Assessment of Criteria Development within the EU Eco-labelling Scheme

5. Methodological aspects analysed on the basis of the adopted criteria

5.1 Relations between life cycle screening and criteria for bed linen and T-shirts
5.2 Relations between life cycle screening and criteria for detergents
5.3 Relations between life cycle screening and criteria for kitchen rolls/toilet paper/copying paper
5.4 Relations between life cycle screening and criteria for copying paper
5.5 Relations between life cycle screening and criteria for paints and varnishes
5.6 Relations between life cycle screening and criteria for washing machines


In chapter 4 "Comparison with other selected studies" special focus was put on goal and scoping (fitness for use, product group definition, functional unit and purpose of study) and on methods for identification of environmental key features. The aspects in question are discussed under the impression of what have been done for each of the investigated product groups.

In the present chapter (5) the LCA methodological aspects are analysed on the basis of adopted criteria. The focus is then the opposite way around since it starts with the criteria and then goes backwards to check the correlation to the earlier identified key features. The product group that are brought into attention is textiles (bed linen and T-shirts), detergents, tissue products (toilet paper and kitchen roll), copying paper, paints and varnishes and washing machines.

Thus the linkage between the property of the product, the approach in the background analysis and the design of criteria are analysed for the product groups where criteria currently are adopted under the EU-Scheme and which has not been analysed in the Prestudy. This is done in order to investigate if some sort of pattern appears.

The analysis are done by categorising the background for the criteria in a table related to respectively the criteria, LC-screening, life cycle phase, cleaner technology aspects, sourcebasis for criteria and basis for levels.

For each product this is done followed by a short description of the particular categories.

In chapter 6 "Features of criteria of the established product groups" the methodological features from this chapter are further discussed.

In the tables in this chapter an overview of the relation between a number of features and the adopted criteria are given. "+" means that the feature is reflected in the adopted criteria. "-" means that the feature is not reflected in the criteria.

5.1 Relations between life cycle screening and criteria for bed linen and T-shirts

In this section an overview of the specific eco-labelling criteria for bed linen and T-shirts is given with respect to the above mentioned aspects: LC-screening, life cycle phase, cleaner technology aspects, sourcebasis for criteria and basis for levels. The overview is presented in a table and thereafter shortly discussed.

Table 5.1 Look here!
Bed linen and T-shirts (cotton/polyester)

Criteria

The criteria cover quite many processes since both cotton and polyester are covered by the product group definition. Further a garment potentially undergoes several manufacturing and processing stages from the pre-production to the end use. Processes which when carried out without attention to environmental issues will have significant environmental impact caused by the character (toxicity, ecotoxicity and other impacts) of the substances used.

There are 12 criteria related to environmental issues, and additionally fitness for use criteria based on mechanical and physical properties and the colour fastness of the product is included.

Criteria concerning the finish treatment were changed by the EU-Commission. Originally the LCI pointed out specific detergents to be banned within this process. The final criteria only put a ban on formaldehyde.

The fitness for use criteria reflects the fact that the quality range of the product is not enabling an adequate definition of the functional unit. Therefore the fitness for use aspect is a set of criteria placed beside environmental related criteria to ensure that the quality is not decreased as a consequence of reduced environmental impact.

Relation to LC-screening

The criteria are based on a comprehensive LCI which is interpreted into criteria by a life cycle impact assessment. The life cycle impact assessment is focused primarily on assessments of substances. These assessments have been done by a number of organisations beforehand. They are not prepared especifically for the eco-labelling studies.

Life cycle phase

The criteria focuses on the pre-production phase and fitness for use. This is partly explained by the character of the product. The pre-production phase (pre-production is interpreted as cradle to final fabric) covers the use of several substances with severe environmental impact. The substances used or added in the pre-production phase also have influence on the physical property in the use phase.

The choice of either cotton or polyester garment influence heavily on the consumption of water, energy and detergent during the use phase. However it was concluded early that eco-labelling criteria will have little if any influence at all on the consumer’s choice of garment.

The focus on the pre-production and production phase is a selection probably done in order to be able to make it possible to administrate and control the criteria afterwards. In other studies it is showed that for example the consumption of energy and discharge of wastewater are related to the use phase (25) by maintenance (laundry etc.). It is, however, not possible to cover these activities by criteria for the textile products since such activities are linked to the behavior of the user and the equipment he/she uses (washing machines/detergents etc.). This issue will be discussed later in this report.

Cleaner technology aspects

The product group shows very close links between concepts for cleaner technology and cleaner products. Especially for the cotton-based products the pre-production phase is a key feature since the residues (which can be eliminated in this phase) will otherwise cause impacts in the use phase of the product.

Source basis for criteria

The criteria are based on the LCI-report, the following impact assessment and the defined key features. Concerning the fitness for use the criteria refers to ISO-standards.

Basis for levels

The setting of levels are partly based on definitions made by international organisations with specific knowledge for the selected areas. The levels are not part of specific survey of environmental assessment. The levels are directly taken from recommendations, evaluations and assessments from the relevant organisations and researchers, dominated by International Agency for Research of Cancer (IARC), EU lists of chemicals and Ecological and Toxicological Association of the Dyes and Organic Pigments Manufacturers (ETAD).

5.2 Relations between life cycle screening and criteria for detergents

In this section each of the final eco-labelling criteria for detergents are hold against the selected aspects: relation to LC-screening, life cycle phases, cleaner technology aspects, source basis of criteria and basis for level of criteria (how tough they are). The overview results are presented in Table 5.2.

Table 5.2 Look here!
Detergents

Criteria

The criteria are dominated by a point system where levels of substances are linked together. The point system includes all textile chemicals and the environmental impact they cause on the aquatic environment. Beside this system there are criteria related to packaging. Both the point system for detergents and the criteria for packaging criteria are related to quantity consumed per kg of garment washed.

In order to avoid thinning of the products as a method of making them look more environmental friendly a criterion for washing performance is designed.

Relation to LC-screening

The criteria set is widely based on LC-screening, the included market survey and the following environmental assessment. The results are used as a guideline for the design of criteria in order to put the right levels for the different parameters in relation to environmental impact of the substances and the market share of the products affected by the level setting.

Life cycle phase

Much of the effort is pointed towards the use phase and disposal of the product by the wastewater from washing. This is well in line with the fact that the entire product is discharged in the waste water during the one and only time it is used. The environmental impact from the disposal can not be allocated to several cycles of use, and therefore the proportion of the disposal has a major influence of the environmental impact in the entire life cycle.

Cleaner technology aspects

Since the key features are pointed towards the use phase and the following disposal by waste water, the cleaner technology aspects are of low priority in the set of criteria for detergents. The criteria are more related to a cleaner product approach. This priority is based on the relation between the environmental impact and the property of the detergents. By linking environmental parameters to the wash of a certain amount of clothes. The criteria are setting up relations between environmental impact and fitness for use. E.g. an environmental friendly product which is less effective in its main function (cleaning of clothes) can not fulfil the criteria. The fitness for use is part of the demands that are set up by the criteria.

However the property of the product can also affect the production phase. If it is possible to mix an effective formulation with use of less resources like the compact washing powder, the customer will use less of the product and the production per wash unit will be reduced. In this term the product will cause improvements in the pre-production phase and the production phase too.

Sourcebasis for criteria

The inventory is primarily based on research done in the LCI, and the substances are selected by the sensitivity analysis linked to the impact assessment. The fitness for use criteria are based on a logical statement in the LCI concerning the essential importance of the property of the product.

Basis for levels

The levels are based on a linkage between the sensitivity analysis and the market study in order to ensure that the limits only exclude the requested amount of products, i.e. that only a certain part of the market will be able to get the label.

For the enzymes it is not possible to locate any links between the LC-work and the final criteria. One possibility could be that the final criteria is a product of negotiations between members of the AHWG and the EU-Commission.

5.3 Relations between life cycle screening and criteria for kitchen rolls/toilet paper/copying paper

In this section each of the final eco-labelling criteria for kitchen rolls/toilet paper/copying paper are hold against the selected aspects: relation to LC-screening, life cycle phases, cleaner technology aspects, source basis of criteria and basis for level of criteria (how tough they are). The overview results are presented in Table 5.3.

Table 5.3 Look here!
Kitchen rolls/toilet paper

Criteria

The background study covers 3 products: Kitchen rolls, toilet paper and copying paper. Below the criteria for toilet paper and kitchen rolls will be analysed within the same section since it is only parts of the final criteria that differ for these two products. The criteria proposed by the consultants was based on a pointrelation for several emission parameters and renewable fuels - a socalled matrix system.

The aim of this design of criteria was to enable a single set of criteria to cover different kinds of pulp methods, raw material and configurations of non-/ and integrated manufaturing systems.

Concerning the copying paper it was not possible to reach consensus in the AHWG about continuing with the matrix system. Therefore the final criteria were defined by the Commission after long and detailed negotiations with members of the AHWG (mainly industrial organisations and competent bodies) who pointed out that the criteria should be transparent and easy to handle for the holder of the licence. This demand could not be achieved by the nature of the point system since a fixed maximum level for each parameter can not be found before all parameters are known.

The criteria linked to the copying paper were based on the following 4 parameters:

COD: 30 kg per Adt
AOX: 0,3 kg per Adt
S: 1,5 kg per Adt
Energy: 30 Gj per Adt (purchased energy > 18 Gj per Adt).

These maximum hurdles concerned the consumption in the various stages of pulp and paper of the production process. The criterion concerning safeguard of forrests was identical for all 3 product groups. The product groups are presented below.

The criteria were based on research which was pointed towards kitchen rolls, toilet paper and copying paper. The criteria were developed for the matrix system, except for the definition of forest management and fitness for use. The matrix system was designed in order to meet the different environmental profiles of the various pulp processes (e.g. some processes are high at one parameter and low on others).

Relation to LC-screening

The product group concerned was one of the first to be established within the EU scheme. The participation from the different competent bodies was very enthusiastic. Thus much detailed information was added to the inventory by competent bodies from nations where pulp and paper production is a major industrial activity including nations which at that time were not EU-members (Sweden, Norway, Finland).

Life cycle phase

The criteria are mostly pointed towards the pre-production and production phase. This is well in line with the fact that the pulp and paper processes potentially caused servere environmental impact. The fitness for use aspect is an analytical conclusion based on the fact that if the fitness for use property is influenced negatively by environmental improvements, the consumption of the product will increase and by then affect the environmental impact from the pre-production and production phases, caused by an increasing volume of paper for the same specific use.

Cleaner technology aspects

The criteria do definitely point toward cleaner technology in a well defined type of processing (pulp processing and paper manufacturing). The possibilities of developing cleaner products for this group is limited to a few items which are linked to the fitness for use aspect.

Source basis for criteria

The pulp and paper processes have been in focus for several years because of the potential significant environmental impact which ealier on threaten this trade. Therefore source basis for criteria is a combination of the LCI results combined with the demands resulted from international negotiations like PARCOM- and HELCOM-recommendations.

Level settings for criteria

The criteria of the different parameters are linked together in a point load system for which a limit is defined (combined system of linked hurdles and cofficients). There are hurdles for maximum levels for each parameter but it is not possible to state an average level for one parameter before all parameters are known. By then there are no fixed levels for any parameters, but the multiplication factors are developed by an ongoing try and error procedure until the best performing mills could match the cofficients and hurdles no matter what kind of pulp process is used.

The intention of this process was to ensure that the less polluting manufacturer could fulfil the criteria. Improvements were required no matter what kind of technology utilised unless the mills were among the small squad of Best Environmental Performance.

5.4 Relations between life cycle screening and criteria for copying paper

In this section each of the final eco-labelling criteria for copying paper are hold against the selected aspects: relation to LC-screening, life cycle phases, cleaner technology aspects, source basis of criteria and basis for level of criteria (how tough they are). The overview results are presented in Table 5.4.

Table 5.4
Copying paper

Criteria

Relation to LC-screening

Life cycle phase

Cleaner technology aspects

Source basis for criteria

Basis for levels

COD

key feature

pre-
production/
production

(+)

LCI (Haskoning)

Commission decision

AOX

key feature

pre-
production/
production

+

LCI (Haskoning)

Commission decision

Sulphur

key feature

pre-production/

production

+

LCI (Haskoning)

Commission decision

Energy consumption

key feature

pre-production/

production

+

LCI (Haskoning)

Commission decision

Forest management

renewability

pre-production

+

Helsinki Commission

Commission decision


Criteria

The criteria for copying paper were established by a simplified approach based on the inventory for kitchen rolls and toilet paper. The design of criteria was managed by the Commission when the AHWG was unable to reach concensus for the matrix approach that was proposed in line with the design of criteria for kitchen rolls and toilet paper.

Relation to LC-screening

The relation between the LC-inventory and the criteria is not fully obvious. There is a correllation between the identified key features and the final criteria The reason is that the criteria proposed by the consultants on the basis of the inventory were rejected by the AHWG. The Commission developed the criteria (which were later adopted) directly by negotiations with members of the AHWG.

Cleaner technology aspects

The criteria are closely related to the environmental key features defined in the research performed earlier for the other products mentioned. Cleaner technology aspects are indeed linked to reduction of the parameters concerned.

Source basis for criteria

The source basis is related to references used for the former adoption of kitchen rolls and toilet paper. The proposal based on the research was closely linked to the experience and patterns made for the former product groups.

The basis for levels is basicly unknown. The criteria were at first developed with a combined point/hurdle system as the skeleton. After this idea was given up the actual levels of the criteria were placed using the levels in the point system as a reference.

5.5 Relations between life cycle screening and criteria for paints and varnishes

In this section each of the final eco-labelling criteria for paints and varnishes are hold against the selected aspects: relation to LC-screening, life cycle phases, cleaner technology aspects, source basis of criteria and basis for level of criteria (how tough they are). The overview results are presented in Table 5.5.

Table 5.5  Look here!
Paints and varnishes

Criteria

The criteria cover both paints and varnishes for indoor use. The criteria are dominated by the results of the LCI in which it is pointed out that the production of pigments (especially TiO2) is the major environmental key feature for the life cycle of paints.

At the same time the pigments are the major contribution to the essential property of the product: The opacity. Thereby a link between the environmental key features and the fitness for use of the product is established.

The character of the product enable an adequate definition of the functional unit to be linked to the fitness for use and thereby linking the property of the product to the environmental impact. As mentioned earlier, in the LCI the amount of paint for covering 20 m2 is in the range of 1,16 liters to 3,13 liters. These data are further used as a basis for the establishing of criteria concerning opacity where it is demanded that one litre of paint should be able to cover 7 m2.

Relation to LC-screening

The selection of criteria is based on the LC-screening in which the production of TiO2 is highlighted. The LCI was originally based on screening of 4 types of paint, but demands from industrial groups initiated extention of the study to other 7 paints. The criterion related to toxic substances is not based on the inventory. These substances are eliminated by an exclusion method (5%) in the study.

Life cycle phase

The production of TiO2 is part of the pre-production phase. Therefore, the manufacturer of paints and varnishes is forced to select the subcontractor of pigments in order to fulfil the demands required by the criteria.

Several demands are pointed to the use phase of the paints. Both the opacity, the hasardous emissions when drying and the fitness for use is linked to the use phase. Beside that the property of this kind of product leads back in to the life cycle. If the opacity of the product is poor then more of the product has to be used with more emissions from the pre-production phase as a result.

Cleaner technology aspects

The cleaner technology aspects are by the criteria focused on pre-production for which the emissions from production of TiO2 are central.

Since the formulation of the paints (mixing of substances) has a minor environmental impact compared to the manufacturing of raw materials (pre-production), the manufacturing phase does not have a high priority.

Source basis for criteria

The life cycle inventory has been used as a basis for criteria settings. Some of the criteria are developed after the LCI. That is the case for the harsardous substances. The hasardous substances were elimininated from the study by a 5% exclusion level. But by the criteria concerning hasardous substances products containing such substances will be excluded no matter if there are below 5% of the specific substances. It is simply not allowed to add toxic substances to the paints.

Basis for levels

Most levels are based on the LCI. The data used are confidential and only the consultant knows the source. The study does by then not give any information that makes it possible to assess the actual level for the criteria.

5.6 Relations between life cycle screening and criteria for washing machines

In this section each of the final eco-labelling criteria for washing machines are hold against the selected aspects: relation to LC-screening, life cycle phases, cleaner technology aspects, source basis of criteria and basis for level of criteria (how tough they are). The overview results are presented in Table 5.6.

Table 5.6  Look here!
Washing machines

Life cycle phase

The criteria for washing machines are mostly pointed towards environmental parameters linked to the use phase. The reason is that the use phase dominates the contribution of environmental impacts by a large margin (most parameters app. 90%). The data in the report verify this fact.

Relation to LC-screening

The criteria are closely linked to the inventory report and the conclusions pointing to the fact, that environmental impacts in the use phase exceed the impacts of the pre-production and production phase by large numbers.

Cleaner technology aspects

Since the criteria focuses on the use phase of the life cycle very little attention is pointed towards the manufacturing (pre-production and production phase). This is rather obvious due to the fact that the chosen parameters for environmental impact are several times higher during the use phase than in the other phases of the life cycle.

Thus very little attention is pointed towards cleaner technology aspects since these aspects are closely linked to the manufacturing of the product (pre-production and production phase).

Source basis for criteria

Since the environmental impact is dominated by parameters in the use phase the sources that the criteria are based on are not deriving from analysis based on real LCA principles. The sources for criteria are mainly based on data for performance of the product during use. The parameters are not affected by any discussions concerning methodological allocation-, classification-, valuation- or normalisation elements since the variations are only related to quantification of well defined parameters.