Assessment of Criteria Development within the EU Eco-labelling Scheme
7. Discussion and future development of criteria
Originally the aim of the study was to survey the methods and data used as background of
design of criteria for specific product groups in order to give input to general
guidelines for future development and design of criteria. Within this aim the study also
focused on the ability of implementing cleaner technology and cleaner products by design
of criteria. A more differentiated picture than anticipated in the first set up emerged
during the study.
This finalising chapter firstly provides an overview of the overall picture of the development within EU eco-labelling scheme. Introducting this chapter presents a few statements about methods, data and horisontal and it discusses the outcom of the project in general. Thereafter, aspects relevant for the future development are discussed specificly.
Firstly, the studies turned out to be very different both concerning the methodological approach used and the way of designing criteria. A brief view would judge this as methodological inconsistency but when going through several studies another picture occured. The conditions for the studies turned out to be very irregular due to lack of data and other essential information. In addition the characteristics of the product groups turned out to influence heavily on how the analyses were performed and criteria designed. Each study turned out to include unique aspects in several ways leaving the possible standardisation of criteria design very difficult. The characteristics of the analyses were often affected by the specific life cycle phase(s) where the environmental key feature(s) was (were) located.
Secondly, the study showed a crossroad concerning the aim of transparent criteria. The reason is that the EU-Commission tries to define wide product groups in order to be able to cover large market volumes by the same set of criteria. By expanding the product group the number and complexity of criteria increases rapidly. There are three possible solutions to this paradox. Either to accept more narrow defined product groups or accept more complex design of criteria or at least by making several sets of process related criteria for the same (wide) product group.
Thirdly, the study shows a demand for further standardisation and simplification of specific and horisontal environmental features. Whenever approved lists exist they are used as a simple effective basis for criteria, e.g. use of substances listed in a certain list is prohibited.
The projects show different approaches to horisontal aspects e.g. energy consumption andtransport both concerning methods and complexity. This area develops a crossroad, too. One way is to develop accurate, sophisticated modelling and calculation methodology in order to have very accurate measurements of horisontal elements. Another way is to have rough estimates.
Basically, the result of the study is that the crossroads mentioned have to be solved or decided before it is possible to develope a more direct and adequate methodology for eco-labelling routines. The antagonisms linked to demands of transparency along with aims of wide product groups can only be solved by narrowing the product groups or by accepting more complex sets of criteria.
The study demonstrates that development of criteria for a product group by the rigid imagination of going through the 6 working phases presented by Groupe des Sages, makes a simple and wrong picture of the adequate procedure for this kind of tasks. The steps in the procedure are all right as such, but much more focus on the iterative procedure and how to involve this in the methodology will be a great advantage.
This in fact corresponds with the approach used in LCA’s.
In this chapter, input to future development of criteria based on the experience obtained by the examination of the products that currently are ready for labelling under the EU-Scheme are discussed. The identified themes are relevant for future criteria development and for the ongoing revision of the EU Regulation. The guidelines include several links between the location of key features in the life cycle, definition of functional unit/fitness for use and the final design of criteria.
In general, there is a demand of transparency in the process of developing criteria as well as in the background documentation when a set of criteria is adopted. The demand of transparency already started when the first regulation was adopted and has been further emphasised by the guidelines of the Groupe des Sages as early as 1994. Below, different aspects of demand of transparency" are highlighted and discussed.
7.1 The demands of transparency
7.1.1 Definition of product groups
The complexity of criteria varies significantly. For several product groups the complexity of the criteria is linked to the wide definition of the product group. The intention of a wide product group definition is usually to increase the market volume of the product group that can be covered by the same single set of criteria. Often the wide variety of products fulfilling the same functions increases the complexity of the criteria.
How broad the product group is defined depends on the type of product, but it is evident that the broad product group definitions are much more prevalent in the EU-Scheme than other eco-labelling schemes. In the two last mentioned schemes many product groups are narrowly defined. For instance, the criteria of thermal insulation were in the EU-Scheme defined almost as broad as possible, starting at "thermal insulation of walls" but ending at "thermal insulation of walls and roof". The reason for the broad definition that actually became even broader was the wish of not excluding specific applications and materials. This reasoning was supported from all sides during the process since it soon appeared that there is a large cultural heritage regarding how and which thermal insulation is applied in different countries. This is true both for the actual applications that are chosen and for the materials chosen for the application.
7.1.2 Criteria based on hurdles or point-based matrix systems
For some product groups the criteria are linked together by a point-based matrix system. The idea of this method is in general that different technologies are used to produce the same function and the environmental profiles of these processes are very different from each other. In order to be able to compare different processes that might have an advantage for some environmental parameters and a disadvantage for others, each individual contribution is linked in a matrix system. Basically, the sets of criteria promote cleaner technology and if the right multiplication factors are selected, these kind of systems should be fair for the different processes involved for the same product group. Like other sets of criteria the point/matrix system also involves hurdles that should be met in any case.
Until now the point systems only have had moderate succes. It has been argued both by AHWG-members and NGO’s that there is a lack of transparency when criteria are designed and linked by point systems. It is difficult to assess if the levels that the point system dictate are high or low before the data of several productions (with well known environmental profiles) are placed in the point-based matrix system. And even then the result is a matter of much continuous discussion both in the AHWG’s and in the environmental debating in the press. Especially concerning the art of being able to assess and compare the importance of different environmental parameters.
There are in general demands especially from the industry and its organisations to keep the number of criteria on a minimum in order to reduce the cost of administration and control of criteria. However, the industry seems ambigious on this issue. During the discussions about converted paper products, the industrial organisations on one hand tried to reduce the number of criteria and on the other hand it was criticised that there were no criteria specifically concerning the converting processes and the different properties of the same kind of products.
The discussion of combining several environmental parameters is linked to the discussion of LCA methodology (normalisation) and is central in the handling and assessing of different impacts. For the two paper-based product groups toilet paper and kitchen rolls the point related criteria was made in order to cover the different kinds of pulping methods (sulphite, mechanical, magnephite and sulphate). A mechanical pulp has very low COD emissions but the energy consumption is high compared to the chemical mills. A point system designed to cover such ranges can reduce the work of designing criteria compared to the alternative of making a single set of criteria for each kind of pulp. However, the point system turned out to be regarded as non-transparent and the concept was later abandoned for copying paper. As a result the point system concept has never been considered during the following study of converted paper products.
If a matrix is based on well-known data of different manufacturing methods it could be argued that the transparency could be lost if the different processes got separate hurdles which kept each of them on the best environmental performance. And if the matrix is based on uncertain data, the criteria are based on an insufficient basis anyway.
7.1.3 The implication of the transparency demand on product group definition, fitness for use and functional unit
Demands of transparency are closely linked to the definition of the product group, the fittnes for use and the functional unit. Transparency is easy to achieve within a narrow well-defined product group, but the market volume will be limited. Thus the environmental improvements will also be limited. The same could be argued for fitness for use and functional unit. The transparency can easily get lost if it is not certain which of more functions that are valued in a study.
7.2 Identification of key features
The identification of key features is both during this study and by Groupe des Sages recommended to be identified on the basis of the Life Cycle Inventory. This is contradicting to what happened in many studies, since the identification of key features for many kinds of products is given from the beginning. In these cases this is based on different interested parties’ environmental presumptions about the product group. In the study of hairspray these presumptions were dealt with directly, while in the study of light bulbs the presumptions were incorporated as well qualified input to the process - even before the inventory was performed.
The main task during the life cycle screening is in many eco-labelling studies to find the most suitable level for the parameters concerned. As mentioned earlier this task gets more complex each time a new parameter is added. Another main task is to link these well known parameters to a functional unit of the product that can be handled easily by the holder of the licence.
In the guidelines from Groupe des Sages: some antagonisms can be identified. It appears in the description of the inventory analysis that is introduced as follows:
The inventory analysis should be comprehensive. It should not be guided by pre-concieved ideas. However this does not exclude subsequent research on key issues, based on obtained results which should be scientifically recognised and agreed upon by all interest groups (Groupe des Sages 1997).
For some product groups the environmental key features are obvious. For other product groups the inventory shows several gaps for which the environmental impact is totally blank, e.g. it is mentioned in the paint study that the total spillage of paint in the application phase (the use phase) is 30%. This is an estimate and no further reflections are presented concerning this issue. One could argue that if the waste of the paint product was that high then efforts to reduce it should be part of the criteria. Just a few percent of reduction could reduce the environmental impact of all the other life cycle phases in proportion with the same amount (the same percentage). However, this did not take place.
Environmental key features are not always suitable for a manageable set of criteria, no matter how obvious the environmental impact of the parameter is, e.g. the environmental key features for many garment products are the washing processes in the use phase. But this proces is not in control of the potential holder of the license but must be covered by eco-labelled detergents, washing machines etc.
7.3 Demands for standardisation of environmental elements
Criteria concerning chemical substances do for several product groups refer to lists of chemicals. For instance criteria for T-shirts and bed linen are linked to lists of toxic pesticides and other chemicals. This is a short cut in designing the criteria because the evaluation and assessment of the chemicals is done earlier when the substances are categorised in the lists. However, this implies that the lists are approved by authorities and the organisations taking part in the work.
In parallel, equal handling of several horisontal elements would easen the design of criteria, e.g. several approaches have been found to calculate and rate energy consumption and the related emissions and most of the approaches are not fully alike. This item will be further discussed below.
7.4 The linkages between functional unit/fitness for use and environmental key features
The functional unit is the key to compare environmental performance of the products (chapter 3). For some products it is essential to link the functional unit to fitness for use criteria.
For others this linkage however LCA-relevant will complicate the administration of the labelling activities for the company in charge.
E.g. for paints the linkage is obvious, because the performance of these products is affected by the environmental features. The more titandioxide contained in the paint the better opacity. At the same time the pigment is a central environmental key feature since a large proportion of the waste and energy consumption comes from the manufacturing of titandioxide. As a result the property of the paints is linked to the environmental impact. Therefore it is reasonable to link the fitness for use to the criteria whenever possible.
However, this is not the condition for all product groups. E.g. for the paper-based products the environmental key features mostly derive from the pre-production phase, no matter for what purpose the paper is manufactured. The pulp and paper processing are dominating the environmental parameters concerning emissions and energy consumption. In some instances there is a correlation between the quality of the paper product and the weight and therefore also to the environmental impacts. The environmental impact from one kg of toilet paper, one kg of kitchen rolls and one kg of copying paper is equal and is in all cases linked to the pre-production phase.
Therefore it is reasonable to design some criteria in relation to a weight-based unit despite the fact, that the weight does not necessarily have anything to do with the function of the product and thereby no relation to a functional unit either. For the paper products it could as well have been m2 or the ability to absorb different matters.
For paper products the weight-based unit has another advantage because the paper usually is traded in weight and parameters from the environmental reporting from pulp and paper mills are related to weight units. Thus the environmental parameters can be part of the technical specifications when ordering the raw material from the supplier. The transparency of the criteria for copying paper is therefore obvious because the levels of the criteria can be directly compared with the values in environmental reports from the pulp and paper mills.
Thus, the balance between the functional unit and the fitness for use aspect depends much on the characteristics of the product. The criteria can for many products be related to a well-defined functional unit, i.e. a weight- or amount-based unit. But in order to ensure that the property or the quality of the product is not reduced by taking environmental care, the fitness for use aspect can be an independent criterion besides the functional unit. For example concerning the paints it is obvious that if the environmental considerations reduce the lifetime or the opacity of the paint, then a weight-based comparison is not adequate for this product group. For paints and varnishes a criterion exists both related to the fitness for use (a minimum requirement for the opacity) and it is incorporated in the functional unit.
The right decision is very closely linked to the relation between the defined functional unit and the fitness for use and to the character of the individual function or product. Therefore, an advice could be to take into account matters like: In which life cycle phases are the environmental key features located? Who is the coming-to-be holder of the licence? How does the environmental loads affect the performance? Property of the product?
7.5 Links between product group definition and functional unit
In parallel to the discussion of when in the process it is possible to define key features, the selection of product groups and definition of the functional unit are given some thoughts. The full schedule of design of criteria is presented in chapter 2 "Methodological aspects - Vocabulary". In the first 3 phases (preliminary choice of product group, market survey and inventory) of the establishing of criteria the view of the product group can change several times.
From first sight it seems like a logical way of decisionmaking but when going into details these 3 phases do interact. One of the reasons for this antagonism is based on the intention of defining a functional unit that covers several product groups fulfilling the same functions. The covering of as many products as possible could be seen as both an optimisation of obtaining the maximum volume of a single set of criteria and as an attempt to overcome different national variations. When enlarging the product group definition it reflects the function (indirectly) as well. For thermal insulation the inclusion of a great variety of products also includes more functions like construction and noise insulation.
Another example of the iterative nature is the definition of product group in the preliminary phase. If it later appears in the market survey that the product group is too narrow (meaning it only includes a minor proportion of the market) this could lead to redefinition of both product group and functional unit.
In all the LCA standards that were not yet adopted when the EEC regulation was adopted, it is heavily emphasised that LCAs are an iterative process.This means that one has to go back and forth in the LCA process until expectations and possible achievements are adjusted to each other. In principle nothing hinder the same approach to be applied in the eco-labelling except that this process is done in a political, multinational arena. In the political multinational context it can be very difficult to change decisions - even upon new knowledge - if a certain degree of harmonisation (finally) has been obtained.
7.6 Standardisation of horisontal elements
The horisontal elements (energy consumption, emissions from transport, electricity etc.) are very heterogenious in the studies so far. The electric power generation is different within the borders and that affects the emissions from electricity. The current development in the common European energy market as well as the latest development in LCA seems to make the decision more simple in the future. The cohesion of the European grid seems increased over borders and by then electricity produced in one part of the community will often be utilised after crossing several borders. The traditional concept that the emissions should be linked to the manufacturer is definitely unlogical concerning the manufacturing of power. Like the standardisation of assessments of chemicals a simple formular for electricity would make design of criteria much easier.
The quality of electricity is the same no matter what type of fuel or technology is used to produce it. Therefore electricity based on cleaner methods, windturbines or hydro power is able to substitute coal- or oil-based energy in other parts of a region. On this basis the power should be treated equally since the hydropower could substitute coal-based power. This area has changed dramatically within th last couple of years (1997-1999) and has to be considered carefully in the near future due to discussion of market-based marginals.
The LCA development seems to support this. The right dogma seems at the moment to be that if the purpose of the LCA is decision-making like for the eco-labelling the data should be market-based.
7.7 The role of the consensus orientated decisions
The process of developing criteria affects the final results for several product groups. When strong interests are represented in the AHWG the focus of the analysis is not only directed by the advice of the consultant but very much by the statements and oppositions from the members. Apart from competent bodies from different EU-countries the AHWG usually consists of industrial organisations, NGO’s (mainly environmentalists) and others who each of them all put their effort on different points.
The national bodies have an interest in getting the criteria oriented in order to suit their industries, environmental regulation and recipients.
The industrial organisations have an interest in getting the criteria oriented in order to suit their members. Since industrial organisations are very often trade-based the motivation to get the criteria designed and levelled so they do not affect the average activity of their members is obvious. If these AHWG members forced the levels so only a fraction of their members could be labelled, they would conflict their own justice. Further more reduction of environmental impact based on new investments and costs is always treated as negative in the economic terms.
The environmental NGO’s force the design of criteria in another direction by putting efforts in getting the levels oriented so the environmental impact is reduced as much as possible. Since environmental improvements are their single goal their points can often be impossible to reach but their voice can have the result that the specific item is left as a possibility for criteria.
7.7.1 Changes due to the consensus oriented decision-making process
When the facts from the studies of a product group are grinded in the discussion processes by the AHWG, the final result of criteria can be far from the first draft of criteria. There is much reasoning for this. I.e. the basic definition of the product group can be changed during the processes causing split ups of the product into subgroups or extensions of product groups.
Due to the many iterative processes the reports of each product group can not be studied in isolation. The final criteria are based on many arguments - some of these can be obtained from the life cycle screening in a draft report, while others are put forward by the members of AHWG during the AHWG meetings.
7.8 The range of eco-labelling as an environmental regulation tool
The present survey examines the methodology used in the background studies of the product groups criteria adopted within the EU eco-labelling scheme and gives an overview of the limitations and possibilities for the use of eco-labelling as a voluntary tool of environmental regulation. The experiences from this examination points out several issues.
When the entire life cycle of the products are screened the environmental key features often can be located in activities that relate to suppliers rather than coming-to-be eco-labelling holder.. This is the fact for paints and varnishes where the environmental key features and the following criteria are related to emissions during production of the pigments. The action taken from the paint and varnish manufacturer concerns selection of subcontractors that are able to fulfil the criteria. For converted paper products the same conditions appear since the environmental impacts from the converting processes are of minor importance compared to the pulp and paper process.
The demands on keeping the number of criteria on a minimum in combination with sufficient transparency of them causes difficulties if the criteria should both cover the environmental key features from a product related point of view as well as a trade related approach. If transparency and a limited number of criteria should be emphasised it is obvious that some environmental features must be ignored. It is also obvious that less parameters eventually can lead to less equality if different methods to obtain an equal function has to be assessed with few parameters.
All this indicates that environmental labelling is a supplement for other kinds of regulation and not a substitute.
7.9 Products’ suitability for eco-labelling
When the scheme was established several requirements were listed as preferable for products which should be labelled.
When selecting the product groups considerations should be made. Below a few of these considerations are mentioned:
 | relevance for the environment, and for the use of natural resources, |
| interest of consumers and the general public, |
| interest of industry and other interest groups, |
| international aspects. |
With the analysis in this study in mind one could question these requirements for selecting product groups. The tendency of the experience shows that other demands might suit (and be included in) the process as well. An important issue is the possibility of defining the product group and how closely it is linked to the functional unit. If this alternative way of selecting new product groups can not be accepted then there definitely is a need to accept more complicated screenings and more complex design of criteria.
The selection of product groups for coming labelling activities should take these discussions into acount.
One approach could be to establish labelling systems for groups of products like it happened (although without the intention) with textiles, detergents and washing machines. This is pointing towards that the future selection of product groups rather should cover product systems.
7.10 Final views of future development of criteria
This study shows that it is not possible to make a simple standardisation of the study as a basis for eco-labelling of products. On the basis of the criteria examined in this study the experience could be listed in the following items:
| Product groups have to be selected carefully in order to avoid complicated limitations late in the work. Selection of product systems might be a relevant solution. |
| The balance between functional unit, fitness for use and design of criteria should not be handled as rigid as earlier proposed since this will not necessarily promote either design of criteria or the later administration by the holder of the licence. In other words the iterative approach has to be kept. |
| Agreement of some parts of the impact assessment, e.g. normalisation of global and regional impact would ensure that some issues would be treated equally in all criteria-development-studies. This could both lead to less time consumption in the development of criteria as well as more transparency. |