7)  A Conceptual Framework for Life-Cycle Impact Assessment.

3. Methodological aspects from the Prestudy

3.1 The LCA approach

In this chapter the results from the investigated studies in the Prestudy (light bulbs, refrigerators, soil improvers) is presented with respect to methodological aspects. The focus has been put on some general aspects in the LCA approach like the goal definition, the inventory and the impact assessment. For each of these aspects the approaches used in the investigated studies in the Prestudy will be highlighted. Individual characteristics of the studies will in relevant instances be stressed out. All the considered studies are 1. generation studies. For many of the product groups there have been at least one revision since the present study was done.

Following the three separate presentations a comparison of the three studies from the Prestudy is presented and similarities and differences are highlighted and the most significant features are drawn out.

3.2 Light bulbs

In this section an introduction to the goal definition and scoping in the light bulbs study will be presented.

Purpose of the study

As it is stated in the study itself the purpose of the LCA study was to catalogue and sum up potential adverse effects on the environment of the light bulbs in order to:

	provide an objective appraisal of the environmental impact of the light bulbs,
	facilitate comparison between the different light bulbs within the same product category (corresponding to the product group).

Product group definition

Two separate product categories were defined in the report. These were single-ended and double-ended light bulbs.

The categories were defined taking the following points into account:

	Double-ended light bulbs are easily distinguished by the consumers from the single-ended bulbs both with regard to appearance and function.
	Double-ended light bulbs constitute a homogenous group in terms of energy efficiency, technology used (mostly fluorescent) and design purpose (mostly non-domestic).
	By defining the product categories as above direct comparison between compact fluorescent bulbs and standard incandescent bulbs is allowed within the category of single-ended bulbs.

Product categories based upon the function for which the light bulbs are purchased might appear more relevant for the consumers. Thus, the light bulbs could with advantage be divided into product groups of domestic and non-domestic light bulbs.

Criteria setting

Criteria were in the first case only proposed for single-ended light bulbs on the basis of following arguments:

	Relevant criteria - in terms of energy use - for double-ended bulbs will exclude double-ended bulbs for domestic use, since they are less energy efficient than the non domestic bulbs.
	If separate criteria for the two product categories were made the consumers could be mislead to buy eco-labelled single-ended bulbs in preference to non-labelled double-ended bulbs which actually are more energy efficient.
	If the same set of criteria were used for the two categories, all double-ended bulbs would meet the criteria and the eco-label would then fail to achieve its aim.

The purpose of the Eco-Labelling Scheme is to encourage manufacturers to introduce cleaner and sustainable technology in the manufacturing of products from all of the product groups encountered in the scheme. Therefore, criteria for each product group should be proposed but the stringency of the criteria for a specific product group should of course be adjusted to the environmental performance in general within the product group. At an interim stage criteria were also proposed for double-ended bulbs

Fitness for use criteria

Some fitness for use criteria were proposed. These were:

	The bulbs should comply with three European standards concerning electromagnetic interference developed by the European Committee for Electrotechnical Standardisation (CENELEC - Comité Européan de Normalisation Electrotechnique).
	The packaging of the light bulbs should contain information about any special characteristic of the bulbs.

The fitness for use criteria did not cover the most straight forward demand on light bulbs; to provide light for the purpose of use throughout a minimum time period. This could be ensured by proposing a minimum number of lumen hours for the bulbs.

Scope and system boundaries

The LCA included the environmental interventions directly associated with the light bulbs, namely the phases of pre-production, production, distribution including packaging, use and disposal. Effects arising from the construction of plant and tools, the development of infrastructure or the needs of workers were excluded, since it was considered very difficult to determine and allocate them objectively.

Only few aspects of the different life stages in light bulbs’ life cycle were actually included in the report and this was only done to a limited extent. It implies that for instance in and output of auxiliary products were for the most part excluded.

Environmental fields

No aspects of occupational health or risk of accidents were considered in the LCA.

In the study of light bulbs it was argued that the experience has shown that the potential impacts arising from construction of plant and tools, the development of infrastructure and the needs of workers only to a minor extent contribute to the total potential impact of a product and therefore these factors were excluded from the study.

Functional unit

For the purpose of comparisons, a functional unit was selected. The selected functional unit was equal to 1.5 times the light output of a standard incandescent bulb (60W) and 0.3 times that of a compact fluorescent bulb (11W). The functional unit was not used when discussing scarcity of the elements identified in compact fluorescent bulbs nor was it used or considered in many of the proposed eco-label criteria. For some of the figures it is not clear whether they are related to the functional unit, since it was not specified in the legends to the figures. Since consumption of energy appears to be of crucial importance in connection with environmental performance of the light bulbs throughout their life cycle, it would have been more transparent directly to include an aspect of energy consumption in the functional unit. Thus, a functional unit of a fixed number of lumens per watt would somehow have been a better standard of reference for the environmental performance of the light bulbs.

Key features

No real LCA was performed in the light bulb study. Instead a very limited sort of screening LCA was performed. The so-called "environmental indicators" were selected.

The "environmental indicators" were selected very early in the study - before the inventory - to include the fields that could be of environmental relevance in connection with the light bulbs' life cycle. Thus, the environmental indicators were used as parameters for the analysis and indicated the direction of focus for the analysis. In this matter, the environmental indicators can be interpreted as being equivalent to "key features" - the term commonly used in other studies - with the reservation that key features often are selected after the inventory.

The following environmental indicators were selected:

Emissions to air:	particulate matter
	greenhouse gases
	acid forming gases
	critical volume.
Emissions to water:	chemical oxygen demand (COD)
	suspended matter
	critical volume.
Solid waste:	mass generated.
Natural resources:	energy used
	mass used
	scarcity index of elements used.

The critical volumes of water and air were employed as indicators of toxicity to man and were mentioned to be based on emission loadings to air and water normalised after the toxicity standard of "MAK⁸.

3.2.2 Inventory analysis

The inventory contains in- and output data on five of the most typical bulb models within the four different technologies (standard incandescent, tungsten halogen, compact fluorescent with variable control gear and tubular fluorescent) used for domestic lighting in the EC. Compact fluorescent bulbs with both magnetic and electronic gear were included. Thus, data for one type of double-ended light bulbs, namely tubular fluorescent bulbs, were included in the inventory, although no criteria were in the first place proposed for these bulbs. The data were included for the purpose of comparisons with the figures from the four different single-ended light bulbs. Little attention was paid and little information was given about the control gear of the compact fluorescent bulbs and the transformer necessary to use some of the tungsten halogen bulbs.

Process flow chart

An illustration of the environmental interventions of the light bulbs' life cycle was included in the report. The illustration outlined in a schematic way the interventions related to the phases of pre-production, production, distribution, use and disposal. The flow chart illustration is very simplified and does not add any extra information to the life cycle stages of light bulbs compared to what could be expected. The flow charts serve as an general illustration for the reader. Therefore, the flow charts are not elaborated in respect of input/output.

Allocation procedures

In the study on light bulbs, allocation procedures were not paid much attention. There might be several reasons for that. Two of them deserve some thoughts in this presentation.

The study of light bulbs was in some way carried out in a general way, e.g. the used flow charts did not include connection to public plants, neither did it mention that several production chains could take place at the same factory.

While developing criteria the specific application procedures were not considered. A guidance document or maunal was not developed or considered. Because of this, procedures including allocation matters were not considered.

Inventory data

Most of the information concerning the inventory data was presented in the section dealing with the inventory and in Annex B of the report which was added to the second edition. Within the annex the various background data and methods used both in connection with the inventory and the impact assessment were discussed, and assumptions were identified and explained. A lot of the data selected for the inventory was already aggregated, such as SO2 emissions and VOC emissions.

The inventory data were mixed with the aggregated data normally presented in the impact assessment. To some extent data that are not used were also presented and also a number of non-explained abbreviations. These things may lead to confusion.

The majority of the data used in the LCA was selected as being the "most suitable" for the study and was taken from the European manufacturers and associations, mainly the European Lighting Council (ELC), BUWAL/FOEFL (Swiss Federal Office of Environment, Forests and Landscape) (19), TEMIS, A Computerised Tool for Energy and Environmental Fuel and LCA and Energy in Europe, Annual Energy Review CEC DG XVII (22).

The inventory data obtained from the European manufacturers and their associations were presented in one inventory table. The remaining inventory data were presented in Annex B of the report.

In the inventory table the data representing tubular fluorescent bulbs were presented mixed together with the data concerning the single-ended light bulbs. No specific data on solid waste were presented whereas data on performance in use were included. The presentation of the data on double-ended light bulbs among the single-ended light bulbs can be confusing since it veils the previously defined product categories. Few inventory data were actually presented in the table and the data were mostly related to input, whereas output data were more scarce. Output data for the life phases of pre-production, distribution and use were omitted. On the other hand, data on the lifetime of the bulbs were included which - strictly spoken - have nothing to do with in- and output. Some of the data in the table were actually aggregated data (like VOCs) and should therefore rather be presented in the section of characterisation under the impact assessment. The term "VOCs" was not defined in the report. Also, terms as "electronics" and "others" were used without a describtion of, what they stand for but mentioning that it was unspecified by manufacturers.

3.2.3 Impact assessment

Classification

No real process of classification of impacts was performed in the report but the selected "environmental indicators" constituted a form of classification of the supposed input and output. Thus, the impacts of the light bulbs' life cycle were indirectly classified in the following categories:

	global warming,
	acid deposition,
	dust nuisance,
	water quality,
	air quality,
	depletion of natural resources and
	generation of solid waste.

No potential damage to the ozone layer, terrestical ecology or noise impacts has been included in the assessment since - according to the report - no aspect of the light bulbs' life cycle would cause specific effects in these fields. Any potential impact on occupational health or aspects of accidental risks was excluded as well.

The statement that light bulbs do not have any potential impact on terrestical ecology or noise impact is not further discussed or documented in the report.

Characterisation

The identified environmental impacts were aggregated into impact categories as follows and were all calculated per functional unit. The impact categories were global warming, acid deposition, toxicity to man and resource consumption.

The Global warming expressed as CO2-equivalents per Mlm.hr. (Mega Lumen hours), include figures for emissions of CO2, CO, CH4, N2O and non-methane volatile organic compounds. Global Warming Potentials (GWPs) were taken from the International Panel on Global Warming (IPCC, 1992) reflecting a 100 year timescale.

According to IPCC, non-methane volatile organic compounds (NMHCs) are categorised as indirect greenhouse gases meaning that they only indirectly - via formation of ozone, water and CO2 - have a greenhouse effect. The GWPs for indirect greenhouse gases (mainly NMHC, CO, NOx and CH4) are connected with large uncertainties and therefore, IPCC does not recommend using them. If the indirect GWPs are used they should be distinguished from the direct GWPs and all of the indirect GWPs should be considered or the reasoning for only including NMHCs and not the other indirect greenhouse gases should be mentioned.

The Acid Deposition expressed as SO2-equivalents per Mlm.hr., include figures for emissions of SO2, NOx, NH3 and HCl. Conversion factors were taken from the French Eco-Labelling Study of Paints and varnishes which used the data from VROM Bestrijdingsplan Verzuring 2000 (1990).

In addition to the above mentioned gases, hydrogen fluoride - as proposed by the Dutch Centre of Environmental Science in Leiden (CML) - is also often included as a gas which contributes to the acid deposition. The study does not mention whether HF initially was considered for light bulbs.

The Toxicity to Man was divided in one part concerning air and one part concerning water. Concerning air, the toxicity to man was expressed as critical volumes of air per functional unit. The emissions to air were mentioned to be related to the Swiss MAK standards. In connection with energy consumption, the data of critical volumes were taken from the BUWAL database and included the following emissions:

As for air, toxicity to man was considered and was expressed as critical volumes of water per functional unit. The emissions to water were mentioned to be related to the German MAK standards. With regard to energy consumption the critical volumes were taken from the BUWAL database and included the following emissions:

For the Consumption of resources the figures of electrical energy consumption have been aggregated and are expressed in primary energy using a conversion factor of 38% for electrical energy in the EC. It is not clear what kind of fuel was considered in the case of consumption of thermal energy.

Valuation

No quantitative valuation was performed in the study but the various impact categories were compared in an implicit way since some of the potential impacts were highlighted on the behalf of the other impacts.

The majority of the emissions connected to light bulbs' life cycle was shown to arise from the consumption of electrical energy during use, and therefore the energy efficiency of the bulbs was regarded as the most important environmental characteristic of the bulbs.

Depletion of natural resources was discussed in connection with the use of different elements as raw material for light bulbs. The use of raw material per functional unit was shown to be largest for compact fluorescent light bulbs with magnetic control gear. Therefore, a table showing the different elements identified in compact fluorescent light bulbs was presented together with a scarcity index (reserves/production ratio). In that table, tin (from the EC Directive on pollution caused by certain dangerous substances discharged into the aquatic environment (76/319/EEC)) was shown to be the most scarce resource with an existing world supply of no more than twenty years.

Other potential impacts that were highlighted were as follows:

	Emission of dust particles to the air during the phase of pre-production due to mining activities.
	A relatively high Chemical Oxygen Demand (COD) due to release of organic matter to water during production of packaging material used in the distribution phase.
	Relatively high critical volumes of air and water emissions during the phases of pre-production and distribution due to releases during mining, particularly of metals and releases during production of packaging materials.

A scarcity index of the various elements used in the bulbs is a good help for evaluating the potential depletion of natural resources but it should be combined with figures of consumption before being of any use. A high annual consumption of a less scarce element can easily be of higher environmental concern than a minimal consumption of a more scarce element.

This could have been expressed by a very simple formular like e.g.:

3.3 Refrigerators and freezers

In this part the eco-labelling study of refrigerators and freezers is presented in detail.

Purpose of the study

3.3.1 Goal definition and scoping

In the report, the purpose of the study was described as developing criteria that might help to promote the development and employment of cooling appliances which, while complying with safety and performance requirements, have a reduced environmental impact. It was mentioned that the promotion of the criteria should be achieved by giving a clear and complete picture of the interactions that refrigerators and freezers have with the environment throughout their life cycle.

Product group definition

The product category of cooling appliances was initially defined as "refrigerators, refrigerators/freezers and freezers sold on the market". Subsequently, on the basis of a market analysis, the product category was redefined as: Refrigerators, refrigerators/freezers and freezers having the following cha-racteristics:

	household applications,
	electrically powered,
	compressor refrigerating circuit,
	total net capacity ranging from 50 to 1,000 litres,

where the appliances either may be:

	upright or chest models,
	free-standing or built-in models,
	with one or more doors,
	with or without low temperature compartment,
	with or without Frost Free system.

It was emphasised that the following types of cooling appliances were excluded from the product category:

Appliances for industrial, commercial and vehicle applications because of:

	The great variety of types of appliances with respect to specific use.
	The relatively low number of units sold.
	The complexity involved in undertaking LCA.
	The relatively little importance of the environmental issues directly connected to the particular performance requirements.
	Absorption-type appliances since they imply a different technology compared to the traditional compressor-type technology and therefore, cause different environmental effects.
	Appliances for special applications because of the relatively limited number of appliances within this group and since such appliances are often only used in short time periods (e.g. camping refrigerators).

It was mentioned that the excluded types of cooling appliances could be examined in separate ad hoc studies.

The defined product group was further divided into appliance classes where several appliance classes were introduced for various purposes.

With respect to the final eco-label criteria the following 12 appliance classes were defined:

The "star system" was mentioned to be a conventional system indicating which temperatures can be reached and which cooling performances can be obtained by the cooling appliances.

The "No-Frost" system was mentioned to consist of a special design of the cooling appliance where the evaporator is positioned in a separate part of the cooling compartment(s) allowing cold air to recirculate inside the compartment(s). This permit a better temperature control and distribution in the compartment(s) as well as a lower humidity level. Moreover, it was stated that no defrosting operations are necessary during use of cooling appliances with No-Frost system. Therefore, No-Frost appliances were mentioned to be particularly useful for cooling appliances under:

	Intense use with frequent door opening rate.
	Climatic zones characterised by high temperature and/or high humidity level.

Originally, a slightly different classification was used, where the refrigerators with 1 and 2 star(s) compartment(s) were grouped in one class and the refrigerators with low temperature compartment and those with 0 star compartment were divided in separate groups. After the second peer review this classification was changed to the above shown classification. However, No-Frost appliances were still kept in separate classes, since their specific characters otherwise easily could be hidden by non-No-Frost appliances in the same class.

For the purpose of determining the material composition of the cooling appliances another sub-classification was used.

While performing the quantitative LCA, a grouping system based on "standard models" was in order to consider different "cases" in connection with the "standard models".

The many different classification groups or classes is confusing. This confusion was further emphasised since the structure of the report did not reflect or explain the many subgroups.

The reasoning for grouping No-Frost appliances in separate sub-categories appears reasonable while considering the expected increase in No-Frost appliances but this distinction between No-Frost and normal appliances is not kept up in the quantitative analysis, where the appliances are considered together just with the inclusion of a correction factor.

The term "fitness for use" was not used directly in the report. However it was used indirectly since a set of preliminary conditions (that were a number of EEC norms and regulations) was required.

The content of the above mentioned norms and regulations should have been described. It might also have been a good idea to include some more stringent requirements - not necessarily standardised norms - in order to profile the eco-label in a better way.

Scope and system boundaries

The following stages of production were considered: Extraction of raw materials, transformation of the raw materials into basic materials (steel, plastic etc.), transportation of the materials, processing of the basic materials to form appliance components and finally the assembling of the components. The CFC substitutes present merits and disadvantages from the point of view of appliances manufacturing process, functional performance and environmental behaviour. Therefore, the working group avoided to set specific criteria on them.

The distribution phase comprised transportation of the appliances from the manufacturer to the retailer and further on to the consumer as well as transportation of discarded appliances to waste disposal plants. Also, contributions from the packaging materials throughout the stages of production, distribution and use was included in the distribution phase.

During the use phase of the appliances, the following aspects were considered: Consumption of electrical energy, accidental loss of CFCs, CFC loss during maintenance operations and noise.

For the stage of disposal, the volume of solid waste, the amount of water and air pollutants as well as the consumption of energy and water (if any) were considered. There are some uncertainties as to which aspects are actually included in this item, e.g. it is not clear whether CFC and/or HCFC is included. In the cases of recycling of materials and heat energy produced by incineration, the obtained resources were subtracted from the respective figures of consumption. The impact of 3 different disposal methods of the discarded appliances including packaging were examined, namely straight dumping, dumping after removal of refrigerating fluid, dumping after removal of refrigerating fluid and recovery of recyclable parts. Furthermore, a 25%’s incineration of the waste otherwise ready for dumping was probably also included but this aspect was not quite clear.

Environmental fields

In the analysis the stages of production, distribution, use and disposal were considered. For each of these stages, the following aspects were mentioned to contribute to the environmental impact of cooling appliances:

	energy consumption,
	consumption of raw materials,
	water consumption,
	air emissions,
	water discharges,
	solid waste production and
	noise.

Considering the relatively high content of iron and sheet steel in cooling appliances impacts in connection with the preparation of these materials could have been considered relevant. Soil pollution/degradation and effects on eco systems have not been considered either.

Furthermore, no aspects of occupational health were considered despite the fact that many hazardous chemicals (lubricating oils, paints etc.) are used in the production phase of cooling appliances. The risks of accidents were considered in connection with some of the alternative refrigerating and foaming fluids.

Functional unit

No functional unit was directly defined in the study. Instead the various types of cooling appliances were compared on the basis of different cases of two defined "standard models". The standard models consisted of two defined cooling appliance models of different sizes (with or without freezer) but with fixed characteristics in terms of material percentage composition, weight and consumption of auxiliary resources (water, energy for production, methane for production).

Key features

Considering the many different models of cooling appliances existing on the market it appears like a quite significant simplification only to consider 2 standard models of cooling appliances. Significant differences exist in for instance the characteristics of chest freezers and upright freezers which may be overlooked when only using two standard models as a starting point for the analysis. A minimum of 4 standard models namely refrigerators, refrigerators/freezers, upright freezers and chest freezers, would have given a better picture of the very diversified market of cooling appliances.

Otherwise, a reduced number of the twelve appliance classes could have been used as standard models.

Also, the cooling capacity of the appliances could with advantage have been included.

A screening LCA or qualitative LCA was performed in order to reveal the various environmental characteristics of the different types of cooling appliances. Throughout the stages of production, distribution, use and disposal the various environmental aspects were discussed and the current state of the aspects was mentioned.

Especially the environmental problems connected to the use of CFCs and to a minor extent alternative refrigerating and foaming fluids were discussed with respect to the different life stages, and the production of CFCs was examined in details.

In connection with the phase of production a "mean percentage composition" was introduced. On the basis of the collected data, it was stated that little difference occurred in the minimum and maximum percentage compositions of the appliances (the biggest difference occurred for iron materials/cast with a minimum composition of 46.2% and a maximum of 66.5%) across the sub-categories and therefore, a general mean percentage composition was calculated in order to represent all of the appliances. The mean percentage composition was used subsequently in the quantitative LCA.

Also, an average weight for two standard models was identified in the qualitative analysis. For the standard model with freezer compartment an average weight of 56.0 kg was calculated whereas for the smaller standard model without a freezer compartment a weight of 31.7 kg was used based on the average weight of the appliances in the category of "refrigerators with 2 doors and 1 compressor", see Table 3.1.

In order to outline the "environmental features" of the various cooling appliance models the following parameters - or key features with the reservation that the parameters were selected before the inventory - were selected:

Natural resources:	consumption of virgin raw materials10)
	consumption of recycled materials,
	water consumption,
	energy consumption.
Emissions to air:	direct green house gases,
	indirect greenhouse gases,
	uncertain greenhouse gases,
	ozone depleting gases,
	acid equivalents,
	toxicity (critical volume).
Emissions to water:	chemical oxygen demand (COD),
	biological oxygen demand (BOD),
	toxicity (critical volume).
Solid waste:	mass generated.

In any case it is still a quite marked simplification to apply the same material composition percentage to the mentioned categories. More specific material composition values relating to for instance the 4 standard models as previously proposed would have been preferable.

The selection of environmental parameters before the inventory cannot be recommended since important aspects easily can be overlooked in the initial phase.

3.3.2 Inventory analysis

The inventory analysis was based on 11 different scenarios of the two standard models of cooling appliances. It was emphasised that the 11 scenarios of the standard models not necessarily were models existing on the market but that they were defined in order to represent the various types of cooling appliances on the market. The eleven scenarios of the two standard models (with or without freezer) of cooling appliances were defined combining 2 possible levels of energy consumption, 3 different refrigerating fluids, 4 different foaming agents and 3 alternative disposal methods.

It was mentioned that the final results of the analysis on the 11 scenarios were to be transferred to the 12 product categories for which the eco-label criteria were proposed.

By performing the quantitative analysis on scenarios and defining the scenarios the way they are, the analysis will automatically be focused on - or limited to - the aspects outlined in the case models. These are the aspects related to the refrigerants and the foaming fluids, the disposal method and to a certain degree to energy consumption.

Fixation

However, the fixation of some of the minor aspects, like for instance water consumption during production, exclude the possibilities of establishing criteria on these aspects which are of minor - but still measurable - importance.

All the other parameters of the scenarios such as material composition and consumption of auxiliary resources during production (water, methane, energy etc.) were kept constant having the values as defined for the standard models. The specific data on the material percentage composition and the weights of the two standard models (with or without freezer) are shown in Table 3.2.

As for what is mentioned in the report, the mean percentage composition of the two defined standard models should fit with the weight-based values of the materials as given in Table 3.2. This is obviously not the case but why the figures do not fit with each other and on which basis the weight-based figures then are derived is not clear.

Table 3.1 Look here!
Case models for which the quantitative life cycle was performed.

Table 3.2
Material and weight composition of the two defined standard models.

* Somehow the percentages for material composition do not fit with the weight-based values for the standard models as indicated in the table. No explanation can be given for this discrepancy.

Process flow-chart

Three process flow-charts were included in the report, depicting the production of CFC-12, the production of a specific cooling appliance model and the stage of disposal of discarded appliances. None of the included flow charts were commented in the report.

Allocation procedures

In the present study on cooling appliances not much attention was paid to allocation procedures. There are several reasons for that. The study of cooling appliances was general, therefore the use of scenarios evolved on the basis of aggregated and standardised data can not reveal information concerning allocation procedures. When the data are aggregated there should have been aggregated data that deal with allocation procedures as well. However, that sort of information may be difficult to obtain as general information. Further, the proposed criteria did not cover the appliance procedure and thereby difficulties in the assessment procedure including allocation procedures were not revealed.

Inventory data

In general, little information was given about the used data and the below mentioned information is for the most part derived from the raw data tables in the back of the first part of the report.

The data background for many of the used data is not clear and in general, the data are not very transparent. Furthermore, it might be of significant importance that the data used for the inventory analysis are not taken from the same source (or at least not directly from the same source) as the data on which the threshold levels for the criteria are based. Differences in for instance the age of the data, measuring methods, data collection procedures etc. might result in selection of biased data and thereby in the establishment of biased threshold levels.

The data sources are among others the European manufacturers (mainly Italian manufacturers), BUWAL/FOEFL (Swiss Federal Office of Environment, Forests and Landscape) (19), Life-Cycle Analysis of selected Packaging Materials - Quantification of Environmental Loadings, Chalmers Industriteknik (20) and "European Eco-label - Project for Application to Paints and varnishes" (8).

In order to establish specific threshold levels for the proposed eco-label criteria, data from various existing databases on cooling appliances were used while forming a new mixed reference database.

The comments related to the quality of the selected data will be discussed in the section dealing with the data quality aspects.

3.3.3 Impact assessment

Classification

No real classification was performed but a form of impact classification was already made via the various parameters selected in order to outline the "environmental features" of the cooling models. Accordingly, the impacts of cooling appliances throughout their life cycle were indirectly classified in the following categories:

	ozone depletion,
	global warming,
	acid deposition,
	water quality,
	air quality,
	depletion of natural resources and
	generation of solid waste.

As previously mentioned, few impact categories are actually included in the study. Especially the impact categories of soil pollution/degradation and effects on eco-systems could with advantage have been included.

Characterisation

The various impacts were aggregated and quantified within each of the identified impact categories. The identified categories were ozone depletion, global warming, acid deposition, toxicity to man and resource consumption.

The ozone depletion was expressed in Ozone Depletion Potentials (ODP) relative to CFC-11 per life cycle of the case model, included figures for CFC-11, CFC-12, CFC-113, CFC-114, CFC-115, Halon-1211, Halon-1301, Halon 2401, HFCs (=0), HCFC-22, HCFC-123, HCFC-124, HCFC-124b, HCFC-142b, CCl4 (tetrachloromethane) and C2H3Cl3 (1,1,1-tri-chloro-ethane)¹¹.

The global warming was expressed in CO2-equivalents per life cycle of the case model as direct Global Warming Potential (direct GWP, included figures for emissions of CO2, CH4, N2O, CFC-11, CFC-12, HCFC-22 and HCFC-134a), indirect GWP and uncertain GWP (included CO, NOx, HCFC-123, HCFC-124, HCFC-124b, and HCFC-142b) and summed up as Total Equivalent Warming Impact (TEWI)¹²⁾¹³⁾.

The indirect GWPs - as well as the uncertain GWPs - are connected with large uncertanties and therefore, IPCC does not recommend using them. Furthermore, negative indirect GWPs also exist and if the "positive" indirect GWPs are included in the analysis, the negative indirect GWPs ought to be included as well.

The acid deposition was expressed as Acid Equivalent factors (AE factors grams of H⁺-ions divided by the equivalent molecular weight per life cycle of the case model, figures NH3, NO2, SO2 and HCl were included¹⁴⁾.

Toxicity to man was divided in one part dealing with air and another dealing with water. Concerning air, the toxicity to man was expressed as critical volumes of air per life cycle of the case model (1 scenario). The emissions were related to Swiss and German MIK standards and, when no MIK standards existed, they were estimated on the basis of MAK standards. The standards were taken from the BUWAL database and included figures for the same components as in the BUWAL database.

Concerning water, the toxicity to man was expressed as critical volume of water per life cycle of the case model (1 scenario). The emissions to water were related to Swiss threshold limit values for discharges to recipients and included figures for the components as in the BUWAL database.

The consumption resources was focusing on the consumption of electrical energy. This was aggregated while assuming a conversion factor of 33%. The electricity conversion factors were taken from the BUWAL database.

Valuation

No quantitative valuation was performed. Instead the identified environmental impacts were qualitatively evaluated. The various impacts were assigned a rating where the ratings of "moderate" or "important" were used. Only two of the identified impacts were assigned the rating "important", namely the impact of air emissions - caused by electrical energy consumption - and the impact of CFC discharges during the life stage of disposal, see Table 3.3.

In connection with energy consumption, it was emphasised that about 80% of the total air impact during the use phase were attributed to emissions related to production of electrical energy. Especially with respect to the total potential of global warming (TEWI) and acid deposition, the consumption of electrical energy was the main contributor to these impacts.

The discharges of CFCs used as refrigerating and foaming fluids were also pointed out as being of great importance in connection with the total environmental impact of cooling appliances. By substituting CFCs with alternative fluids having lower ODPs or ODPs of 0, marked reductions of up to 96% of the ozone depletion potential and 30% of the global warming potential could be obtained. Furthermore, removal of CFCs from the discarded appliances would reduce the potential for ozone depletion with 25% and the total potential of global warming with 18% during the phase of disposal.

As regards the use of alternative refrigerating and foaming fluids, little differences occurred in the analysis among the case models and considering the many open questions on some of the fluids, it was stated that none of the fluids could be said to have a distinct better environmental performance than the others.

Table 3.3
Relative importance attributed to the various environmental impacts identified in the life cycle of the case models of cooling appliances.

3.4 Soil improvers

In this part of the eco-labelling study soil improvers are presented in detail.

3.4.1 Goal definition and scoping

In this section a discussion of the goal definition and scoping in the soil improver study is presented.

Purpose of the study

The purpose of the LCA study was to identify which features of the soil improvers have a significant effect on the environment and to determine at which stages in the life cycle they occur and by that establish proposals for criteria for the award of an eco-label to soil improver material offered for sale as branded products.

A number of specific issues are encountered with other product groups. The most specific of these is to take into consideration the specific provisions of the Community waste management strategy.

Fitness for use

No accepted measures of the performance of soil improvers exist. It was therefore mentioned, that the performance of soil improvers can only be judged in the context of the ground they are used upon and the skill of the gardener.

However, it was stated that the ability of soil improvers to better the physical structure of the soil generally is associated with a number of effects. These are soil crumb formation, structural stability, buffering capacity, storage capacity, textural modifiers and bulking agents. These effects were all mentioned to be related to a minimum content of bulky organic matter in the soil improvers.

In the case of prolonged application or over-application of some soil impro-vers it was mentioned that they may have an adverse impact on health, safety and environment rendering the soil improver unfit for the purpose of use. This is due to the fact that some soil improvers are based on waste-derived materials potentially containing components like toxic elements (e.g. heavy metals), organic chemicals (e.g. pesticide residues), non-putrescible elements (e.g. plastic contaminants), nutrients in abundance and nuisance dust.

Thus, inexpedient application of some soil improvers may lead to (soil) contamination of the above mentioned components and it was therefore emphasised that the fitness for use aspect of soil improvers was closely interwound with the environmental performance of the soil improvers during use.

Because of this coherence between the fitness for use and the environmental performance of soil improvers, the aspect of fitness for use was considered as being an integrated part of the eco-label criteria and as such dealt with in the eco-label criteria. The fitness for use criteria were dealing with aspects like general labelling requirements, product performance, soil degradation and water pollution, health and safety and nuisance.

It can be argued that the presence of heavy metals or other undesired components in some waste-based soil improvers do rarely influence the immediate performance of the soil improvers; such components do rather have an impact on the long term perspective. Instead, the immediate performance of soil improvers is directly dependent on the content of bulky organic matter as stated in the report. Therefore, it could have been advanta-geous only to consider the content of bulky organic matter in the fitness for use criteria and to deal with the other aspects under the eco-label criteria.

Environmental fields

As already outlined in the definition of the soil improver product group, the study was only dealing with branded soil improvers which for the most part excluded soil improvers used in the professional sector since they are rather purchased in bulk than as branded products.

In the report emphasise was put on processing routes of the major constituents - mainly organic bulk matter - in the soil improvers whereas potential impacts of the minor constituents like synthetic and/or inorganic materials were not considered. Two major processing routes of the organic matter in the soil improvers were identified and the study was limited to examine potential impacts connected to these two major routes. The two major processing routes were the processing route of natural deposit-based materials and the processing route of waste-based materials, where the latter was further sub-divided in three distinct waste-based processing routes.

The life stages of production, distribution and use were considered in connection to the major processing routes. For the included life stages potential impacts were examined in the areas prescribed in the EC Eco-Labelling Directive. These impacts are waste, soil pollution and degradation, water contamination, air contamination, noise, consumption of energy, consumption of natural resources and effects on eco-systems.

The remaining two life stages - namely pre-production and disposal - were excluded on the basis of a number of considerations:

Natural deposit-based materials:

The processes were considered as being the natural processes in which the deposits were created and laid down and as such, out of the scope of environmental impacts related to mans activities.

Waste-based materials:

The processes considered were the upstream processes generating the waste. These processes were excluded since:

	It would arise insurmountable practical difficulties to describe all the processes that potentially could be actual and therefore, to operate the eco-label scheme.
	Many of the potential environmental problems associated with these upstream waste processes arise primarily from the waste itself. By using the waste as raw material for soil improvers, these problems are eliminated or diminished.

Disposal:

For materials processed by either of the two major processing routes the phase of disposal was judged to be without relevance since the soil improvers are being consumed during the use phase.

The above mentioned areas are only indicative since all of the environmental fields were mentioned in the report but often just stated as being without relevance or significance with respect to soil improvers without presenting any arguments.

In other studies the pre-production phase is normally regarded as being the phase in which the raw materials are extracted and processed i.e. including all the processes until the actual production of the product. Thus, for the processing route of natural deposit-based materials the phase of pre-production could with advantage have been included.

For the waste-based processing routes the arguments for exclusion of the pre-production phase appear reasonable as long as transportation of the waste to the production site and potential waste segregation are considered, which is the case.

The exclusion of the waste aspect in connection to the use phase is questionable since any potential residues (heavy metals, resistant compounds etc.) of the soil improvers in the soil can be considered as being a waste product of the soil improvers. In that case, the residues should be regarded as any other in- and output in connection to the soil improvers life cycle and not only dealt with as a fitness for use aspect.

Few aspects of occupational health and no aspects of potential risks of major accidents were considered.

Functional unit

No functional unit was defined in the report and the concept was not discussed. However, in the impact assessment the consumption of energy was calculated per tonne produced soil improver meaning that the mass of produced soil improver for each processing route was used as a basis of comparison and therefore, implicitly as a functional unit.

It is questionable whether the mass of produced soil improver constitutes an equal basis of comparisons since - as mentioned in the report - the performance of a soil improver during use rather is dependent on the content of bulky organic matter than on the total mass of soil improver. The degree of putrefaction of the organic matter used in the soil improver or the ratio between the organic matter and the bulky matter content could determine whether the mass is an equal basis of comparison.

Key features

A screening LCA was performed using the term "life cycle overview". No key features were selected, instead the life stages of relevance for the environmental performance of soil improvers were selected for the detailed LCA. Thus, the various life stages were looked over and the reasoning for excluding the phases of pre-production and disposal was mentioned. Furthermore, the coherence between the fitness for use aspect and the environmental performance of soil improvers were discussed.

The screening LCA was based on processing routes of the soil improver constituents rather than on the constituents themselves. There were a number of reasons for this. Some of the reasons were:

An almost infinite range of materials of organic origin can potentially be used as raw materials for soil improvers raising practical problems in order to operate the eco-label.

	Common processes may have common impacts regardless of the type of organic material processed for the soil improvers.
	All soil improvers can easily be separated into two major processing or production routes, namely a processing route of natural deposit-based soil improvers and a processing route of waste-based soil improvers.

The waste-based processing route was further divided into two broad process routes, on which the analysis was based.

Process route of natural deposit-based soil improvers:

Process routes of waste-based soil improvers:

Furthermore, a qualitative description of the processing routes was given summarising the various processes connected to each route throughout the different life stages. Parallel to the summary a list of key words was included highlighting the various processes within the processing routes.

It was emphasised that many of the branded soil improvers are composed of mixtures of the above mentioned processing routes, but in most cases a single material, processed following a single processing route, makes it up as a dominant constituent.

The idea of using processing routes seems good considering the almost infinite diverse range of materials of organic origin that potentially can be used in the production of soil improvers though it might cause some operational problems in terms of how to allocate the identified emissions of the processing routes to the final soil improver products. The majority of the soil improvers is composed of mixtures of materials from the different processing routes and can therefore not directly be related to the emissions of the separate processing routes.

3.5 Comparison of three different life cycles analysis

It has been shown that many differences between the studies occur when we get into details. In this part some of the main differences within special selected areas will be discussed. The structure of this part will be the same as in the parts concerning specific studies.

3.5.1 Goal definition and scoping

Purpose of the studies

While being aware that it is a very difficult task to compare the purpose of different studies, it is, however, very important that the same sort of thoughts are made in the initial phases.

Concerning the purposes of the studies it has been revealed that there are some variations. In the study of light bulbs it was explained that the purpose of the study was to catalogue and sum potential adverse effects on the environment of the light bulbs in order to provide an objective appraisal of the environmental impact of the light bulbs and to facilitate comparison between the different light bulbs within the same product category. In the study of cooling appliances it was mentioned that the purpose of the study was to promote the development and employment of cooling appliances which, while complying with safety and performance requirements, have a reduced environmental impact. Further, it was mentioned that the promotion of the criteria should be achieved by giving a clear and complete picture of the interactions that refrigerators and freezers have with the environment throughout their life cycle. Finally, in the study of soil improvers it was mentioned, that the purpose of the LCA study was to identify which features of the soil improvers that have a significant effect on the environment and to determine at which stages in the life cycle they occur.

On this basis it seems obvious that besides the common purpose of establishing proposals for eco-labelling criteria for the specific product group there is a great level of variation in the details and also in what seems to be the most important aspect in the selection and establishing of criteria. E.g. in some studies it is mentioned that the purpose is to promote the production of cleaner products while the focus in other studies is placed on how the comparison of different products within the same product group can be done.

Product group definition

The way the definition of the product groups is handled in the studies is very different. In the study of light bulbs, the definition of the product is specified very much with respect to the outfit of the product while aspects concerning the identity of the consumers is toned down. In fact, this procedure leads to a very narrow rank of products which exclude many types of products. In the study of refrigerators and freezers a number of divisions leading to a very large rank of specified product types is introduced. This approach does not seem to be very visionairy since it illustrates the status quo of the products very well but it does not reveal specific advantages or disadvantages of the products. In fact, except in a very few special cases this does not lead to exclusions of a number of product types. It rather leads to generalisations that simplifies the work on criteria. In the study of soil improvers the starting point is a mixture between a general definition based on the technical performance of the products and at the same time a demand saying that the products shall be branded. This approach is at the same time broad because of the definition based on the function of the product and narrow because of the demand on branded products.

In the regulation it is a prerequisite that the criteria deal with existing products. In practise this demand leads to some exclusion of new not very settled products at the market. This is especially obvious in the case of refrigerators/freezers and in the case of soil improvers, while it seems to be less limiting in the case of light bulbs.

Scope and system boundaries

The investigation on how the scope and system boundaries have been set, revealed some variations, too.

In this part, the three different approaches to life cycle studies will be compared in order to illustrate which parts of the life cycle phases that have been included in the considerations.

As can be seen from the overview matrix, Table 3.4 three of the fields from the indicative matrix have not been considered at all or only to a very limited extent in the three studies investigated in the Prestudy. These are a) soil pollution and degradation, b) noise and c) effects on eco-systems. Waste relevance has only been considered to a minor extent. In the study on light bulbs, most emphasis is put on consumption of resources and energy, and emissions related to energy consumption, all other environmental matters are considered of minor importance.

On the basis of the first three studies it can be observed that the LCA centres the work on certain contributions to the environment no matter what the product group is. Cooling appliances, soil improvers and light bulbs are very different groups of products and therefore one would have expected a more varying picture of which part of the life cycle that is contributing mostly to the environmental impact than what this screening of the studies has shown. In the next part this shall be further investigated.

Table 3.4
A matrix showing the areas considered in the LCA of the light bulbs, refrigerators and freezers and soil improvers.

Pre-Prod. = Pre-Production

Prod. = Production

Distri. includ. Pack. = Distribution including Packaging

a = Considered in the LCA of light bulbs

(a) = Only briefly considered in the LCA of light bulbs

b = Considered in the LCA of cooling appliances

(b) = Only briefly considered in the LCA of cooling appliances

c = Considered in the LCA of soil improvers

(c) = Only briefly considered in the LCA of soil improvers

Environmental fields

In principle, non of the studies exclude themselves from any specific fields. Some of these aspects are already discussed in the section above dealing with scope and system boundaries. In this section only the main issues will be drawn out. Especially, the focus will be put on issues that are horizontally orientated.

In short, the consumption of resources and energy (ressources), the waste relevance and the contamination of air and water which to some extent are derivates of the consumption of ressources are the most investigated parts of the studies. In fact, in one of the studies only the consumption of energy and ressources has been considered thoroughly. The soil pollution and degradation, noise and effects on eco-systems do not seem to be investigated at all in any of the studies.

The aspect of packaging is not dealt with in any of the LCA approaches. In stead, criteria for packaging materials are set up on different basis. E.g. in the light bulb study criteria for packaging are suggested, but no life-cycle analysis on packaging¹⁵⁾ is carried out. While in the two other studies the aspects on packaging are ignored.

In one of the studies, the study of light bulb, it is argued, that experience has shown that the potential impacts arising from construction of plants and tools, the development of infrastructure and needs of the workers only to a minor extent contribute to the total potential impact of a product and therefore these factors are excluded from the study. In the other studies no attention is paid to these aspects.

Generally, aspects relating to occupational health or risk of accidents are not considered in the LCA. This is especially conspicuous in the study on cooling appliances since many hazardous chemicals (lubricating oils, paints etc.) are used in the production phase. The risks of accidents were considered in connection with some of the alternative refrigerating and foaming fluids.

Functional unit

In any international contexts it is generally recognised that the definition of a functional unit is necessary when it comes to the comparison of different products. Therefore, it is interesting to note that in two of three studies, no functional unit has been defined.

In the study of light bulbs, a functional unit, although this can be criticised, was defined. In the study of soil improvers no functional unit was defined and the concept was not discussed. However, in the impact assessment some comparisons were made on the basis of one tonne produced soil improver. In the study of cooling appliances no functional unit was defined either. The matter was briefly touched and the comparison between different products was done by comparing two defined standard models. By defining standard models, the analysis in the study is very limited since most of the in- and output is kept constant while only a few key features, which are selected beforehand, differ from one product to another.

Establishing of key features

The way of handling the establishing of key features is similar in the studies of light bulbs and cooling appliances, while the approach is different in the study of soil improvers.

In the study of light bulbs and the study of cooling appliances environmental indicators and environmental features were selected. In both cases, however, this was done before the inventory. This is a very prejudiced way of handling an LCA whether it is meant as a screening or not. In the study of soil improver more care was taken to the screening LCA. However the screening LCA was carried out on the basis of qualitative process routes.

In the LCA of light bulbs and refrigerators/freezers, not only the approach but also the appointed key features are similar. In the light bulb study the environmental indicators were used as parameters for the analysis and indicated the direction of focus for the analysis. In this matter, the environmental indicators can be interpreted as being equivalent to "key features".

In the light bulb study the following environmental indicators were selected:

Natural resources:	energy used,
	mass used,
	scarcity index of elements used.
Emissions to air:	particulate matter ,
	greenhouse gases,
	acid forming gases,
	critical volume.
Emissions to water:	chemical oxygen demand (COD) ,
	suspended matter,
	critical volume.
Solid waste:	mass generated.

The critical volumes of water and air were employed as indicators of toxicity to man and were mentioned to be based on emission loadings to air and water normalised after the toxicity standard of "MAK".

In the study of cooling appliances the "environmental features" were selected:

Natural resources:	consumption of virgin raw materials,
	consumption of recycled materials,
	water consumption,
	energy consumption.
Emissions to air:	direct green house gases,
	indirect greenhouse gases,
	uncertain greenhouse gases,
	ozone depleting gases,
	acid equivalents,
	toxicity (critical volume).
Emissions to water:	chemical oxygen demand (COD),
	biological oxygen demand (BOD),
	toxicity (critical volume).
Solid waste:	mass generated.

The critical volume approach was used in the case of cooling appliances as well.

Process flow charts

In all three studies, process flow charts were included and in all three studies the information that could be obtained from the flow charts were either very limited or it was not used. In one of the cases, cooling appliances, the flow charts were not made on the product but on the auxilary products. Anyway, the most common experience obtained from the studies is that the information that could have been obtained from flow charts is not revealed.

Allocation procedures

In the present studies much attention was not paid to allocation procedures. The studies were in some way general, e.g. the used flow charts did not include connection to public plants neither did they mention that several production chains could take place at the same factory. When those aspects are not considered carefully they can not be incorporated as a natural part of the study.

The comments of the general approach that has been used in the three studies also applies for the proposed criteria. In all three cases the criteria did not cover the appliance procedure, and thereby difficulties in the assessment procedure including allocation procedures were not revealed.

Inventory data

Concerning the inventory data it seems to be common but unfortunate that the data are mixed with aggregated data that could have been presented in the classification in the impact assessment. That has been the case in the study of light bulbs, soil improvers and cooling appliances. The data that have been depicted are in most cases presented as data that are most suitable for the purpose. Since specific data for the investigated products has not been collected. The data come from more or less common data bases. That may be the reason why the data sometimes seem very untransparent and in general too many tables have just been tranferred from other reports without having been given much thought. It is understandable and acceptable to include data depicted from different sources. However, when this is done it must be discussed and justified.

Classification

No real classification was made in any of the studies. In two of the three studies, the light bulb study and the cooling appliances study, some classifications were made although indirectly since the "environmental indicators" and the "environmental features" constitute a form of classification. However, some areas were without reasoning left out of the classification, e.g. ozone depletion, terrestical ecology. In the study of soil improvers neither classification nor characterisation was done.

Characterisation

As already mentioned characterisation was not made at all in the study of soil improvers. In the study of light bulbs special attention was given to global warming, acid deposition and toxicity to man (air and water). In the study of soil improvers special attention was given to global warming, ozone depletion and toxicity to man (air and water). Further, in the light bulbs and cooling appliances studies some focus was also put on resource consumption. The global warming was in both studies expressed in terms of CO2-equivalents, ozone depletion was expressed as ODP relative to CFC-11, acid depletion was expressed in SO2-equivalents. In both studies toxicity to man is expressed in terms of a critical volume approach. In both cases the BUWAL study and a mixture of German and Swiss MAK (and sometimes MIK) values was used. In generel, consumption of resources was not paid much attention in any of the studies.

Valuation

The valuation was performed differently in each of the studies. In the light bulb study the valuation was performed primarily on the basis of a scarcity index. There was, as mentioned in the section concerning the impact assessment on light bulbs, not paid any attention to the actual consumption per year of a certain resource but only to how scarce the resource is considered to be. In the soil improver study some ranking systems based on qualitative thougths were made. The ranking categories were: no-, low-, medium- or high significance and were based on the qualitative data collected on soil improvers. In the study of cooling appliances some rating was used, too. Only two aspects were identified as important, the rest of the aspects were identified as moderate.

3.6 Conclusion of the Prestudy

The Prestudy shows a wide range of methodological approaches for what is seen as equal starting points for solving parallel tasks at first sight. The different outcome cannot just be seen as different ways of handling the problems concerned. It is also a matter of different product groups which requires different methodological solutions. However, in order to ensure a harmonised proces of criteria development it is advantageous to use same methodlogy. In the following chapters the remaining product groups will be analysed differently in order to be able to identify the links between criteria and background reports.

⁸ The right abbreviation is "MAK" and not "MAC" as used in the report; "MAK" stands for "Maximale Arbeitsplatz-Konzentration" = "maximum concentration at the workplace") which are Swiss occupational standards.

⁹⁾ This class did also include those (very few) appliances with one door and an inner, separate, 4 stars compartment.

¹⁰⁾ A division between virgin and recycled materials was made beforehand.

¹¹ It was not mentioned which source the ODP values were taken from.

¹² The direct and the indirect GWPs were taken from the International Panel on Global Warming (IPCC, 1992) reflecting a 100 year scale. The uncertain GWPs were taken from (RIVM, 1991).

¹³ It is not clear which gases - nor which potentials - that are considered to be the indirect GWPs. A list is included in the report but it only indicates whether the different gases show sign of indirect GWP without presenting any values.

¹⁴ It was not mentioned where the concept of AEs was taken from. Normally, it is NOx that is considered while quantifying the potential of acid deposition. It is not clear whether NO - assuming previous oxidation - actually was included in the figures for NO2. Hydrogen flouride is often considered as contributing to acid deposition, too.

¹⁵⁾ At the time (1992) there was an Italian study on eco-labelling of packaging (21) going on. The criteria are preliminary and that the results of the Italian study are awaited.

4. Comparison with other selected studies

In this chapter the choices taken in other 9 studies will be described shortly in order to reveal similarities and dissimilarities in the chosen LCA approach.

In chapter 3 "Methodological aspects from the Prestudy" many LCA methodological aspects were highligted. Since the studies were prepared in the early 1990´ies the impact assessment methodology within LCA were not very developed. This has not necessarily led to wrong conclusions but the impact assessment framework at that time (medio ’90) is not comparable with todays impact assessment framework. However, the goal and scoping was much more developed within LCA. In chapter 4 "Comparison with other selected studies" the focus naturally will be on the most eco-labelling relevant part of goal and scoping. In chapter 5 "Methodological aspects analysed on the basis of the adopted criteria" the studies are analysed though the criteria and thereby the result of the impact assessment will be emphasised.

On the basis of chapter 3 "Methodological aspects from the Prestudy" and in order to structure the reporting 5 areas are depicted. These are:

	fitness for use,
	functional unit,
	purpose of study,
	product group definition,
	methods for identification of environmental key features.

4.1 Fitness for use

The handling of fitness for use varies from study to study. However, even though it has not been mentioned by name in the three studies of the Prestudy it has not been neglected in any of the studies. On the basis of the Prestudy it seems to be very common to identify allready existing standards which, if they are met, can be a measure for the fitness for use of the products in question.

In the Prestudy it has been looked upon how the fitness for use has been handled. In the text to follow the handling of fitness for use in other investigated studies is presented.

In the study of detergents it is stated that "Detergents are highly competitive products on the market. The dosage recommendation is one of the key criteria and weighted strongly by a weighting factor....."¹⁶. Furthermore a washing performance test is proposed as a measure for how fit the product is for its purpose.

In the study of hairsprays (December 1992, p. VI-15) many considerations concerning fitness for use of hairsprays are presented. The overall goal of these thoughts can be illustrated by the following text "All products qualifying for eco-labels must be fit for use. Unfit eco-labelled products, however environmentally benign, would not be particularly useful and would damage the credibility of the programme". However, this subject is further elaborated and it is stated, that a standard does not exist to be used with respect to the performance of hairsprays at present. The authors to the report therefore propose some kind of test that includes testing for "holding power, duration of hold, drying time, ease of brushout and degree of removal by shampooing" (proposed by French experts). It is further mentioned that the testing should be performed by two experts nominated by the manufacturers of hairsprays in each member state and that no two experts of a member state should come from the same company.

In the study of packaging (June 1992) aspects concerning fitness for use is not considered nor mentioned. The study is still to be finished.

As a result of the study of paints and varnishes a set of criteria of fitness for use is placed. The fitness for use criteria for paints deal with the hiding power of the paint in question. The fulfilment of the criteria is proved by compliance with an ISO standard. The fulfilment of the criteria is proved by compliance with another ISO standard. As in the study of hairsprays many considerations were made in the light of correlation between environment and performance. In this case it is obvious that if the paints do not hide or if the varnishes are not resistant it implies a larger consumption of the product and this could imply a larger burden to the environment.

In the study of paper products the issue of fitness for use is dealt with only in an indirect manner. However done in an indirect way, the subject of fitness for use is touched upon in more parts of the report (Miljøprojekt nr. 179, 1991, p. 15, 29, 40-41), and later in the progress of the development of criteria it was decided that the weight and the quality of the product is correlated positively. This means the higher content of fibres pr. ton product the higher quality. In the first study the fitness for use issue is discussed in connection with matters like "the grammage effect" (p. 15), "the quality aspect" (p. 15) and "paper in comparison with other materials" and "paper in combination with other materials". However, mentioned several times, it is not done in a proper way in the first report but considerations were made later. Later research in the study of paper upon fitness for use showed, that the subject happened to be treated in a correct way, firstly. Further, for the tissue products a sort of correction factor for the absorption of liquid was added in order to take into account the fitness for use. The factor was developed by the industry.

In the study of thermal insulation fitness for use was, however not exhaustive, considered carefully (23, p. 18). The considerations are primarily centered on the thermal performance respectively the thermal properties and the thermal conductivity. As a consequence of this fact a criterion is settled with the purpose of a minimum requirement on the thermal performance. This has to be proved by compliance with an ISO standard. No criteria are settled with respect to the applicability of the different thermal insulation products placed at the marketplace.

In the study of textiles (March 1994, p.55) the aspect of fitness for use is taken care of in the setting of criteria. In the criteria a number ISO standards which the product has to meet are mentioned. These standards deal in general with matters like mechanical and physical properties, colour fastness and for T-shirts a spirality test as well.

In the study of washing machines (August 1992) fitness for use is touched several times. As a conclusion to these discussions it was decided to set a performance criteria. The performance criteria deal with the machines’ ability to wash. The criteria are to meet the requirements of a certain test method in order to prove that the machines are able to wash. The standard is a national standard since an international standard does not exist.

4.1.1 Discussion of fitness for use

The discussion presented below is divided into four main areas. These areas are if the fitness for use is defined at all (and how) in the studies: if the proposed demand of fitness for use is relevant, if there is a correllation between the defined fitness for use and the environmental performance of the products and if the fitness for use demand is based on the results obtained from the LCA study.

In all the investigated studies but packaging fitness for use is considered. This does not only mean, that the subject has been considered but also that demands are proposed in all studies except packaging. In many of the studies the criteria concerning fitness for use is based on some sort of (international) standard. This is the case for light bulbs, refrigerators and freezers, detergents, paints and varnishes, thermal insulation, textiles and washing machines. The proposed standards are international recognised in all studies but the study of washing machines. The standard proposed for washing machines is national. In the study of light bulbs criteria that are not based on standardisation are proposed as well. For soil improvers, hairsprays and paper no standards are mentioned, but the matter is handled in different ways. For soil improvers a number of fitness for use demands have to be met, for hairsprays an expert panel is proposed and in the case of paper the problem is solved by the use of the functional unit and if relevant a correction factor.

The considerations concerning fitness for use is on the one hand manyfold while on the other hand not always brought into effect in a useful way. In many cases this is because it is a difficult task. In the case of light bulbs it would have been useful to propose a criterion concerning the provision of light for the purpose of use throughout a minimum time period. In the case of soil improvers it would have been useful to propose a fitness for use criterion concerning the content of bulky material. For thermal insulation the life time of the product would have been relevant. The life time of the product was considered thoroughly but an international recognised standard did not exist.

In more of the studies it is identified that there is a positive correlation between the reduced environmental burdens and the (quality of) fitness for use performance of the products. This is the case of light bulbs, refrigerators and freezers, detergents, packaging, paints and varnishes, thermal insulation and washing machines.

The correlation between the environmental aspects and fitness for use is only identified through the use of LCA in very few studies. Even though this aspect is mentioned in more reports this is then caused by the imagination of the authors. In fact the correlation is only identified through figures in the study of detergents, hairsprays (partly) and paints and varnishes. In the study of soil improvers the exclusion of the waste aspect in connection to the use phase is questionable since any potential residues (heavy metals, resistant compounds etc.) of the soil improvers can be considered as being a waste product, e.g. contributing to soil pollution one of the impacts not dealt with in the LCA. In that case, the residues should be regarded as any other in- and output in connection to the soil improvers life cycle and not only dealt with as a fitness for use aspect.

The limited use of LCA means that even though the results are reliable, they are not actually proved in the studies. This is really a pitty since one of the very basic ideas of the LCA is to challenge dogmas and thereby verify these or the reject them. Thus, the reason for focusing on fitness for use is the credibility of the label, e.g. a bad functioning eco-labelled product could lead to credibility problems to the label in general.

4.2 The functional unit

The functional unit is the key measure of environmental performance which the system that is investigated delivers. It has to be clearly defined, measurable and relevant to input and output data. Examples of a functional unit is "the amount of detergents necessary for a standard household wash" or "the packaging used to deliver a given volume of beverage" (16).

In this section it is described if a functional unit is defined in the studies and whether the defined (or non-defined) functional unit is used in the studies. In the situations when a functional unit is not defined, the way the comparison among different products has been handled is described. Limitations of the defined functional unit, inclusion of other functions in the definition of the functional unit and the workability of the functional unit is discussed.

The picture obtained from the Prestudy of the definition and use of the functional unit is very inhomogenous. The results from the other investigated studies will be presented in the following text. Like it was shown in the Prestudy it is varying to which extent attention is paid to the definition of the functional unit and like the generel trend from the Prestudy, many difficulties and inaccuracies were introduced when the functional unit was defined.

In the study of detergents no functional unit was defined. (11). In the criteria document of March 1993 "the criteria are related to Gramm (g) per Wash respectively Gramm per kg dry textile and the critical dilution volume in liters per wash (l/wash). Provisionally g/wash is used but it has to be converted to g/kg textile as the heavy duty detergents are related to: dosage per 4,5 kg load (dry textiles) and the low duty detergents to dosage per 2,5 kg load in the washing machine".

Thus, some sort of unit for comparison was established by the g, g/wash, g/l and g/kg units. The matter of the ability to wash and clean clothes - the washing performance - was discussed but a functional unit was not defined.

In the studies the data connected to the inventory and/or the impact assessment are not related to any firm unit. Some of the data are related to the g/wash as mentioned above. Other data are connected to predicted environmental concentrations, PED while others use other units.

As mentioned above the criteria are related to units for comparison but not what is normally meant to be a functional unit.

In the study of hairsprays (7) a functional unit was defined. This was determined to be the volume of liquid formulation. The quantity used was determined to be an equivalent pump litre (p. V-3).

The functional unit was not used in the inventory stage of the LCA. It was argued that this is not necessary in order to determine which stages of the life cycle that contributes the most to the environment (IV-8).

The criteria are set up with the equivalent pump litre as a basis for comparison.

In the study of packaging (21) a functional unit is not defined. The subject is not discussed but in the section of the report dealing with "Packaging as a group of products" some considerations concerning "Determining a reference base for packaging" are made. However, the reference base is not used in the study. Criteria are not established in the study.

In the study of paints and varnishes "the functional unit used for analysing the inventories of the paint is: the amount of paint necessary to cover 20 m² with an opacity of 98%" (8, p. 9). Further, in the section dealing with "The General Methodology for Life Cycle Inventory", it is stated that the flows listed in the Life Cycle Inventories are not calculated for physical quantities of the products, but on the basis of the performance of an equivalent service.

The criteria of paints and varnishes are split up into several groups. These groups are gloss and non-gloss paints, and water- respectively VOC-based paints and varnishes. In the report (8) it is argued (at page 12) that the classification is based on the function of the paints and stems from the discussions of the ad hoc working group members about the volatile organic componds content of the paints which have shown that the VOC content and various characteristics of the paints (washability, gloss, hiding power, corrosion resistance ...) are closely related through the Pigment Volumic Concentration (PVC). This split up on the basis of funtion makes it look like either another definition of product group should have been chosen or the criteria should have been presented in a more general manner. Seen from a Danish perspective another understanding could to a much wider extend have lead to criteria promoting non-VOC products.

Some of the criteria are related to the functional unit. Some of the criteria are not related to the defined functional unit directly. These are set up with a general purpose like general requirements with respect to information to the end user.

In the first published report on paper products (12, 13, 14) a functional unit was not discussed and it was not defined. Some attention was paid to the so-called grammage effect but this matter was not further developed. The data used for the inventory were based on a per kilogramme basis.

The set of criteria that was developed first also related to a kilogramme basis. Except for the criteria that are related to more general issues like sustainable forestry.

At later stages of the work it was concluded that the per kilogramme basis was the right choice, and it was concluded that the grammage effect was the best factor to use. For the case of kitchen rolls that was later corrected by a factor of absorption.

When a per kilogramme basis is chosen as a functional unit for these types of products, this does to some extent include a measure of quality as well.

For textiles the definition of a functional unit was paid much attention, and it was decided to use kilogramme of fabric as a basis. The data in the inventory are not related to a specified functional unit.

The criteria are related to the defined functional unit except in the situations where this is too rare, e.g. the fitness for use criteria. Some of the criteria deal with general environmental aspects and these are not related to the functional unit.

In the study of thermal insulation the functional unit was defined very early in the process of developing criteria. The functional unit includes some quality aspects, e.g. the products thermal insulation property, while the durability of the product and e.g. technical building characteristics as carrying capacity are not included.

The data of the inventory are presented both with respect to per kilogramme basis and with respect to per functional unit basis.

The criteria are in general related to the defined functional unit. Some of the criteria deal with general environmental aspects and these are not related to the functional unit.

In the study of washing machines no functional unit was defined. However, the data in the inventory use a per kilogramme basis for comparison and the criteria, except the general related ones, are set up with a per kilogramme basis.

4.2.1 Summing up the results of the going through of all studies

As already indicated in the introduction to this section it is varying very much to which extent a functional unit is defined or for the matter of that if and how the functional unit is used in the study and in the criteria. In many of the studies it is very hard to determine whether one could say yes or no to these questions. However, in Table 4.1 it is indicated with the sign of plus or minus what is the closest answer to these questions. The table can not stand alone but it is meant to be a help in order to get an overview.

Table 4.1¹⁷
In the table it is indicated - by the use of "+" and "-" - to which extent the functional unit is defined and used in the studies.

More of the functional units include to a certain degree other aspects than the primary function. This can be aspects like life time and quality. Life time of the products is included in the functional unit of light bulbs. In the studies of hairspray, paints and varnishes, textiles and washing machines life time is a part of the study, e.g. durability is discussed. In these studies it has been chosen not to include the matter in the functional unit but the subject has been taken care of when relevant in other ways, e.g. in the criteria or in the fitness for use criteria.

The quality of the products is a very general issue in the investigated EU eco-labelling studies. In most cases it is argued that for the credibility of the scheme it is very important that the coming-to-be-eco-labelled products are of high quality.

For some of the products the quality aspect is partly included in the functional unit. This seems to be the case in the study of hairspray, paints and varnishes and paper products.

Quality

The quality aspect is further discussed in the section dealing with the setting of criteria.

The definition of product groups and the definition of functional units are areas that arise too many potential conflicts. This is often because the functional unit can cover a wide area of product groups which in fact are more (different) product groups. This conflicting situation arises in several of the studies where a functional unit is defined. That is the case for light bulbs and partly the case for cooling appliances, hairspray, paints and varnishes, paper, textile and thermal insulation. This situation can be difficult to handle and one has to take care in order to make exact references and definitions.

4.3 Purpose of the study

In this section it is described how different eco-labelling studies have handled the item "purpose of the study".

Several of the investigated studies refer to the eco-labelling regulation in the description of the purpose of the study. It is, however, not the same articles of the regulation they are referring to.

In the study of paper (12, 13, 14) there is a reference to article 1, section 3 defining environmental impact in the following way: "The reduction of the environmental impact will be achieved through minimisation of:

	use of natural resources and energy resources,
	emissions into air, water and to soil,
	generation of waste and noise

and through the maximisation of product life, and where applicable, through the use of clean technologies to ensure a high level of environmental protection".

In the study of thermal insulation reference is made to article 1 in it's full length. The text in the report of thermal insulation states that the "criteria should be able to meet the demand of the Council Regulation, which in this context is defined as promotion of design, production, marketing and use of products which have a reduced environmental impact during their entire life cycle and at the same time to provide consumers with better information on the environmental impacts of products(23, p. 23). The same reference to the Regulation is made in the study of textiles (15, p. 4) and detergents (11, p.2).

As mentioned above the paper study is divided into two parts. In this context the scope and system boundaries will be considered on the basis of the full study. The first part is a qualitative description rather than a quantitative collection of data upon which the most important phases with respect to the environment have been pointed out. This report was made by an expert (from the Swedish Pulp and Paper Research Institute) and discussed among experts and to some extent member states within the EEC - a sort of open peer review was made then.

In the study of paints and varnishes articles 4 and 5 of the Council Regulation are emphasised, and it is stated that "three kinds of criteria are distinguished:

	the ecological criteria, which are determined according to a global approach (from cradle to grave),
	the criteria which refer to general principles (toxicity...),
	the fitness for use criteria, to ensure that the product should have at least a minimum level of quality."

Some of the studies do not refer to the Council Regulation but state a purpose of the study.