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Prioritisation within The Integrated Product Policy

4 New product groups for environmental labels

4.1 Identification procedure
4.2 Car purchase and driving
4.3 Tents and outdoor equipment
4.4 Transport services
4.5 Energy for temperature regulation in buildings
4.6 Candles
4.7 Electricity

As part of the application of the project results, 5-6 product groups have been identified for which the development of new environmental labelling criteria would be relevant. This chapter describes the identification procedure, and the identified product groups in terms of the environmental effects that contribute to the results as well as the potential for improvements.

4.1 Identification procedure

A product group for environmental labelling should first of all be environmentally relevant in the sense of having high environmental impact intensity. Thus, the candidate product groups for environmental labelling should be found at the top of the lists in Chapter 1.2.5. Since the environmental labels are restricted to products for which a significant part of its sales volume are sold for final consumption or use (European communities 2000) it is the consumption perspective that is relevant, i.e. the list where fireworks is at the top. In table 4.1, this list is expanded to include more products. The corresponding lists per impact category are provided in chapter 1.4.2 are those for Danish consumption with the largest intensities (Tables 1.20, 1.24, 1.28 etc.).

As a second step, these product groups with high environmental impact intensity are then screened for their relevance according to a number of exclusion criteria, namely:

• Product groups for which labelling criteria already exist
• Product groups not for final consumption or use
• Product groups restricted according to the conditions of the eco-labelling directive (European communities 2000, article 2, point 4 and 5), namely:
  • Substances or preparations classified as very toxic, toxic, dangerous to the environment, carcinogenic, toxic for reproduction, or mutagenic,
  • Goods manufactured by processes which are likely to significantly harm man and/or the environment,
  • Goods which in their normal application could be harmful to the consumer,
  • Food products,
  • Beverages,
  • Pharmaceuticals,
  • Medical devices intended only for professional use or to be prescribed or supervised by medical professionals.

For example, fireworks, in spite of being very relevant in terms of environmental impact, will not be eligible for labelling since it could be harmful to the consumer in its normal application.

Also, as can be seen from Table 4.1, many of the products with high environmental impact intensity are food products (including animal foods) and therefore not eligible for environmental labelling. It is somewhat provoking that many environmentally relevant products are thereby excluded from environmental labelling, and this could suggest that it may be relevant to re-consider this exclusion criterion when revising the eco-labelling directive.

Table 4.1. Products in Danish consumption sorted according to falling environmental impact intensity, and indexed according to eligibility for new environmental labelling criteria.

(a) Non-durable household goods is a very complex product group, covering items such as labels, polishes, minor textile items, wrapping paper, brooms and brushes, carbondioxide cartridges and pesticides. Some of these items are already labelled (some polishes and textile items) while some are potentially harmful in normal application (pesticides).
(b) Although not under environmental labelling schemes, these products could – in parallel to foods - be labelled as “from ecological agriculture” (“Det grønne Ø-mærke”)

As a third step, the product groups that pass without remarks in Table 4.1 (indicated with italics) are then evaluated on two further criteria:

• The volume of sales in the EU
• Steerability, i.e. the extent to which the environmental impact can be influenced by ecolabelling (NEB 2001).

This is documented in Table 4.2.

Table 4.2. Sales volumes in EU-25 in 1999 in GEUR (billion Euros) corrected to EU-15 PPS (purchasing power standard) and steerability of the eligible product groups from Table 4.1.

1) Total values from Eurostat (2004) extrapolated to EU-25 by Nielsen (2004)
2) Not including electricity
3) Estimated as 22% of non-durable household goods, based on the Danish consumption pattern. An industry source (Dreyer 2004) estimate that the correct value may be closer to 5 GEUR as the consumption per capita is larger in Northern Europe than in the rest of Europe, corresponding also to the consumption in the USA (approx. 0.1% of the total retail sales).

From the three steps reported above, we arrive at the following products for which we in the following sub-chapters will describe the contributing environmental effects and the potentials for improvements via ecolabelling:

• Car purchase and driving
• Tents and outdoor equipment
• Transport services
• Energy for temperature regulation
• Candles
• Electricity

4.2 Car purchase and driving

Taking up approximately 12% of the average household budget and topping the list in terms of environmental impact intensity, automobiles are of obvious interest for ecolabelling.

However, it could be argued that cars do not fulfil the conditions of the EU eco-labelling directive, since automobiles “in their normal application could be harmful to the consumer.” In 1997 an estimated 165,000 persons were killed on the roads in the ECE region and more than 6 million persons were seriously injured (UNECE 2004). Out of this number more than half were consumers (car drivers or passengers).

On the other hand, it can be argued that accidents are just one of the detrimental effects of car driving, which could be taken into account in the ecolabelling criteria, e.g. in the form of requirements on safety measures for both passengers and other road users.

Another argument against ecolabelling on automobiles would be that as a mode of transport it is less environmentally beneign than alternative modes of transport, notably rail transport (Dom & de Ridder 2002). Thus, it could be argued that out of the different transport modes, only railroads should be eligible for ecolabelling (see also Chapter 4.4). However, current car usage shows clearly that often other modes of transport are not seen as realistic alternatives, which would support an ecolabelling initiative that could at least help the consumers reduce their impact of car driving.

Leaving these discussions aside, we find that the main environmental effects from automobiles are related to the emissions from fuel combustion during driving. A recent EU Directive (1999/94/EC) requires comprehensive labelling for all new cars providing information on carbon dioxide emissions and fuel economy. The UK Government promotes moving this further towards comparative labels in line with their Vehicle Excise Duty, which are based on vehicles' CO₂ emissions and fuel type (CVTF 2002).

Also the vehicle production itself contributes significantly to the overall impacts, both due to its chemicals use (VOC emissions), energy use (especially electricity) and materials use (aluminium and steel), thus leaving ample room for developing further ecolabelling criteria relating to the production itself. As a pioneering effort, the car manufacturer Volvo provides environmental product declarations for their S80, S70, S40 and V40 models. Weight reduction is one of the most practical ways to increase the fuel economy of vehicles, and is thus complementary to the efforts to reduce chemical, electricity and materials use in the vehicle production.

CVTF (2001) identified several so-called Environmental Rating Systems (ERSs) in the public domain, and state: “These efforts, however flawed, are the only guidance available to consumers and others that wish to understand the relative environmental performance of one model compared with another. Given the lack of such an ERS from either government or industry, it is likely that independent efforts will continue to be developed - whether or not they accord with government or industry needs”.

As pointed out in section 1.7.9, the most direct improvements option is to focus on reducing the need for car driving, an issue which cannot easily be covered by ecolabelling. However, there may be possibilities for including ecolabelling criteria relating to equipment that can assist in reducing driving needs, e.g. GPRS systems for improved route planning, and registration equipment that provide driving statistics for improving vehicle usage patterns through mobility management. Registration equipment may also be used for improving driving behaviour towards a better fuel economy and reduced emission intensity.

We thus conclude that there are many options and arguments for developing ecolabelling criteria for cars.

4.3 Tents and outdoor equipment

Ecolabelling criteria already exist for textiles in general, but these do not cover textiles used in tents. It is therefore obvious to consider if these criteria could be extended to cover textiles used in tents.

4.4 Transport services

Transport services include mainly passenger transport by railroads, busses (both regular and chartered), taxis, aeroplanes (regular and chartered), and passenger ships. Included in this product group is also, but with less importance, facilities for car parking, removals companies, travel agents and tourist agencies.

We concentrate here on the passenger transport. The different transport modes are in principle comparable, since they all transport passengers a certain distance, although with differences in speed and comfort. Thus, it could be argued that ecolabels should only be applicable to the transport mode with the least environmental impact per passenger*km, which (disregarding walking and bicycling) is rail, and busses when rail is not available (UITP 2003).

This could also be seen as an argument against ecolabelling automobiles, see Chapter 4.2. However, as an alternative, rail transport is obviously limited to the areas covered by the rail network. Furthermore, from current usage patterns we can see that even when rail is a physically existing alternative, users often do not accept it as a comparable mode to cars and aeroplanes. This means that an ecolabel on a specific transport mode would not be able to move many passengers from other modes.

Considering instead an ecolabel for transport services within each specific transport mode encounters another problem, namely that often only one transport option exists within each transport mode, e.g. only one rail or bus line connects two specific geographical points. An ecolabel would not be able to increase use of this option. An exception is taxis and chartered operators, for which ecolabel criteria would be possible, in parallel to the considerations for private cars (see Chapter 4.2).

A more promising option may be to develop ecolabel criteria for mobility management schemes, e.g. the management and consulting service reducing the overall impact of transport within a specific organisation (see e.g. www.vtpi.org and www.epommweb.org). This would overcome the limitations of ecolabels on specific modes of transport, and could generally improve consumer travel options, encourage competition and innovation, correct mispricing by converting fixed costs into variable costs, and allow consumers more pricing options (VTPI 2004, page “Market Principles - TDM Impacts on Market Efficiency and Equity”).

4.5 Energy for temperature regulation in buildings

While the emissions related to temperature regulation in buildings are connected to the energy carriers, the heating or cooling requirement is determined by characteristics of the building. Thus, ecolabelling could be implemented both as an energy labelling of buildings and as an ecolabelling of energy carriers according to their environmental impacts per supplied volume of heating or cooling.

Energy labelling of buildings could be based on standard calculations of heating and cooling requirements. The EC Directive 2002/91/EC sets out energy performance requirements for new buildings and larger renovations as well as requirements for energy performance certificates when buildings are constructed, sold, or rented out. However, the directive does not cover the existing, smaller buildings, which contribute to the major part of the energy use, nor does it place any specific technical requirements on how energy performance should be calculated. An energy label could have a wider application area and include more specific requirements for the quality and thoroughness of the underlying energy audit e.g. requiring thermographic inspection of insulation defects and a quantification of the air leakage. A Finnish project on energy certificates for buildings (Aho et al. 1997) suggested that the most appropriate means of introducing an energy label to the market is to combine it with the existing energy audit or building assessment schemes.

A general reservation towards voluntary energy labelling of buildings is that purchase or renting of a dwelling is a decision made only a few times in the lifetime of a consumer, which may make the effect of labelling questionable. The incentive for a seller or lessor to have the building labelled is also unclear. More direct incentives that integrate the cost of heating and cooling in the price of the dwelling are likely to have much more effect.

Ecolabelling of energy carriers is straight-forward, since the environmental impacts per supplied volume of heating or cooling are easy to establish. Renewable energy sources are obvious candidates for ecolabelling. Ecolabelling criteria for solar collectors have been developed in Germany (RAL 2003), mainly including an energy efficiency requirement.

4.6 Candles

The main environmental impact from candles appears to come from their release of CO and soot in the use phase. Besides the obvious health risks involved, soot also leads to increased demand for cleaning and renovation of household textiles, re-painting walls and ceilings, etc.

Also other air emissions during combustion, such as VOCs, may be of importance, especially when considering that the emissions primarily affect the indoor climate. Imported candles may still contain lead in the wick. Scented candles obviously contain more VOCs.

Candles are produced largely from stearic acid and/or paraffin, with mainly vegetable and mineral origin, respectively. Soot (and CO) formation depends on both the raw material type (basically the carbon/hydrogen ratio of the fuel), the purity of the raw materials and additives, and the correct dimensioning of the wick to the candle (Matthäi & Petereit 2004). High content of iso-paraffins or a high degree of branched molecules will decrease the flame temperature and result in a higher tendency of the flame to soot. Other environmental advantages and disadvantes of different raw material compositions warrant further investigation (differences in environmental impacts during production, differences in net CO₂-emissions).

A German product standard for candles (www.kerzenguete.com) contains procedures for optical inspection of the burning behaviour and the purity of raw materials, e.g. sulphur content. It explicitly forbids azo-colourants. A proposal has been made to include also a method for quantification of soot emissions (GK 2002).

There is work in progress to develop a European (CEN) standard (Matthäi & Petereit 2004, Thorhauge 2004), convering fire safety specifications (e.g. flame size, liquid temperature, wick stability, self-extinguishing) and safety signs and warnings, as well as a measuring method for a soot index.

These standards thus provide a good starting point for developing ecolabelling criteria. Representatives from the major industries (Dreyer 2004, Kilström 2004) have indicated willingness to participate constructively in such a development.

4.7 Electricity

The environmental impact from electricity production differs widely, depending primarlily on its source (hydro, nuclear, wind, photovoltaic cells, biomass, lignite, hard coal, oil or gas) and secondly on the efficiency of electricity production and transmission.

The product itself, electricity, is perfectly homogeneous, and therefore comparable across all sources and production facilities. Thus, it is only meaningful to award the eco-label to the source(s) with least environmental impacts, which typically implies an exclusion of the fossil fuel sources.

A possible controversy may arise in relation to nuclear power, as its environmental impact is of such different nature than the other power sources, that a comparison is complicated. Being based on a limite resource base (uranium), nuclear power is not counted as a renewable energy, and its severe problems relating to security and long-term waste has generally excluded it from being considered as an environmentally acceptable alternative. On this background, any further expansion of nuclear power in Europe has until recently been regarded as unlikely (EC 2000, Mantzos et al. 2003). However, the Finnish decision in 2002 to build a new nuclear power plant has challenged this view. The background for this shift in opinion has been the growing focus on global warming, where nuclear power is seen as a quick solution to avoid further increase in CO₂ emissions (CEC 2002d).

Some of the most promising renewable power sources, notably wind and photovoltaic cells, are dependent on natural fluctuating flows, which implies that they are best seen as components in a mix with other back-up sources that can fill in and stabilize the fluctutations. In this context, it is also important to consider how the total mix of sources will be able to cover peak demands, both daily (morning and evening peaks) and seasonal (cold or hot seasons with extraordinary heating or cooling requirements). For these reasons, we recommend to develop ecolabelling criteria for self-reliant mixes of electricity sources, not for individual sources alone.

The EU Directive 96/92/EC of June 2003 requires that electricity suppliers disclose their preceding year's fuel mix, broken down on sources, including also information on emissions of CO₂ and radioactive waste. This could be seen as a first step towards a common labelling, but does not in itself include any incentives to minimize the environmental impacts neither from the current production nor from any new capacity installed.

Many labelling initiatives for so-called “green” electricity already exist. Some of the more well-known are the Swiss naturemade-Star (www.naturemade.org), the German OK-power (www.ok-power.de) and Grüner Strom Label (www.gruenerstromlabel.de), the Austrian ecolabel richtlinie UZ46 “Grüner Strom,” and the Swedish “Bra Miljöval” (www.snf.se/bmv), which is also sold in Denmark as “Naturstrøm” by NESA. A total of 18 labels have been reviewed by White & Vrolijk (2003). The labels have very different concepts of what is meant by “green” electricity, and often include different levels of compliance, some based on a minimum supply from “new” plants, i.e. plants constructed after a certain date, others based on matching current production with current demand. Most of the existing labels allow the inclusion of both hydropower and electricity from direct biomass combustion, which from an ecolabelling perspective appears questionable; see also the discussion of individual power sources below. Some labels even allow co-generation to be a part of the fuel mix. Some labels are more restrictive, like Københavns Energi's “Solstrøm” based exclusively on photovoltaic cells, but resulting in very high prices for the labelled products.

Regarding hydropower, the main environmental concerns are the disruption of the reservoir areas and the barrier effects in relation to fish migration. As a renewable energy source with very limited emissions to the environment, it would be an obvious candidate for ecolabelling, if further expansion of production volume were possible. However, due to its relatively large-scale effects on the landscape, there are few locations in Europe where an expansion is likely (Mantzos et al. 2003). Due to the low cost of production, hydropower will at all times be utilised to the maximum possible, which makes it irrelevant to promote the production through ecolabelling. As has been pointed out by Weidema (2001), such labelling may mislead consumers to think that their purchase of labelled electricity leads to an increased production of hydropower, when what in fact happens is only a reduction in sales of non-labelled hydropower from the same production facilities, thus having no net effect on the environment. Or in the words of the Finnish Consumer Ombudsman: “power companies now sell as green electricity the same electricity which they used to sell cheaper without a green label. Practically all the electricity which is now sold as green is produced in the same way as before. Emphasizing the environmental effects of consumers choice of electricity is therefore misleading.” (Kuluttajansuoja no.2, 1999). The Swiss Naturemade-Star label was one of the first to take steps to avoid such consumer mis-information, since they include a requirement that the entire additional revenue from selling labelled hydropower is to be used for additional distribution and marketing costs for labelled electricity, ecological improvements at the power plants, and a so-called promotional model (Fördermodel) implying that per kWh naturemade-star hydro power, 0.025 kWh “new” naturemade-star renewable electricity (wind, biomass, photovoltaics) must be sold. Such promotional models are now included in other labels, and is one of the key requirements in the pan-European EUGENE labelling initiative (www.eugenestandard.org). However, even though such arrangements reduce the possible problems involved, they do not in themselves provide an argument for including old hydropower plants in the power mix for ecolabelled electricity. With the application of appropriate promotional models, one could equally well argue for the inclusion of coal-fired power plants in the power mix. The main motivation for including hydropower in the “green” electricity mix, is to reduce the overall price of the labelled electricity, with the aim of reaching a larger customer group. However, such “manipulating” of the price of ecolabelled electricity may in the long run harm the credibility of the ecolabelling concept. Thus, notwithstanding that even hydropower can be produced with more or less environmental impact (see e.g. www.greenhydro.ch), we generally advise to avoid inclusion of hydropower in ecolabelling programmes, due to its specific market situation (low production costs, low environmental impact, few options for expanding the production volume). At least, to avoid mispricing, the share of hydropower in a specific ecolabelled power mix should not exceed the share that hydropower has in the total power mix.

In terms of air emissions, direct biomass combustion is not very different from fossil fuel combustion, although the CO₂ emission can be argued to be environmentally neutralised by the equivalent uptake of CO₂ during biomass production. The latter requires, however, that there is no net change in CO₂ release between the biomass production and combustion system and what would have occurred in the absence of biomass harvest (the undisturbed reference system).

Anaerobic biomass fermentation and subsequent combustion of the biogas provides a biomass based power source with lower air emissions, and is a likely candidate as the back-up fuel stabilizing the fluctuations in an electricity mix based on wind and photovoltaic cells.

Wind energy and photovoltaic energy are likely to play key roles in an ecolabelled electricity mix. Both have their main environmental impacts in the production of the power plants (wind turbines and photovoltaic cells), with some concern also due to the impact on natural areas (wind turbines mainly as an aestethic problem, photovoltaic cells more as an area consuming activity). With the recent large turbines, wind power is close to being competitive on normal market conditions, which could put the role of ecolabelling into question, as has been done for hydropower: If wind power capacity is anyway expanded as quickly as possible for purely financial reasons (probably mainly limited by technological lock-ins within the energy planning and political decisions on location of wind parks) an ecolabel would not be able to influence this expansion further.

In spite of the complications mentioned, we believe that it should be possible to design ecolabelling criteria for electricity in such a way that it favours the expansion of a self-reliant mix of power sources with the lowest possible environmental impact.

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Version 1.0 February 2005, © Danish Environmental Protection Agency