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Integrated Supply Chain Information

6 EU-Eco-label and EPD

The EU Eco-label and the EPD system are analysed with the objective to identify potential synergies between the two schemes. The analysis is based on product categories for which both EPDs and eco labels are available. The Swedish scheme – based on ISO type III labelling - is presently among the most developed schemes in Europe and is therefore used as example of an EPD-system in this analysis.

Environmental impact parameters handled in the eco label criteria for two product areas have been identified, and suggestions are made for how environmental product declarations might look if they were to be based on already exiting criteria documents.

6.1 Strengths and limits of the EU eco-label scheme

One of the main advantages of the eco label is that it is simple and easy to recognise. The eco label is therefore an easy tool for the consumers who want to buy environmental high quality products. Furthermore the system is reliable as it is 3rd party verified and as the products has to comply with criteria defined by experts and adopted by authorities.

Advantages and disadvantages of the EU Eco-label

Advantages:

  • Simple
  • Easily recognizable at the product
  • Reliable as 3rd party verification
  • Based on well defined criteria adopted by public authorities

Disadvantages:

  • Simple - "either-or" criteria
  • There may be non-labeled products on the market with a better environmental profile than labeled products
  • Long periods between up-dated versions compared to progress of product innovation
  • The criteria documents and guidance may not be readily understandable by applicants

Some companies find that the eco label is not applicable as a market tool. The most often arguments used is that the eco labelling system is subjective and very simplified as they are based on politically established “either-or” criteria. If the environmental impact of a product was presented in a quantifiable manner, an impartial comparison of the environmental impacts of the product could be achieved. Therefore, some companies would instead prefer a product declaration system based on the internationally adopted ISO standard, type III labelling.

The box above highlights some of the advantages and disadvantages of the eco label as a market tool.

6.2 Strength and limits of the EPD scheme

The ISO type III labelling was introduced as a consequence of the growing industrial demand for quantifiable environmental information about products and services.

The Swedish scheme was the first in Europe and is primarily intended for the professional part of the value chain. The objective is to facilitate a standardised and credible market communication of environmental aspects of products.

Until now, EPDs have primarily been developed for heavily energy consuming products such as refrigerators, washing machines, pumps etc. An outline of existing EPD's in Sweden is presented in Annex 2.

As is the case for general life-cycle assessments, there is a tendency for EPD's not to represent hazardous chemicals sufficiently. A PCR has been developed for chemical products in general [6], which can be used for technical-chemical products such as paint/varnishes, detergents etc. So far, an EPD has only been prepared for methyl ethyl keton [7].

Advantages and disadvantages are roughly listed in box below.

Advantages and disadvantages of the EPD system

Advantages:

  • The presentation is impartial and neutral
  • Impact categories selected by experts based on LCA assessment priority setting
  • The quantifiable presentation form makes the manufacturer able to continuously measure the development of his products
  • Products may be compared according to level of environmental loads within preset categories

Disadvantages:

  • Environmental load information is difficult to interpret for non-experts
  • It is costly to establish product specific requirements for new product areas
  • The data collection process is very comprehensive
  • It may be difficult to achieve quantitative data from suppliers (for eco-label criteria, compliance statements are sufficient)

6.3 Comparison of the Eco-label and EPDs

General similarities and differences between the EU Eco-label and the EPD are presented table 6.

The table illustrates, that the primary differences are to be found in aspects linked to the different targets groups: The professional “up-stream” users and the end-users. A linkage of the two systems seems obvious, as the upstream user needs life cycle data to be able to document the compliance with the eco-label criteria.

The barriers for a technical linkage are analysed in the following for product groups for which both EPD product specific requirements and criteria for eco-labels are present: Washing machines and paint/varnishes. The primary data is presented in Annex 3 and the main findings discussed below.

The EU Eco-label Swedish EPD scheme (ISO Type III label)
Benchmark environmental performance criteria within a product group. Quantitative aggregated environmental impacts categories within a product group
Primary target group: The consumers and other end users Primary target group: Professional down stream users
Based on life-cycle performance of a pre-defined and weighted set of core environmental attributes Based on the lifecycle performance of a pre-defined set of core environmental attributes
Third party verified Third party verified
Only products fulfilling preset criteria are to be assigned the label All products within the preset product group and which fulfil the data requirements may apply the declaration
Rigid categorisation. Either the product/service is assigned the EU Eco-label or it is not. Quantitative assessment based on well-defined system boundaries and data requirements. Comprehensive data providing environmental information on a product, similar to a nutritional declaration for food.
Signalise the product's environmental performance. Need more products with an EPD within the same category to asses the environmental performance of the product.
Based on life cycle thinking – only criteria for selected parts of the life cycle represented Based on life cycle assessment. Only selected parts of life-cycle loads represented in the EPD
Public authorities adopt criteria based on expert assessments. A Competent body decides upon product specific requirements for each product category. Down stream users make their own judgement regarding environmental quality.
Relatively moderate data collection requirements. Supplier needs to provide guarantees that the criteria are fulfilled, not exact data. Very time demanding. Supplier must provide the producer with specific data of the product performance. Can be problematic due to confidentiality concerns.
Chemical content a significant factor in the criteria for some product categories. Tendency not to consider hazardous chemicals

Table 6 Brief comparisons of the EU Eco-label and the Swedish EPD scheme.

6.3.1 Washing machines

For washing machines all necessary data for the potential documentation of fulfilment of EU Eco-label criteria are included in the PCR (table 7) with a few exceptions. Hence, if an EPD for a washing machine is prepared, the extra workload of applying for the EU eco label is very low provided the applicant can document compliance.

The EPD on the other hand requires much more information to be available compared to the eco-label requirements.

Table 7 Data inventory requirements for the EU Eco-label and PCR for washing machines.

Category EU Eco-label PCR
Manufacturer info
Manufacturing Company Yes Yes
Manufacturing Site Yes Yes
Issuer and contact Yes Yes
Guarantee statement Yes No
Estimated lifetime No Yes
Environmental performance declaration
Refinement No Yes
Resource Consumption Yes Yes
Electricity use Yes Yes
Transportation
Refinement → Production No Yes
Production → Sale No Yes
Sale → Use No Yes
Use → Disposal No Yes
Production
Energy Consumption No Yes
Use of Chemicals Yes, detailed Yes, detailed especially for use of
heavy metals as well as halogenated
and brominated flame retardants
Material List Yes, some specific materials, mainly chemicals. Yes, total list
Emission Estimation to air and water Yes, name of components Yes
Greenhouse Emissions No Yes
Resource Consumption No Yes
Use of resources
Energy Efficiency Yes Yes
Water Consumption Yes Yes
Spin Drying Efficiency Yes Yes
Noise Yes Yes
Control of Detergent use Yes No (not mandatory)
Criteria for users manual Yes No
Washing Performance Yes Yes
Category EU Eco-label PCR
Disposal
Recycling Yes, declaration has to be prepared Yes Specification has to be made
Amounts of waste No Yes
Hazardous waste Yes Yes
Separable hazardous materials Yes, declaration has to be made No
3 Public accessible data Data is kept confidential. Specific data is kept confidential
depending of the PCR. The
environmental key figures and
conclusion are to be stated in the
EPD, which is public accessible.

6.3.2 Chemical products / Paint and varnish

Under the Swedish EPD scheme a PCR for chemical products in general have been elaborated (Annex 1). In the following, this EPD has been compared with the background document and the criteria document for the EU Eco-label.

As the product group definition for the two product groups is very different – paint and varnish being a sub-group under “general chemicals”- a detailed comparison is not directly possible. However, it is interesting to compare the two documents in order to analyse whether the generic information relevant for paint and varnish eco-label is included in the PCR for chemicals (table 8) and also the LCA inventory applied for both of them.

Table 8 Comparison of EU Eco-label criteria for paints and varnishes and PCR for chemical products.

The EU Eco-label
Paint/Varnish 		The EPD/PCR
Chemical Products
General Information
Product group well-defined Product group not specific
Amount of product needed for 20 m² surface Based on functional unit of 1000 kg
  Definition of product, manufacturing process, manufacturing location etc is needed
Health and safety labelling
A declaration description (safety data sheet or similar) for ingredients has to be forwarded to the certification body Labelling: Safety and risk phrases have to be stated according to section 15 in the safety data sheet
Cut-off rules
Eco-label criteria values pre-selected The manufacturer can omit information concerning activities assessed to contribute to less than 1% of the total environmental impact. The manufacturer has to explain the reason for omitting data
Production
Not required Detailed description of environmental impact potential in the production phase, keeping the cut-off rule in mind. Detailed information on resource consumption
Requirements to emissions of SOx, sulphate waste and chloride waste from the production of the titanium dioxide pigment used. Emission to air (CO2, CH4, NOx, CO, VOC and particles) Emission to water: N total, P total, COD. Emission of toxic substances. Selection criteria shall be included.
Product requirements
Declaration of composition required. Declaration of composition required.
Instruction manual required. Description of application method needed.
Restrictions on the content of white pigment, VOC, VHS, heavy metals and dangerous substances. General information on chemical content of a product is required.
Ingredients criteria: Restrictions on content of compounds classified with N “Dangerous to the environment”, the content of formaldehyde, and isothiazolinone compounds.
Any use of alkylphenol ethoxylates and diethylene glycol methyl ether is prohibited
Use
Declarations on covering efficiency, water resistance etc. Not mandatory.
Safety instructions required No immediate requirements, but if the chemical product has a predominant field of application, a quantitative assessment of environmental performance of this particular scenario should be presented.
Transport
No requirements Impact potentials from transport have to be estimated.
Disposal
Description of recommended disposal procedures has to be declared, if possible through pictograms Recycling material, hazardous waste and other waste information is mandatory. An explicit recycling declaration is voluntary
Other
  Name of certification body and reference to homepage of EPD system needed.

The major differences appearing from table 8 are predominantly due to the different coverage of the two labels and concrete criteria values selected for the Eco-label. For example declaration demands will primarily be missing in connection with the (end) use of the product, such as instructions for use, warranty etc. that should not be difficult for the manufacturer to prepare or produce.

An interesting point regarding the PCR for chemical products is that additional requirements are needed, if the chemical product has “a predominant field of application”. If this is the case, a quantitative description of the environmental performance related to the specific use of the product is required. This will make the EPD for a specific chemical product groups more similar with an eco-label background document. However, there is no requirement to the form of this additional information.

Based on the eco-label criteria, the relevant safety data sheets for a “generic” paint/varnishes and the generic PCR for chemical products an “environmental product declaration for a paint/varnish” has been prepared (annex 2). This example shows that most of the information requested to elaborate a product specific EPD fulfilling the generic PCR requirements may be obtained from the eco-label criteria document (the eco-label application). On the other hand, relevant information to be used for an eco-label application may be picked up from a paint and varnish specific PCR.

The functional unit is very different in the two labels and for good reasons. For the EPD, the functional unit is 1000 kg product (to be applied for comparison of various chemical products with different applications) whereas for the EU eco-label criteria, it is the amount of paint required to cover 20 m² surface (comparison of products with the same application). There is a need for guidance regarding the additional requirements when an EPD are to be elaborated for a specific product group based on the generic PCR requirements. Such guidance should apply the eco-label functional unit whenever appropriate.

The type of information which only appears in one of the labels are summarised in the boxes below:

EPD

  • Description of the production process- upstream data in general
  • Description of Lifecycle inventory
  • Resource Consumption
  • Information of environmental impact potentials from LCA-emission categories
  • Quantifiable data
  • Common functional unit

Eco-label

  • Instruction manual
  • Warranty statement
  • Disposal recommendations
  • Use of personal protective equipment
  • Use based functional unit

There are no obvious reasons for most of the differences and they are therefore probably the result of lacking co-ordination.

6.4 Synergy between the EU Eco-label and a (future?) EU EPD system

The above analysis of the data requirements for the Swedish EPD and the EU Eco-label gives rise to a number of recommendations for coordination needs should an EU EPD scheme be established.

1: Common LCA foundation

As both schemes are life cycle based, it would be an advantage to use a common LCA foundation. This would lead to consistency in the data collection and to joint system boundaries/definitions. Data collection for lifecycle assessments are very time consuming and a joint data collection effort would save resources. Consequently, it is recommended, that a common background document should be prepared for the establishment of criteria for the EU eco-label and for the preparation of PCR for the EPD's, respectively.

2. Common PCR for both schemes

Both schemes may be based on the same PCR elaborated as a concerted action between the competent bodies for the two schemes. If eco-label criteria were to be developed for a given product group, this could be done based on the PCR for the product group. This would ensure that a manufacturer in the process of developing an EPD immediately would be able to determine whether it would be possible to obtain an eco-label for the product. A rough example of a coordinated information flow is shown in figure 3.

Figure 3 Example of subdivision of PCR for chemical products

Figure 3 Example of subdivision of PCR for chemical products

3. Individual ”functional units”(FU)

The PCR documents for preparation of EPDs under the Swedish EPD-system are worded very broadly whereas the EU Eco-label criteria document is specified for each individual product group. The functional unit for a PCR thus covers a wide range of product types, particularly for chemical products. When a PCR is to be elaborated, functional units should be specified for sub-categories of products to make it compatible with the functional unit for the EU Eco-label criteria. In practise, this work could be performed as “concerted action” between the relevant competent bodies.

4. Common verification body

If the data collection was coordinated and a common LCA foundation was established for the two schemes, certificates could be awarded in a combined or co-ordinated certification procedure. The same competences are needed for a verifier of the two schemes and since the two systems are meant to complement each other and not to be competitive it is expected that a common verification body may improve the efficiency significantly.

Footnotes

[6]Product Specific Requirements for Chemical Products, PCR 2000:5. The Swedish Environmental Management Council, Version 1.0 (www.environdec.com)

[7]Environmental product declaration (EPD) for Methyl Ethyl Ketone. Chemiway Maruzen Petrochemical co (www.environdec.com/reg/e_epd49.pdf)

 

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Version 1.0 February 2006, © Danish Environmental Protection Agency