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Ecolabelling of printed matter - part I

2 Focus and methodology for Eco-label Criteria

• 2.1 Goal
• 2.2 Scope
• 2.3 Input and activities
• 2.4 Overview of weighting in the criteria document compared to LCA results
• 2.5 Weighting for each of the process stages
  • 2.5.1 Paper
  • 2.5.2 Printing
  • 2.5.3 Cleaning
  • 2.5.4 Ink production
  • 2.5.5 Energy consumption
  • 2.5.6 Page production
  • 2.5.7 Plate making
  • 2.5.8 Finishing
• 2.6 Discussion related to the criteria document
  • 2.6.1 Paper
  • 2.6.2 Printing
  • 2.6.3 Cleaning
  • 2.6.4 Ink production
  • 2.6.5 Energy consumption
  • 2.6.6 Page production
  • 2.6.7 Plate making
  • 2.6.8 Finishing
  • 2.6.9 Transport
  • 2.6.10 Waste water treatment
  • 2.6.11 Substitution of biocide
  • 2.6.12 Weighting on resource pull
  • 2.6.13 Qualitative requirements
  • 2.6.14 Chemicals
• 2.7 Methodological Discussion
  • 2.7.1 Functional unit
  • 2.7.2 Waste treatment issues
  • 2.7.3 Structure of the criteria document
  • 2.7.4 Structure across the eco-labelling scheme
  • 2.7.5 Relation to other environmental policies and actions
• 2.8 Conclusions on issues in future criteria documents

This Section covers a comparison between LCA results and the Swan Criteria Document on Printed Matter, version 3.1 (see http://www.svanen.nu/DocEng/041e.pdf). The Section is structured in the following Chapters:

• In Chapter 2.1 – 2.3 goal, scope, input and activities for the Section are described.
• In Chapter 2.4 an overview of the present Swan Criteria Document is given, with focus on the weights estimated from the criteria.
• In Chapter 2.5 this weighting is then compared to the weighting indicated from LCA studies.
• This comparison is then discussed in Chapter 2.6, and with further aspects in Chapter 2.7.

2.1 Goal

The goal is to carry out an assessment of the methodology used for criteria development under the Nordic Swan, and suggestions for methodology to be used for the criteria development under the European Flower are elaborated. The study takes its starting point in the Swan criteria, which is now in its third revised version. The history goes back to1996, where the first criteria document was drafted, thus providing much experience on the practical application of the criteria in the Nordic countries.

Regardless of this starting point, the present study is intended also as a background document targeted towards the development of the first version of criteria on printed matter under the EU eco-labelling scheme, the Flower.

2.2 Scope

The Swan Criteria Document for printed matter contains numerous criteria, defined in several ways. The core of the document is the point system, but this is supplemented with a long list of absolute (quantitative) requirements and qualitative requirements. In the present study, the point system and the list of absolute requirements are assessed in a comparable way. Qualitative requirements, such as documentation or testing requirements, are omitted from the study because the nature of such requirements makes them very difficult to measure and compare to other criteria.

The scope follows the scope of the Part II LCA study when it comes to coverage of the life cycle phases, processes and materials. This scope is at several points much wider than the coverage of the criteria document, which is an important part of the result of the entire project. The data for the scenarios of the Part II LCA study comes mainly from surveys of the Nordic printing industries (see for example Table 12 of the Part II report).

The focus in this section is on the weight of environmental issues and on the principles and the structure of the criteria document.

See the Part II LCA study for the precise definition of the scope.

The RPS approach used in both the Nordic and the European eco-labelling schemes, considering Relevance, Potential for change, and Steerability, has not been considered in this study. The focus has been on the environmental impact from various parts of the life cycle of 1 ton of generic printed matter, whereas the RPS approach covers market considerations. The RPS considerations are important when product groups are selected and criteria are developed or revised, because if either the market or the technology for improvement is not ready for the requirements in the criteria document, then the product group will not be a success – and then no environmental improvements will be possible. Thus, while a clear scientifically based criteria document may give the optimal result in theory, in reality it may not work.

2.3 Input and activities

The starting point for this study is the current version 3.1 of the criteria document for printed matter (printed paper products) under the Swan Scheme [Nordic Ecolabelling: Ecolabelling of Printed Matter, criteria document, version 3.1]. The results from the Part II study (new generic LCA) and relevant existing LCAs included in Part II and a summary of the experience from the history of criteria development towards the current version then forms the basis of the assessment. The relevant LCA references are referred from the Part II.

Based on the results of LCA studies and experience from the previous development of criteria under the Swan, suggestions for changes in focus, structure and methodology for the criteria have been elaborated and described. The suggestions are intended both for revisions of the Swan Criteria and for input to the criteria development under the EU Flower.

2.4 Overview of weighting in the criteria document compared to LCA results

The current criteria document is an example of criteria based on a point system. The point system makes it possible for the license holder to weight processes internally, thus, a badly performing process will be acceptable if one or more very well performing processes are available in other parts of the process line. Not all criteria are included in the point system, thus, the point system is supplemented with absolute requirements and obligations to monitor and report certain parameters.

Covering the point system only, Table 4.3 of the criteria document gives an overview of the weighting between process stages for each type of printing method. The weighting given in Table 4.3 of the criteria document has been extracted into Table 2.1 with point weights transposed into percentages.

Table 2.1 – Weighting in the Swan Criteria Document, point system criteria only (disregarding absolute criteria).

Taking sheet feed separately, which is the scope for this project, the total maximum score is 12 points, with a target value for printing of 7 giving the weight of 58% to this process. For a further analysis of the weighting, the sub-division of weighting in Table 4.3 of the criteria document is presented in Table 2.2. Sub-weighting is calculated by classifying point-giving criteria into issues, and summing up to maximum within each issue, and then normalising to the percentage of the parent heading.

Table 2.2 also contains the weight results from the Part II study, looking at environmental impacts and using the scenario without paper and energy consumption at the printing company. The weights in the point system are thereby comparable directly to the results of the Part II study.

Table 2.2 – Detailed weighting in the Swan Criteria Document, point system criteria only (disregarding absolute criteria), and compared to weighted results from the Part II study.

* Reference scenario excluding paper and energy consumption at printing company (based on weighted potential environmental impact).

** Not included in the Part II study.

Table 2.2 presents the weighting of criteria that are point giving. However, some criteria are absolute requirements, and these cannot be assessed percentage wise in relation to the point giving criteria, because an absolute requirement may be allocated a weight anywhere between almost zero to almost 100%. Therefore, no effort has been made to quantify absolute and point giving requirements in a combined assessment. In Table 2.3 the list of absolute requirements has been added to the point system list, providing an overview of all quantitative criteria as defined in the eco-labelling terminology. The reference scenario from the Part II LCA study, including paper and energy consumption at the printing company, has been chosen for comparison in this table because the absolute requirements on these issues from the criteria document have been included too.

This overview does not, however, cover the more qualitative requirements such as environmental assurance, quality, testing, marketing and documentation requirements. The purpose of such requirements is to put focus on issues such as energy consumption by implementing the registration of energy consumption, or organisation around the production by implementing organisational structure for reporting changes in the production to the eco-labelling body. Such criteria are not covered by the scope of this study.

Table 2.3 – Absolute requirements added to the point system list

@ In this column, “fulfilled” means that in the reference scenario of the Part II study this requirement is fulfilled a percentage indicates the weight on potential environmental impact derived from the study results and “not relevant” means that this is not included quantitatively in the study.

* Lamination not included.

** Printing ink contains more than 2% w/w of low volatile paraffin (mineral oil) with components (tetradecane) that according to the assessment done in the Part II study should be classified as hazardous for the environment.

# Emission of ink residues at the printing industry included: 16.5% (ink production) + 17.7% (ink emission)

As mentioned above, it is not feasible to transform absolute requirements into quantitative values, which could be added to the point system values. Taking, for example, the printing incl. cleaning value of 58%, which by coincidence is equal to the weight given by the Part II study, then there are seven absolute requirements supplementing this value, which gives the impression that printing incl. cleaning is actually overestimated in the Criteria Document’s weighting. However, the seven absolute requirements have a different focus to that which is pointed out by the results of the Part II study.

The seven absolute requirements under printing incl. cleaning:

• Max limits on washing (amount, aromatic content)
• Alcohol, max. 6 kg/tonnes
• Collection for destruction or recycling
• Wash or energy recovery of cloths
• Treatment of waste washing water
• Surfactants readily degradable
• Treatment of waste damping solution

The focus given by the Part II study:

• Substances used in cleaning agents and inks

Furthermore, a number of the absolute requirements given later in the table under production requirements refer to parts of the printing and cleaning processes, but still they do not focus on substances used in cleaning agents and inks to an extent that meets the weighting of the results of the Part II study.

Thus, the existing LCAs included in Part II and the results of the Part II study indicate the importance of including new LCA stages/issues (e.g. energy consumption at printing company and transport) and a different weighting (e.g. on printing ink) if the criteria are to be based on a product LCA approach.

2.5 Weighting for each of the process stages

The results of the LCA study in Part II of this project are outlined as a weighted distribution of impacts from sub-processes (activities) in the Part II LCA study. Roughly the following seven sub-processes dominate the potential environmental impacts:

Paper production (31%)
Printing (41%, thereof 17% points from ink production)
Cleaning (17%)
Energy at print (6%)
Plate making (2%)
Page production (2%)
Finishing (<1%)

In the following, each of the process stages is covered. Requirements for the production processes are given in Section 4.3 of the criteria document.

2.5.1 Paper

Requirements for paper are given in Section 4.2 of the criteria document.

Paper can be regarded as part of the printing process (raw material for printing) but here is considered separately.

All studies referred to in Part II of this project (except the Part II study it self) find paper to dominant in the potential environmental impact (typically 70 – 80% in importance). Even though paper is not overall dominating in the Part II study, it plays a very important role, accounting for about 31% of the aggregated weighted potential environmental impact. The main reason for this difference in importance of paper between the existing LCAs and the Part II study is probably that chemical related impact categories are included in the Part II study (making it more comprehensive) which is not the case or only so to a limited degree in the existing LCAs. This difference in comprehensiveness does also have impact on the importance of the other activities, especially printing as described below. In the current criteria, paper is omitted from the point system, but with an absolute requirement of using Swan or Flower labelled paper or paper fulfilling one of these criteria documents. The weight of 31% from the Part II study is based on paper that fulfils these criteria.

If paper is not recycled (most important) and the heat from incineration not exploited, the importance of paper increases to above 48%. If, additionally, the paper is used for land filling (dumped), then the importance will increase significantly due to possible emissions of methane to air (contributing to global warming) from the anaerobic degradation of the cellulose in the paper.

2.5.2 Printing

All the existing LCA studies included in Part II point to the printing step as the second most important. However the Part II study points to printing (58%) as the most important step and only if both cleaning (17%) and ink production (17%) are excluded from the printing step does paper (31%) become most important. Other issues of importance at the printing step according to the Part II study include the possible emission of ink residues to water, emission of used fountain solutions containing biocides to water and emission of alcohol (IPA) to air.

These focus point’s call for demands on consumption (e.g. ink spillage reduction), substitution (e.g. pigments and biocides) and waste handling (e.g. for used fountain solutions).

2.5.3 Cleaning

The existing LCA studies included in Part II are not very specific on the importance of the cleaning step, however VOC emission from cleaning is pointed out as relatively important. The Part II study points to cleaning as one of the important steps, accounting for 17% of the total aggregated potential environmental impact. Emission of solvents from cleaning agents based on mineral oil is dominant.

This focus point calls for demands especially on substitution but also consumption and waste handling.

2.5.4 Ink production

Generally only energy consumption from ink production is included in the existing LCAs included in Part II. On this basis the importance is relatively low (typically around a few percent). However the Part II study comes up with a 17% importance of ink production mainly due to emission of synthesis chemicals during the production of pigments.

This focus point calls for demands especially on ink consumption (ink spillage) and substitution.

2.5.5 Energy consumption

Energy consumption at the printing company is typically not shown separately in the existing LCAs included in Part II. However it is shown in one case for sheet fed offset but only covering the printing process and accounting for below 1% in each of the energy related impact categories included. In the Part II study the total energy consumption at the printing company gives rise to an importance of 6% of the total aggregated weighted potential impact, also including chemical related impact categories.

This focus point calls for demands on energy consumption combined with demands on energy source.

2.5.6 Page production

The existing LCAs included in Part II either do not include page production (repro) or do not show its importance separately (only stating that the importance is small). However for the sheet fed offset case a category designated “film and film chemicals” accounts for 1% - 6%, depending on which of the energy related impact categories is looked at. In the Part II study repro accounts for about 2% of the total aggregated weighted potential impact also including chemical related impact categories.

This focus point calls for demands on, for example, substitution (e.g. hydroquinone) and cleaner technology.

2.5.7 Plate making

For plate making the existing LCA studies included in Part II, for which this process is shown separately, estimate an importance for plate making of about 5% (1% - 13% depending on energy related impact category). The Part II study assigns plate making an importance of about 2%, assuming that the aluminium plates are fully recycled (only 8% loss) and allocate the avoided energy consumption from production of virgin aluminium to the plate making process. If production of 100% virgin aluminium is used instead, the importance of aluminium in the Part II study becomes about 4%, which is more at the level of the existing studies. However the main contributor to plate making in the Part II study is emission of biocides via used recycled rinse water, accounting for about 1.7%.

These focus points call for demands on, for example, substitution (biocides), waste handling including consumption and recycling of aluminium plates.

2.5.8 Finishing

Finishing is not included or shown explicitly in the existing LCA studies being part of the LCA study, Part II,  – at least not in a quantitative way that would make it possible to estimate a relative importance. However one of the studies indicates that it may have significant importance in some cases (e.g. energy consumption at bookbinding). Bookbinding and lamination is not included in the Part II study and the importance of finishing is estimated to about 0.4%.

2.6 Discussion related to the criteria document

The earlier LCA studies and the Part II study indicate that, disregarding paper, some issues, left out of or given low priority in the criteria document, might be included or have a greater weight. In this section, each of the process stages covered in Section 2.5 and a few more themes are discussed in relation to the Swan Criteria Document.

2.6.1 Paper

2.6.1.1 Paper waste in production

Existing LCA studies included in Part II indicate that, excluding paper production, the paper waste in the production becomes third most dominant factor on global warming.

The Part II study shows that assuming a reduction in the paper waste from 32.1% to 3.3% reduces the total weighted aggregated environmental impact by 11%, as shown by this study with Nordic printing houses, (see for example Table 12 of the Part II report).

In Section 4.3.10 of the criteria document, paper waste has a general requirement of maximum 20%. This covers only cutting waste. Besides this, waste paper will be generated from start-up/calibration of printing machines, but this is not included in the current criteria.

Demands on paper cutting waste (20%) should be changed. Demands on waste paper in general (including waste sheets etc.) should be included.

As this parameter goes hand in hand with economy, printing companies have interest in this already.

Methods for optimisation of paper use are a matter of both planning and technology. Also, classification of processes and equipment types would make it more feasible to specify realistic paper waste fractions in total (cutting waste and upstart/calibration paper waste).

2.6.1.2 Disposal for recycling or incineration

The Part II study shows that recycling and exploitation of heat from incineration of paper waste is very important for the LCA profile.

There is a general clause in Section 4.4.2 about sorting waste and sending all fractions for best treatment, such as recycling.

The general requirement in Section 4.4.2 of the criteria document may not be feasible for improvement, because waste treatment depends mainly on local and regional policies and capabilities for optimal treatment.

If paper is land filled, it will develop methane, which contributes to global warming (if not captured and used for energy production), thus, markedly increasing the impact from paper.

2.6.1.3 Use of recycled paper

The reference study (i.e. the reference scenario in the Part II study) is based on the current situation today, i.e.  an unsaturated paper market situation. Combining this with the marginal approach, also used in the reference scenario, leads to the immediate result that there is no difference in the impact from printed matter produced on virgin paper basis as compared to printed matter produced on basis of recycled paper.  However, a special scenario (also done in the Part II study) shows that if a saturated paper market is assumed, then changing consumption from fully virgin paper based to fully recycled paper based results in a reduction of 16% in the total weighted environmental impact. So, even though the paper market is unsaturated today, the use of recycled paper is very important from an overall societal point of view (keeping the recycling system at work).

Points may be given for the use of recycled paper.

2.6.2 Printing

Printing has 58% weight in the criteria document, which is mainly allocated to inks, washing agents and alcohol. Furthermore, much energy and many chemicals are used in the printing process.

In Section 4.4.1.3 of the criteria document, only 2% hazardous substances, no heavy metal based inks, Pb, Cd, Hg and Cr (VI) below 100 ppm, no phthalates, nonylphenoles, ethylene glycol ethers and halogenated hydrocarbons are allowed. There are in general no criteria relating to upstream production of chemicals.

The Part II study also gives 58% weight to printing, but for other reasons, especially because of the inclusion of upstream data for ink production, as further detailed below.

Printing issues are dealt with in further detail below under cleaning and ink production, and under energy issues.

2.6.3 Cleaning

In the Part II study, cleaning accounts for 17% of the total aggregated potential environmental impact. This high weight is due to emission of solvents from cleaning agents based on mineral oil. Criteria for cleaning/washing agents are given in the criteria document in Section 4.3.3. Even though detailed criteria are given to the vapour pressure of washing agents and to the content of aromatic compounds, this is not enough to minimise the potential environmental impacts from cleaning. This is due to inconsistency in the criteria document as further discussed later in Section 2.6.14:

The requirements on classified substances are related to Section 4.4.1.3 regarding chemicals ending up in the product (inks, varnishes, toners etc.), not washing agents. Point-giving criteria on washing agents focus on vapour pressure and aromatic content as mentioned above, but not on substances, which should be classified as environmentally hazardous.

2.6.4 Ink production

Inclusion of emissions from use and production of other chemicals, especially inks, in the Part II study increases the importance of this phase. In the existing studies ink has an overall weight of about 10% (including paper).

• The Part II study indicates that the production of pigments/inks implies relatively high potential impacts within the impact category for eco-toxicity (totally 17% with paper included) especially. Assuming a reduction in the printing ink consumption (e.g. by reducing the ink spillage) of 26.5 kg/ton product to 1.8 kg/ton products reduces the total potential environmental impact by 56% (see for example Table 12 of the Part II report). (see for example Table 12 of the Part II report).

In Section 4.3.3 of the criteria document, UV inks are given 2p, while other inks are given 1p or 0p.

Inks in general may be given more weight. Or common inks may be assessed content wise and criteria may be defined in further detail about better and worse ink components.

The Part II study indicates that the emissions from production of inks/pigments have high potential impact. Criteria will focus on spillage reduction of the printing company and requirements to suppliers of inks.

This will call for a lot of assessment on chemical products, and for building up databases on inks in a co-operation between the Eco-labelling Bodies and others such as the suppliers.

A further study will be needed to identify if criteria should focus on the choice of ink types or ingredients or on cleaner technologies and emission control.

2.6.5 Energy consumption

Energy consumption in the production (page production, form production, printing and finishing) is included in most studies. The weighted LCA profile on potential environmental impact for the Part II study indicates a 6% share for this energy consumption. Furthermore, the study indicates dominating resource pulls for coal, oil and gas as a result of the processes’ energy usage.

In Section 4.3 of the criteria document, there are in general no criteria on energy consumption in the production phases. (Except for standby level for digital printing devices (4.3.8 in the criteria doc.), which are outside the scope of this study.)

Points may be given for energy consumption in the printing machinery and the various sub-processes and auxiliary consumption, such as lighting, ventilation and room heating. Another focus point could be moistening.

Low points may be given for low consumption and for the documented use of “green energy”, such as wind or water energy.

Further studies on possibilities for optimisation of energy consumption in the relevant processes will be needed.

2.6.6 Page production

The Part II study indicates a weight of 2% of the total aggregated weighted potential impact, which is mainly related to the use of some hazardous chemicals, which could be covered in future requirements on chemicals as discussed in Chapter 2.6.14.

2.6.7 Plate making

Existing LCA studies included in Part II indicate that, excluding paper, this sub-process becomes dominant on global warming. This is mainly due to the high-energy consumption in the production of aluminium. The Part II study shows only a 2% share of the total weighted potential impact for this sub-process.

In Section 4.3.2.1 of the criteria document, little weight has been given to the requirements on aluminium plates used in the sub-process.

More weight may be given to aluminium plates in this process stage.

No new parameters (apart from energy consumption) are to be developed here, only adjustment on weights. As the market value of secondary aluminium from plates is high, the recycling of aluminium plates is already at a high level.

2.6.8 Finishing

Finishing has a very low weight in the Part II study and is not further discussed here.

2.6.9 Transport

Existing LCA studies included in Part II indicate that, excluding paper, this sub-process becomes second most dominant on global warming, or around 10% on the overall impact. Transport is not included explicitly in the Part II study and only in the material phase. The results show, for example, that transport during paper production amounts to about 2% of the total LCA global warming potential. It is assessed that the importance of transport is about 5% when chemical related impact categories are included as in the Part II study.

No criteria have been set up for transport processes.

Points may be given for transport (paper to printing company, semi-products in the production chain, waste to treatment facilities, product to customer).

No criteria have been set up for transport processes in the current criteria document. This is a totally new area, which calls for assessment of the market situation and steerability. Registrations of geography of supplier, waste treatment facilities and customers will be necessary.

2.6.10 Waste water treatment

The Part II study indicates that including wastewater treatment (e.g. municipal WWTP) may reduce the total weighted environmental impact by 26%. The degree of implementation of WWTP in EU-25 is depending on each country’s plan for WWT and the method of WWT within Europe.

2.6.11 Substitution of biocide

The Part II study indicates that substituting a biocide like benzalkonium chloride with an isothiazoline based (i.e. Kathon) type may reduce the total weighted environmental impact by 21% (WWTP included) or 69% (WWTP excluded). As within EU-25 WWTP is not very well established, substituting benzalkonium chloride with an isothiazoline based biocide should be assessed properly in relation to workers environment.

2.6.12 Weighting on resource pull

Results from the Part II study point to kaolin as the main resource pull from printed matter. Kaolin is used in paper production and may be substituted by chalk, giving a lower profile. Omitting kaolin, the important resource pulls are related to energy consumption (oil, natural gas and some heavy metals (Ni, Cu, Cr), and uranium from other energy scenarios under cleaning and finishing), silver for repro and to the use of aluminium for plates.

These results stress the importance of focussing on energy consumption as mentioned above.

2.6.13 Qualitative requirements

As mentioned earlier, a number of qualitative requirements are excluded from this assessment. Requirements for documentation and declarations from authorities are important for the overall focus, environment and good housekeeping is given by such criteria, but it has not been possible to cover them in the present study.

2.6.14 Chemicals

Compared to the results of earlier studies with less focus on chemicals, the printing and cleaning processes are much more dominant in the Part II study results, which is mainly due to high potential impacts on eco-toxicity coming from production, use and discharge of inks and emissions of cleaning agents and biocides during use.

The criteria document contains a number of absolute requirements for substances, mostly given in the general section for production, under chemicals (Section 4.4.1). These criteria specify properties covering:

• phthalates
• nonylphenols and derivates
• ethylene glycol ethers
• halogenated hydrocarbons
• aromatic content
• biocides
• surfactants
• classification as hazardous substance
• content of heavy metals, aluminium and copper

The reference scenario in the Part II study is based on the use of raw materials meeting the existing criteria in the Swan Criteria Document, and many of them even far better than the requirements in the criteria. An example is the aromatic content in washing agents, which is required as lower than 50% for maximum 2% of the yearly consumption and less than 1% for the remaining 98% of the yearly consumption. In the reference scenario, the aromatic content is equal to or lower than 0.1%. On the other hand, whereas biocides in the damping solution are not bioaccumulable, as required, then typically bioaccumulable components in inks and washing agents are used in the reference scenario. This property contributes to and is part of the explanation for the high potential impacts from printing and cleaning.

Most dominant, however, is the toxic effect part of eco-toxicity contribution from the emission of high volatile paraffins (i.e. hexane) and low volatile paraffin’s (i.e. tetradecane) used for washing, and emissions of cuprous chloride and dichlorobenzidine from the production of pigments for inks.

Hexane and tetradecane are not covered by the criteria document maybe because they are part of mixtures and here chosen to represent a mixture of high volatile solvent and a mixture of low volatile solvent respectively. The requirements for classified substances are related to Section 4.4.1.3 regarding chemicals ending up in the product (inks, varnishes, toners etc.), not washing agents. Point-giving criteria on washing agents focus on vapour pressure and aromatic content, but not on substances, which should be classified as environmental hazardous. This is an example of the criteria document not being consistent when it comes to chemicals accepted in the life cycle of the product.

Emissions from production of chemicals are in general not considered for the criteria document. This is a general situation in eco-labelling. The knowledge and data availability on this issue is limited, and a consensus on methodology is lacking. However, the result of the estimation method included in the Part II study shows that the importance of upstream emissions may be very significant for the outcome of a product life cycle assessment. Studies conducted on the basis of the EDIP methodology are part of the leading research in this field and data are becoming more available during these years, which is why it has been possible in the Part II study to include a reasonable coverage of this, taking the present data availability into account. Thereby, emissions of cuprous chloride and dichlorobenzidine are examples of emissions that appear in the LCA of printed matter when the production phases of chemicals are included, and the Part II study reveals the importance of this issue for the life cycle of printed matter. A new study including measured (not estimated) emissions from upstream chemical production would most probably strengthen the reliability of the LCA profile for printed matter substantially.

2.7 Methodological Discussion

This section covers discussions of more principal and methodological nature, which are not directly targeted at the process stages or the criteria documents.

2.7.1 Functional unit

If a life cycle approach should be a unifying principle in the criteria document, then all amounts should in principle relate to production volume (i.e. using the same functional unit). For example, limits of a substance discharged to sewers of X kg/year for a production site should be changed to Y kg substance discharged/kg produced printed matter. Thus, all requirements are unified into covering the same kind of product, and so are comparable. However, there is an important discussion around this issue: If all requirements are set by weight of product, then reducing paper thickness will have the opposite effect, namely that, for example, the use of chemicals per weight unit will increase, drawing a negative picture of change, even though the total environmental impact is reduced due to reduction in paper consumption. This illustrates the problem of choosing a good functional unit for printed communication. However, in this case, the positive effect will most probably be reflected in an LCA profile.

A way to overcome this problem is to base all requirements on area of paper printed. Thus thinner qualities will be positively rated, and so will printing on both sides. However, this approach has some other disadvantages, for example, some calculations have to be carried out from specifications of the individual machine, the cylinder format and the number of printing units, as well as the number of runs/cylinder revolutions (Bagh et al. 2002). But these problems may be solved by setting up standard categories of paper and providing standard calculation routines for estimating the area.

Another suggestion is to base some parameters directly on amount of ink used, which would create an incentive to minimise this amount.

2.7.2 Waste treatment issues

In general, waste treatment processes are left out of generic LCA studies because relevant LCA data do not exist. For a European criteria document, however, it may be considered to carry out a study on the overall potential impact from emitting waste (e.g. used rinsing water with biocide content emitted to waste water treatment plant) as compared to treating waste as chemical waste, i.e. disposal under controlled conditions at chemical waste treatment facilities. Such an investigation would probably elucidate the pros and cons of different waste disposal strategies.

Criteria on discharge of damping water and rinsing water should be based on legal provisions of the region. If a well functioning wastewater treatment plant is available, the local authorities may very well permit discharge through the common sewer. Whereas in other cases, the correct procedure would be to collect the same fractions and classify it as chemical waste for treatment at a specialised plant. This discussion is complex and dealing with it will require a huge data collection on treatment culture in all relevant regions.

2.7.3 Structure of the criteria document

Traditionally in eco-labelling, criteria documents are structured like the present Swan document for printed matter. First criteria are set for the various specific processes covered by the definition of the product group. Then this is supplemented with criteria for various cross-disciplinary issues like auxiliary chemicals, testing, management and marketing. When chemicals are in focus as indicated by the Part II study, this approach is not optimal, because it may be difficult to keep track of all requirements set on chemicals across the document.

Therefore, another approach, suggested here, is to establish a basic section of requirements for chemicals, and then build, on top of this base, further requirements for specific processes, see Figure 2.1. The advantage of this approach would be that requirements set on one chemical are global for the criteria document. Thus, the risk of setting requirements for a substance in one section and on the other hand allowing the same substance in another section will be minimised. When adding process specific requirements to this base, it will be quite clear if the requirements for a substance or a group of such will increase or decrease (adding an exception for a process).

Figure 2.1 – Outline of an approach where requirements for chemicals are given commonly as a base, which is then built upon for each process.

The approach outlined in Figure 2.1 may also be adopted for other issues, for example, requirements for waste handling or transportation.

2.7.4 Structure across the eco-labelling scheme

Even in stepping up a level from the specific criteria document on printed matter to the entire eco-labelling scheme (e.g. the Flower) the approach outlined in Figure 2.1 may still be relevant. Some stakeholders around the eco-labelling schemes for different regions have often put forward the problem derived from the fact that criteria for specific chemicals in different criteria documents vary a lot. Thus, lead, for example, may be banned in one document and accepted at a certain level in another document. This is of course due to differences in processes and use patterns for lead in the two cases. However, the result for the eco-labelling scheme as such is a much more difficult job in promoting the scheme and explaining to consumers the advantages of the labelled products compared to conventional products: There is no clear message to the consumer, such as “there will be no lead in eco-labelled products”.

A way to more systematically deal with cross-disciplinary criteria on chemicals, transport, energy etc. is to adopt the approach in Figure 2.1 at the scheme level. To support this, a modular development of criteria documents should be considered. Such a system may be database-based to ensure that no earlier experience with a specific substance will be forgotten when developing or revising a criteria document. In such a system, when introducing a substance for criteria setting, a list of all earlier criteria in all criteria documents related to this substance would be available, and thereby, a level suggested. Then the criterion on the substance for the specific application may be suggested with full knowledge of the history of the scheme. In this regard, it can be mentioned that this concept has already been implemented in the Nordic Environmental label criteria for paper.

On the output side, such a system would provide much clearer messages, such as “the level of lead in an eco-labelled product will not exceed 100 ppm”.

2.7.5 Relation to other environmental policies and actions

Another discussion, which is related to the one above, is about the possibilities of integrating eco-labelling with other LCA based tools. Many of the tools under the Integrated Product Policy [COM (2003) 302] (IPP) have in common that the life cycle approach is the basis, and therefore life cycle data on products are necessary for the operation of the tool. Examples are eco-labelling (type I and III), eco-design, green product development and green procurement. But also, tools that are traditionally not regarded as belonging to the IPP family may benefit from a life cycle approach and supporting data. Striking examples are environmental management systems (EMAS and ISO 14001), environmental reporting and cleaner technology measures, like the activities under the IPPC Directive (1996/61).

For example, EMAS registered companies will have to confront the challenge of prioritising the actions that will continuously lower the environmental impact from their production. In the beginning, this will normally be an easy task, because there is a great deal of knowledge about environmental hot spots in the production. But after some years of continuous improvement, then the use of energy, water, chemicals, etc. has been optimised, and the task of prioritisation becomes more difficult. At this stage, the introduction of a life cycle approach may often lead to new knowledge and thus, initiate new actions that may lower the environmental impact further. For this purpose, the companies will need life cycle data, i.e. data related to the product – not the production site, and data from stakeholders around the production site in the product chain.

Once this approach has been implemented and data has been gathered, the basis has been established for a number of IPP tools, which may be integrated on various levels in the company and used by a number of stakeholders around the company: An eco-label license may be obtained, environmental product declarations may be developed and used in marketing, documentation on environmental impacts from products will be available for customers, authorities, neighbours, and other stakeholders – and may be used for greener purchasing. However, one pre-requirement for developing an environmental product declaration for graphics products is the completion of a projects with the purpose of generating uniform methods for collecting data. Internally this approach will provide a unique overview of the product – not only technically on site, but also regarding materials, resources, waste, chemicals etc. which come as input to and output from the site. And the effort of stepping from the life cycle approach and data basis to the other IPP tools may be limited because they all draw on the same basis and data sets. However, today each company has to invent the wheel themselves regarding how to optimise the work across all obligations, but if the schemes developed further integration, then the companies might, for example, report data only once, generating both an environmental product declaration (EPD), giving an EU Flower licence and reporting on best available technology for a line of products.

If these aspects are taken seriously by those who develop and run schemes for labelling and stakeholders around them, then methods and procedures should be developed for integrating instruments a lot more than they are today. The struggle SMEs in particular have in living up to all kinds of obligations to record and report on environmental issues is a strong incentive for the development of an integrated approach to all this.

If eco-label criteria documents were developed in close mutual coordination with developments in other schemes and policies as mentioned above, then the struggle for the licence applicants may be easier. If also criteria on specific issues, like processes, materials and chemicals, could be harmonised, using a modular system, then criteria would be more easily accepted (because they have been used before), more easily understood and more easily communicated. Thereby, also the scheme will be more easily promoted and justified.

Figure 2.2 indicates how some of the IPP tools and other tools may be integrated if a more holistic approach is developed within European environmental policy. The core idea in the Figure is that within a framework platform, life cycle data on specific product families may be collected and agreed on. Based on this framework of data, companies may adjust to their own case with specific data and so have instant access to a number of tools: Firstly an EPD, and if this EPD based on the company specific data shows results below certain levels for each of the impact categories, then the Flower licence would automatically be assigned to the product.

Furthermore, if the company holds an EMAS registration, then the prioritisation would be much easier when the framework of data for the product area is established, because the LCA would point out the hot spots. If the EMAS Scheme is developed with the framework in mind, then it may be designed to give EMAS certified companies an obligation to cover those product group parameters that are defined in the framework. Thus the EMAS based environmental strategy will be further focussed and benchmarking between companies would be well defined.

Environmental reporting as part of a management system or as mandatory in some regions (e.g. green accounting in Denmark) would gain from an integrated framework, because data might be drawn more or less directly from generic life cycle data combined with site specific data.

Drawing the lines for the IPPC Scheme would be mainly on the data side, where the IPP framework and the IPPC Scheme would gain from mutual exchange of data on processes and technology between the BAT (Best Available Technology) Reference Notes (BREF) and life cycle inventory databases, which would ensure that both sides are always updated with latest information, and that data will be available on both the process and production site level as well as on the product level.

Figure 2.2 – Outline of a more integrated set of tools in European environmental policy. Here exemplified by the product family of Printed Matter. See further explanation in the text.

The framework platform as outlined here is not around the corner, but it reflects some of the ideas that are behind much strategy work on IPP and other environmental policies, and there is a large potential in streamlining the environmental obligations for companies all over Europe.

Today, incentives are low, because no legislation prescribes the life cycle approach. However, there is a proposal for a directive soon that prescribes documentation on eco-design considerations for energy using equipment (COM (2003)453), which is the first case of such prescription. It can be expected that this is just the first product area which will be regulated in that way, and therefore a more general shift towards product life cycle based regulative drivers may be expected over the next decade and on.

Coming back to chemicals, the framework outlined may also be coupled to chemicals policy and schemes in future, which may again streamline the obligations for companies to report, for example on the use and discharge of chemical substances.

2.8 Conclusions on issues in future criteria documents

The comparison of the existing Swan Label Criteria Document for printed matter and the results of the Part II LCA study and existing LCA studies reveal a different distribution in the potential environmental impact between sub-processes and issues than presently reflected in the criteria document. The main reason for this is the result of the Part II study including data on production and emissions of chemicals, and chemical related impact categories to a degree not done before, thus making this LCA on printed matter more comprehensive. Furthermore the inclusion of knowledge about generic composition of raw materials for the printing industry combined with knowledge about the potential environmental impact of the components has created the basis for the inclusion of the chemical related impact categories (ecotoxicity and human toxicity).

Many requirements are set, both on the point system level and as absolute requirements for chemicals, but the criteria are not consistent across the document, giving room for environmental properties of chemicals for one sub-process that are restricted for use in other sub-processes. The inconsistent structure of the criteria document creates confusion about which chemicals are allowed and which is not. Thus, a more stringent structure related to substances covered would improve the feasibility of a future criteria document. See Figure 2.1 above on a proposed alternative structure.

A number of further studies are needed to assess and further conclude how to set criteria on chemicals, as this field is new and dominated by lack of data and consensus on methodology.

There is the general discussion about how to set requirements to substances. The following five methods are commonly used in eco-labelling:

• classification based requirements
• negative lists
• positive list
• max. content level requirements
• documentation requirements
• combinations of these

Each method has its pros and cons, and it may be considered – especially if the approach given in Figure 2.1 is adopted – more strategically how and when the different methods should be applied.

Further studies to strengthen the development of criteria that provide the best environmental improvement profile would be:

• a study to identify if criteria should focus on the choice of ink types or ingredients or on cleaner technologies and emission control
• a study to further identify impacts from upstream emissions (e.g. production of pigments)
• a study of the possibilities for optimisation of energy consumption in the relevant processes
• a study on the relevance and steerability of transport processes for printed matter
• a study at sector level on the possibility of changing the functional unit from weight of product to, for example, the area printed product. It is worthy of note that a case study was carried out in Denmark for a single company based on processes and key process figures for only this company in this area.

It may be a good idea to create simple LCA databases for each product group or printing technique (e.g. sheet fed offset, cold set, heat set, screen printing etc.), making it possible to identify the consequences of substitution, consumption reduction etc. during criteria development. The development of these databases could benefit from the experience and the unit processes on sheet fed offset already achieved in the Part II study.

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Version 1.0 August 2006, © Danish Environmental Protection Agency