Assessment of Criteria Development within the EU Eco-labelling Scheme
6. Features of criteria of the established product groups
This chapter deals with which factors that are linked to the properties of the product
groups. The product groups in question are those for which eco-labelling is adopted. In
chapter 3 "Methodological aspects from the Prestudy" and chapter 4
"Comparison with other selected studies" the criteria of each product
group were analysed separately. In chapter 5 "Methodological aspects analysed on the
basis of the adopted criteria" there is an overview of the relation of the
life cycle screening and adopted criteria for at number of product groups. The aim of this
chapter is to discuss the trends that are seen and further, whenever possible, to identify
common patterns. Such patterns can be useful in future criteria developing.
6.1 Criteria design
From the work described in former chapters it can be summarised that the concept for design of criteria depends on the following characteristics of the product.
Among others the characteristics are related to:
 | which life cycle phase the environmental key features are linked to, |
| to which extent it is the same environmental parameters that are identified, |
| how similar products made by different materials can be compared. |
These requirements seem rather obvious but when AHWG-members and the European Commission add the demands that the number of criteria should be at a minimum and that the criteria at the same time should be clear and transparent, the design of criteria sets gets quite complicated.
For the 15 product groups that currently (primo 2000) are adopted in the EU-labelling scheme the number of criteria varies significant. The number of criteria for a single product group varies in a range between 4 (washing machines)19 and 34 (textiles). Apparently the criteria are concentrated on certain phases of the life cycle in several of the adopted criteria sets. As shown in chapter 5 "Methodological aspects analysed on the basis of the adopted criteria" the reason for this tendency is closely related to the character of the product. E.g. the production of textiles covers a large number of different processes for which the difference between average solutions and application of best available technology is large. Opposite for the criteria for washing machines that are concentrated on the use phase. The environmental impact in the use phase is linked to relatively few well defined parameters (energy, water, detergents, best practice instructions). The approach for criteria design is simple compared to the textile products.
Criteria can only be clear and transparent if they contain the same kind of parameters. The key issues for the same kind of products made of different materials are hardly the same. Neither are the parameters to describe the environmental impact.
When turning from equal parameters to allocation and assessment factors transperancy is decreased. However, this is the essence of LCA methodology - the tool designed in order to be able to assess different manufacturing systems for the same functional unit.
Therefore the design of criteria has to overcome this crossroad either by redefining the scope of criteria development, narrowing the product groups or making specifications for the use of LCA-methodology. This crossroad will be further discussed in chapter 7 Discussion and future development of criteria".
As earlier mentioned the definition and the particular role for the analysis of a functional unit are defined in different ways in the studies concerned. In some studies the definition of product group and the definition of functional unit are defined very narrow, e.g. bed linen of cotton, polyesters or blends hereof or textiles of 10 different sources of fibers. From a product related point of view this can be problematic - especially when products or materials manufactured by different processes should be compared.
When the environmental key features are linked to the pre-production phase it does not influence much on how the functional unit is defined. It is more important that the specific manufacturing processes which cause the basis potential environmental impact and thereby give rise to the key features of the product are described by a well-defined unit, which suits normal rutines for environmental reporting and auditing of the particular manufacturing system.
For instance for the paper- and pulp-based materials (copying paper, toilet paper and kitchen rolls) most of the criteria are related to a weight-based unit of the product. The reason is that the main environmental key features of the products are linked to the pulp processes and paper manufacturing activities. The functional unit for the product is not a central issue for establishing well-defined criteria for this product group.
However, this discussion is closely linked to the balance between the functional unit and the fitness for use aspect. The range of quality of the substances made in the pre-production phase is for many products linked to the selected processes for the manufacturing. The demands for quality related to fitness for use aspect and the functional unit do for many products affect the environmental impact of the pre-production/production phase.
This is the point concerning paints. Due to the fact that the opacity is linked to the amount of TiO2 added to the mix and the production of TiO2 is the environmental key feature of the production chain, there is a close relationship between a well-defined functional unit, the fitness for use aspect and the environmental impact of the product.
6.2 Relations between design of criteria and the LC-screening
The relations between the LC-screening reports and the formulation of criteria are not always obvious. One reason is that the formulation and level setting of criteria very often are done by complex negotiations based on long discussions between the interested parties of the AHWG (NGO’s, national competent bodies and industrial representatives, the consultants and the Commission). In the beginning of the EU eco-labelling scheme the final design of criteria was often done several years after the first draft of the reports. Thus, the criteria were often based on additional data and technological concepts to what the first draft is based upon or the design of criteria was redesigned. The copying paper illustrates this route for adoption of criteria. However, the speed of this process has increased dramatically.
The quality and the focus of the LC-screening has a major influence on the way criteria can be designed and in the end it also influences on the precision of the criteria.
For other groups the LC-screening can not be used as a basis for priority of key features, no matter how correct and adequate this activity is actually made. The reason is that the products made for the same purpose can derive from processes that are so different that design of criteria covering all processes are considered quite difficult. This is the experience concerning thermal insulation products that are manufactured of either polymers, wood, stone or glass. Further they are more or less processed during manufacturing (by different processes). At last they have different properties during the use phase appart from the property of insulation (construction temperature, weight, volume, moisture resistance etc.). It is very difficult to make transparent criteria for this product group without dividing the materials in several comparable groups.
6.3 Life cycle phase
The specific life cycle phase that the criteria are linked to varies significant within the different product groups. This is due to the character of the products. The general picture is that criteria are placed in the phase where they origin. However, there are variations to this. For hair spray, there is established a criterion on the VOC content in the product. The impact to the environment of the VOC is in almost all life cycle phases. The criterion on the content is thus a both direct and indirect way to deal with this. For paints and varnishes the energy consumption of extraction (pre-production) of TiO2 is of major concern. Instead of only having a criterion related to the energy consumption while extracting the matter is also dealt with in setting a criterion for the TiO2 content in the product. TiO2 is not considered to be an important environment issue in itself. As can be seen, criteria are set up both for the life cycle phases where an issue is directly relevant but also sometimes in phases other than where the environmental issue is relevant. For instance waste paper is used in the paper production in order to reduce the waste aspect and at the same time contributing to lower emmissions from the production phase. This indicates that the criteria really are based upon a screening of the entire life cycle. The criteria focuses on the manufacturing of cleaner products rather than on how clean the technology in the production of the products is.
However, it should be highlighted that when no key features are within the production phase, the conclusion is not necessesarily that cleaner technology is not relevant for the specific production. It is a fact though, that within the proportions of the life cycle phases the manufacturing phase is not the only phase, that is relevant for the specific product group. The production and the choise of technology linked to the manufacturing system can, when analysed from other points of view be of particular importance. This could for example be the case concerning degreasing and varnishing of elements for washing machines and dish washers. The issues are not part of either the inventory or the final criteria, but they might very well be a key feature when considering the manufacturing system as a black box.
The holder of the license of the label will very often be the manufacturer of the product. Depending on which phase of the life cycle the criteria are linked to (pre-production, use phase etc.) the holders ability to demonstrate compliance with and administration of the criteria is varying. The holder can select the subcontractors. He/she has to rely on their performance which can be invisible on the final eco-labelled product. The emissions and energy consumption when extracting TiO2 are not possible to measure in the final delivered pigment. The liberty of action for the licence holder is reduced to the selection of a subcontractor and no further action can be taken by him except reducing the use of the pigment.
When the criteria are within the use phase the actual performance is often settled in the pre-production phase, e.g. the consumption of energy is decided upon in the design phase. This means that several products on the market never will be able to fulfil the criteria unless the manufacturer redesigns the product or replaces some of the subcontractors.
If the criteria are pointing towards the subcontractor several issues are getting uncertain for the holder of the licence. This concerns both the control of the subcontractor for the specific product and the control of the parameters in charge of the subcontractor.
Furthermore, the holder of the licence will always have challenges in handling environmental impacts in other life cycle phases than his own (pre-production and production). As illustrated by the criteria for washing machines the environmental key features to some extend can be controlled by actions taken in the design phase.
As mentioned in chapter 5 "Methodological aspects analysed on the basis of the adopted criteria" most of the criteria for textile products are related to either the pre-production or the production phase. In fact the environmental key features for many textile products are related to the use phase concerning use of energy and discharge of waste water during laundry of the products (15). However, these activities are out of the direct control of the holder of the licence. At the same time this example indicates the limits of life cycle related key features when focusing on a single product during design of criteria. The key features for the use phase of a garment product have to be covered by criteria for washing machines and detergents. This is pointing towards that the future selection of product groups should indeed cover product systems. This will be further discussed in the next chapter.
6.4 Cleaner technology and cleaner product aspects
For many product groups the specification of the criteria and the interaction between different criteria is a question when discussing how and when the criteria will promote cleaner technology. Specific criteria limiting emission of certain parameters are regarded as an environmental improvement of the performance of a manufacturing system. However, there is a level for the limit of lowering emissions of specific parameters without fundamentally changing the chosen technology.
The effluents for COD for example can to some extend be lowered both by waste water treatment, recycling and alternative technical solutions within specific processes. In some examples a further lowering beyond a certain limit causes further and other environmental impacts, e.g. emission on CO2. Waste water treatment is energy consuming. There is an environmental break20 even when discussing purification of the "last fraction" of organic matters. However, in the studies in question it seems that the selection of parameters are guided by the data available. Thus, criteria are focused on lower values of parameters which have been defined as key features earlier. The COD parameter is a good example. The COD loads from pulping exceeded 1500 kg per tonne earlier on (26). Today, 15 kg per tonne is a common level in modern mills. Despite this, the parameter is still rated as a key feature without surveying the environmental impact caused by the waste water treatment needed to get this value.
This discussion is both a matter of the environmental impact assessment and the system bounderies defined for the product concerned.
The concept of cleaner products was (at the beginning) beyond the scope of this study in which the focus should be pointed towards implementation of cleaner technology (i.e. environmental improvements in pre-production and production phases).
When analysing the complete life cycle of a product group the phases concerning cleaner technology (pre-production and production) for several products are of minor importance as cleaner technology will only contribute very little to the total environmental impact in the life cycle. Since the criteria are intended to reduce the environmental impact from a given product in its entire life cycle, the focus is not necessarily linked to the production phase.
This aspect was not very clear from the beginning of this study and when the EU-Scheme for environmental labelling of products was initiated the focus was oriented towards information of the consumer about the environmental performance of the product as a method for implementation of cleaner technology too. In the meantime there has been a mutual recognition of cleaner technology as an integrated part of the cleaner products policy. Naturally, the environmental key features of the products are not necessarily linked to the manufacturing process. To some extend this recognition has been influenced by the results of environmental screening activities of products within the eco-labelling schemes. Today it is recognised that environmental impacts do not disappear by cleaner technology alone. Environmental impacts are a consequense of the products’ entire life cycle.
6.5 Source basis for criteria
The sources used as a basis for the design of criteria mostly depend on the character of the key features that are in focus for the specific product group (e.g. which life cycle the specific key features are linked to).
Lists of different contaminants, hasardous materials etc. serves as basis for several criteria. The essence of this is, that the environmental assessment is external of the projects or in other words the projects are based on assessments experienced for other (earlier) purposes.
The levels of environmental impacts from the pre-production and production phases are mostly based on data from companies involved in the specific manufacturing chains. Earlier the data was of rather poor quality. The data quality has increased dramatically on the basis of development of environmental reporting systems and a more conscious registration of the flow of in and output in the manufacturing systems.
6.6 Basis for levelsThe study has shown that the basis for levels are closely linked to the selected environmental key features and the provided knowledge of these features.
In designing the criteria environmentalists/consultants and civil servants have faced the difficulties in fixing a value of an environmental parameter so it will cover the 30% of the products which performs most environmentally sound. There are several reasons for these difficulties:
Firstly, the different parameters selected do not necessesarily act proportionally. Processes giving rise to low emission of one parameter are perhaps high on others. The pattern of emission levels can rarely be described as a normal distribution. Thus the level on one parameter can cover 80% of the trade and the best performing standards for other parameters might either cover 5% or all of the manufactureres.
Secondly, the basis for levels is linked to the quality and age of the data provided in the inventory. The quality of data has always been a matter of discussion in the AHWGs. Thus levels of values of specific parameters have been rejected on the basis of the quality of the presented data.
Thirdly, it seems like a tendency of conservatism hits the choise of parameters despite the possibility of substitution. E.g. the level of AOX continues to be discussed when criteria for paper-based products are designed despite it is possible - and often happens - to avoid the AOX-relevant emissions (fully eliminating chlorine as the bleaching agent).
When the features and criteria concerns toxic and carcinogeniceffects of substances used or contained in the products, the basis is dominated by levels defined by internationally based organisations and institutions or investigations performed on large scale by well approved laboratories.
This is illustrated in the criteria for textiles (bed linen and T-shirts) where the levels for chemicals and toxicity are based on lists published by different organisations.
These lists prove to be very useful for this purpose because the criteria can be designed on the basis of these lists when it is relevant, i.e. when the substances concerned are part of the processes or substances. In this context several organisations for different manufacturing systems have established lists which in some examples are more detailed than the lists developed by environmental authorities (e.g. CEPE (The European Confederation of printing Ink and and Artist Colours Manufacturers Associations) recently published a negative list concerning substances in inks and dyes) (27).
In addition the European Commission has developed several lists concerning carcinogenic and hasardous substances. These lists are included in several criteria sets.
19) Some criteria sets are now 2. generation and has been changed. However, the general perception is varying. [Back]
20) This probably varies from the economic break even. [Back]