour and stress
that the most underprivileged among them are those who are
the least sensitive to the problems of our planet.
In our opinion, inconsistency is a problem for the researchers
themselves as it is paradoxical:
a) using "economic" arguments, to reproach
a single one of the actors for behaving in a rational way:
i.e. for not wanting to pay extra for what (such as honesty)
is a duty and what (such as a healthy environment) is a right
(Consumer Chart, UN 1985).
b) using "sociological" arguments, to add
to the problems of the poorest consumers and to fail to recognise
that at the moment, through higher prices, "ethical"
and "green" consumers purchase above all and consciously,
the communicative value attached to these products.
At the same time a message is more efficient if it is unusual
... and this contradicts the major need for good behaviour
to be normal.
The most competitive practices of the
best companies must be found first in the widening of their
market at the expense of the least effective products
in qualitative terms. There is room here for governments to
display through public procurement consistency betweeen what
they demand from their citizens and their political programme
on the one hand and the criteria for adjudication on the other.
AEC notes that the CSR document does not introduce
a clear enough distinction, seemingly essential to consumers,
between production and distribution companies,
which through the choices they make play a major role
in consumer choices.
a) Consumers want to know purchase policies of distributors
because they condition their own.
You can only choose what is on offer on your market: thus,
you have to be able to control whether the selection criteria
of products on offer adopted by the retail point are compatible
with your own. It has to be pointed out that the mere sale
of "organic" or "ethical" products cannot
be said to be the answer to this demand.
b) The presentation of products is equally important
and must be familiar to consumers.
Some companies make their profit through rent-seeking and
not through a fair renumeration of enterprise and work: consumers
should be informed of a number of practices which in the end
will influence their choices and for which they will pay the
final bill: they include for example the leasing of sale outlets
including conditions that leases will be cancelled in the
case of companies who do not "push" their product
sufficiently through advertising.
c) Price policies: those that would be aimed at a fairer
distribution of benefits among all those in the chain should
be brought to the consumers' attention.
Commercial communications need to be more reasonable
including bans on misleading advertising.
Advertising brings significant costs and precedes purchases
but consumers are the ones who pay for it in the end: having
to pay for aberrant practices is paradoxical. Variations in
the capacity of companies to anticipate these costs
can have negative effects on products which in fact would
be appreciated by consumers. The onus should not be on them
to find solutions to this problem, but it is essential to
circulate freely information about production or trade
practices whose goals are particularly commendable.