February 5. 2023. 7:27

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Academic: ‘Mandatory EU labelling is the only way to fight proliferation of ecolabels’

The European Commission’s upcoming sustainable product initiative should seek to clean the market for ecolabels and impose an EU-wide standard based on lifecycle assessment, says Professor Finkbeiner. However, “I doubt that the EU Commission will be brave enough to put out a mandatory label,” he told EURACTIV in an interview.

As an expert on lifecycle assessment, you took part in the European Commission’s Product Environmental Footprint (PEF) process several years ago. Can you briefly describe the purpose of the PEF exercise? What products did you evaluate, and how did the process conclude?

The whole idea of this environmental footprint initiative was to standardise the European Commission’s way of performing lifecycle assessments (LCAs). And this was done by developing basically their own methodological approach on how LCAs are supposed to be done.

In parallel, the Commission did some 20 pilot studies that looked into different products from the food and non-food sector and developed specific methodological rules called PEFCRs – or Product Environmental Footprint Category Rules – for specific product types. These set out specific rules for how LCAs are supposed to be done for those particular products.

The pilot phase concluded in 2016, and they are now in a transition phase. So the process is basically ongoing, maybe with a slightly lower profile.

The main target now is to fine-tune the method and develop proposals for how it could be implemented into policy.

The PEF pilot studies were conducted by the European Commission in 2013-2016 and focused initially on food and drinks like wine, olive oil or packed water. However, some of those pilots were discontinued, like those regarding meat and marine fish. What was the reason for this?

There were two waves: the first wave was non-food related, and the second focused on the food pilots. And in the course of the process, several pilots were stopped, including the one on meat.

I don’t have first-hand information on why it was stopped, but from what I understand, the process was quite demanding and a moving target, with changes in the methodology. And the whole exercise was getting more demanding in terms of budget and resources.

Some pilots also were not completely happy with the direction the process was taking and the rules they were supposed to follow under the regime.

What were the main challenges when evaluating the environmental footprint of a product in those pilot projects?

The biggest challenge was that there was no precise policy implementation scenario. To develop LCA as a policy tool, you must start with a goal and scope definition phase. Because you have to make the LCA fit for a specific goal or purpose.

And in this case, the purpose of the whole exercise was to be kept completely open. The European Commission started by seeking to tackle the jungle of green labels currently on the market and developing an EU-wide green label to replace them.

But later, the scope was widened to include public procurement and greening the industry – whatever the problem was, the environmental footprint methodology would fix it.

And that made it a challenge to develop a method that is really fit for purpose. Because if you develop a method to improve products or a method for eco-labelling, then you have to consider different things. And even though the overall target was to harmonise the different approaches, it actually ended up in a piecemeal approach because the pilots were quite different. In addition, the industries working on those pilots had different agendas.

Another challenge related to bureaucracy – the European Commission asked a lot of documentation of the participants. And some of the approaches tested in the impact assessment were not very mature. For example, they tested methods that everybody knew from the start were not going to work, which was not very efficient.

It’s a long trail, I could speak for two hours about the challenges, also because they differ between product groups. But the main problem was that it wasn’t clear – and it is still not clear – how this method actually is going to be used.

I think they tried developing something that is fit for every purpose, but with that approach, you usually end up with something that is not really fit for any purpose.

It seems the purpose may now be clearer. If you look at the European Commission’s upcoming sustainable product initiative, it focuses on green claims and labelling. Do you believe this will make it easier to choose the right methodology?

Definitely, if you have a clear goal, you can actually make the method appropriate for that. But it remains to be seen what exactly the Commission will come up with in its proposal.

Take, for example, the “EU flower”, the ecolabel of the European Commission. That is being developed by the Commission’s environment directorate, which is also in charge of the product environmental footprint method. The most straightforward thing would be to marry these two initiatives. So I’m quite curious to see how they actually want to link it.

In theory, a new ecolabel should tell the consumers why this is more or less robust than the existing ones. Or that it is cleaning the market from greenwashing by imposing a new label.

However, it remains to be seen whether the environmental footprint methodology can easily accomplish this. nd I’m not quite sure how concrete this proposal will be. We have worked, and we even published scientific papers on different options for how the PEF could be implemented for labels, depending on whether they are consumer-facing or not.

So labelling is definitely one potential use of the method. But it has to be adapted specifically for this purpose.

The sustainable product initiative will apply the PEF methodology to new categories of products like electronics & ICT equipment, textiles, furniture, etc., with a view to develop consumer-facing environmental labels. Do you believe the methodology is sufficiently mature to deal with these product types? Or do you see shortcomings there that still needs to be addressed?

I definitely see shortcomings in the environmental footprint method we have right now to be used in consumer labels.

On the other hand, the current situation with so many consumer ecolabels is a challenge as well, and many are not lifecycle-based at all. So I definitely support a consumer labelling scheme based on lifecycle assessments, even though there are challenges in verifying the information and making it really robust.

And even though I’m supportive of the idea, I still have doubts that the method that has been developed so far is ready to serve that purpose.

Like I said, there is already an EU ecolabel, the “EU flower”. And we have environmental product declarations. And for some product groups like paper or paints, we already have these two types of labels.

Now the key question is: do you use the environmental footprint to improve the existing labelling scheme, or do you put out another voluntary one? And as soon as you put out another voluntary label on the market, you contribute to the proliferation of labels rather than cleaning the market.

And I doubt that the EU Commission will be brave enough to put out a mandatory label. Because it means this will become the only option, and all the other labels will have to go.

This would be the only approach to fight the proliferation of labels. But I don’t believe they will dare go there.

Regarding the footprint measurement, what are the main categories that you are looking at? Is it water consumption, CO2 emissions or other types of environmental impact?

As environmental scientists, we focus on minimising the trade-offs. To save the Earth’s climate, for instance, you should not kill biodiversity or deplete water resources. That’s why we say it’s important to look at the broad set of impact categories and not only one.

Now the PEF methodology tries an intermediate approach. For a particular type of product, they prioritise 3, 4 or 5 main environmental impacts that should be looked at.

And that is already a bit risky because it means that all the other impacts are neglected. If you take the PEF pilots, for example, none of them prioritised radioactive emissions from energy use in countries that choose nuclear power. That means shifting all your energy systems to nuclear energy will come out as a winner in this case because the specific emissions of nuclear power won’t be taken into account.

The incentive for companies when doing PEF assessments is to be able to communicate the results when they are positive. Can a simple consumer label be sufficient to communicate complex findings? Traffic light systems, for instance, is often used in food. So what do you think an ideal consumer label should look like?

As an environmental scientist, the main challenge for me is the one that you described – the message for consumers needs to be highly simplified, ideally a black-and-white message, which basically says: ‘I’m a good buy’.

However, if you look at LCA, it’s unfortunately rarely the case that a product is clearly preferable to another one. And that’s a real challenge. That’s why environmental scientists like me prefer introducing a bit of nuance with more transparency about the trade-offs for each product. But of course, communication people don’t really like that.

And with the traffic light system – yes, it’s understandable, it’s well established. But the problem is how you set the benchmark. Some PEF pilots were quite smart and put the legal limits for some of the constituents in the benchmark recipe.

But in the end, you may end up finding that every product that is legally on the market is well below the benchmark. Whereas if you take an average, you know that more products will end up looking good.

And finally, the main question is whether you make the label voluntary or mandatory. As long as the label is voluntary, you will only get labels with a green light, because why would anyone say: ‘Hey, look, I have a really bad product’! And then, in the marketplace, you end up in a strange situation where everybody has good marks.

So that’s what makes the labelling question really complicated. And even if a robust label could be established, there are other trade-offs linked to consumption volumes. Because if people think it’s a good buy, they may buy two or three instead of one, which makes the environmental impact worse.

The challenge, of course, is when the label delivers a bad grade because the manufacturer will be upset and will question the methodology. Can that be resolved?

Of course, no methodology is perfect, and there will always be errors or approximations. But if you’re really serious about clearing out the jungle of green consumer labels, you have to start somewhere.

I’m usually not the kind of guy who is always asking for the government to fix things. But if you really want to do something about consumer labels, you have to have the political will to opt for a mandatory system.

That’s what we have in the food sector. Whether you like it or not, some of the declarations are mandatory and need to be placed on the label. And then, of course, the method can be improved over time.

But with a voluntary label, I don’t see how you can achieve that.

Critics of the PEF methodology say it is too focused on CO2 footprint. With growing public concern about climate change, do you believe it’s justified to focus on CO2 as one of the main elements of an ecolabel?

I actually have to defend the PEF methodology here because, by definition, it does not look only at CO2. Many initiatives right now focus on decarbonisation and on CO2 only, but the PEF, from the very beginning, was broad and looked at 15 or 16 different impact categories.

It’s true that PEF methodologies also come up with a weighting of what is the most relevant impact. And global warming is often the most dominant in that category, which can be criticised. Because it’s a very subjective decision whether you prefer being killed by climate change, by some toxic substances or by something else.

So, in that sense, I don’t think it’s really fair to criticise the PEF for being overly focused on CO2 emissions. Because the PEF actually looks at other impact categories, whereas on the overall political agenda, people tend to focus on CO2 only.

To conclude: if you could spot the main differences in PEF assessments between food and non-food products, what would it be? And how would that translate in the PEF methodology?

Technically, agriculture comes with specific challenges because the agricultural production process is relatively heterogeneous. If, for simplicity, you calculate with average data the environmental footprint of something controversial like palm oil, for example, so that things are comparable, you kind of set things into stone for the entire sector.

But that may not correspond to the reality. In reality, palm oil can be the most sustainable or the least sustainable option depending on how it is produced. And if you set default values into a PEF methodology, you end up punishing the really good ones and rewarding the bad ones. This heterogeneity is, I think, a particular challenge for agricultural production systems.

There are also implications on the administrative and political side of things. Food labels, for instance, are usually the responsibility of the agriculture ministry, whereas all the other products are usually dealt with by the environment ministry.

And for non-agricultural products?

For those, it’s often related to the use phase. For an ICT product, for instance, a lot depends on how you assume it is used and disposed of. From the life cycle perspective, the result will be driven by the assumptions you make in the usage scenario.

And that comes back to what I said at the beginning: if you have a clear goal, then you can make the assumptions that fit your objective. But if you want to keep it open, then it can be challenging.

Anything else you would like to highlight about the European Commission’s upcoming initiative on green claims and sustainable products?

Generally speaking – and that’s often the case in policy – good intentions are not enough. Even though I can subscribe to many of the intentions behind this PEF process, the way it was done was sometimes quite inefficient and departed from state-of-the-art practice.

There are also pseudo-solutions. For example, the European Commission imposed a lot of bureaucracy to ensure data quality in the contributions from the PEF pilots’ participants. But this approach does not guarantee data quality, and sometimes more resources went into documentation, whereas it could have been spent on improving the quality of the data.

So, if I understand correctly, do you feel that the consultations held by the Commission to develop its PEF methodologies were not efficient or not as open as it could have been?

Formally, the consultation was open to everyone. But there were so many different consultation steps that it was difficult for many stakeholders outside the process actually to contribute. In the very first consultation of the method, we took a couple of days in the group and provided a set of constructive comments.

But, as often in these consultations, we did not perceive a real uptake or impact. And three years later, the Commission officials corrected some of the things that we had pointed out back then, saying they took this from the pilot process. We said: ‘Hey, we told you three years ago!’. And the answer was: ‘Yes, but we needed the pilot process to come to that conclusion’.

In the end, we wasted three years of time testing a proper method. And many stakeholders lost interest in the process unless they were from the industries directly involved and had a direct interest in contributing to the pilot. To comment on all the documents consulted required to read more than a thousand pages, and if you’re not being paid for it, you’re simply not going to do that.

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