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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

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
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