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Environmental & LCA Claims

Introduction

Often, clients are interested in making an assessment either a life cycle assessment, either to understand and become knowledgeable about the environmental impact of their product. A common follow-up question that we are often asked is on the basis of the LCA done, what is then allowed to claim and communicate and to whom it is allowed. The answer very much depends on the type of LCA that has been conducted, and on the scope of the study and its intended application.

What is an Environmental Claim?

According to ISO 14021:2016 “an environmental claim is defined as a statement, symbol or graphic that indicates and environmental aspect of a product, a component or packaging”. These claims may refer to any stage of the life cycle stage of a product, such as how they are manufactured, packaged, transported, used or consumed and disposed. Claims can be disclosed by means of symbols, logos, or plain statements in communication materials such as a website, a news article a digital media post, etc.

ISO has classified environmental claims in three types:

  • Type I environmental claims (ISO 14024:2018 Environmental labels and declarations — Type I environmental labelling — Principles and procedures): claims which give their environmental label to products which meet a set of requirements either set by a governmental body or a private organisation. These types of environmental claims can be seen in different types of products in the forms of logos to show criteria compliance. Examples such as the EU Ecolabel, FSC and Energy star labels belong to these claims.
  • Type II (ISO 14021:2016 Environmental labels and declarations — Self-declared environmental claims) environmental claims: voluntary claims made by manufacturers and businesses, thus “self-declared”. Its aim is to stimulate the demand and supply of products and services causing less strain on the environment by communicating verifiable and accurate environmental product aspects information that is not misleading. These types of claims do not mandate to make the performance of an LCA study but require the consideration of relevant life cycle stages of a product to identify the impact along the value chain.
  • Type III (ISO 14025:2006 Environmental labels and declarations — Type III environmental declarations — Principles and procedures) environmental claims: these claims present environmental information on the life cycle of a product and are based on ISO 14040/ISO14044 LCA standards. These claims require an in-depth LCA, with 3rd party verification and certification. Environmental Product Declarations (EPD) belong to these types of environmental claims.

Greenwashing or Ambiguous Terms

The Unfair Commercial Practices Directive 2005/29/EC is the principal legislative European body regulating unfair business practices in EU law. Particularly, focusing on misleading advertising that could potentially harm consumers’ economic interests or distort their economic behavior. The directive is applicable to business-to-consumer practices and it encompasses environmental claims. Two main categories are distinguished, claims which are deceiving either objectively (i.e. presenting fake information) or subjectively (i.e. information is truthful but the way of presenting may misguide the consumer).

Under any type of environmental claim (type I, type II, and type III), claims which indicate that a product might be environmentally beneficial such as claims like “environmentally friendly” shall be avoided. The same holds for sustainability claims for example indicating that one product is “more sustainable than X”, the complexity of the sustainability term gives room to interpretation and cannot be encompassed under such a claim.

Given the ambiguity of such terms and claims based on them, they are likely to be interpreted as greenwashing – “the act of misleading consumers regarding the environmental practices of a company (firm-level greenwashing) or the environmental benefits of a product or service (product-level greenwashing)”[1]. Therefore, the results of an LCA or carbon footprint calculations do not support such type of claims and thus cannot be used to sustain them.

[1] Delmas, M. A., & Burbano, V. C. (2011). The Drivers of Greenwashing. California Management Review, 54(1), 64–87.

What types of claims can I make with an LCA?

The results of an LCA, whether it is a screening or an in depth LCA, will be the environmental impact of the product or system under study.

It is important to point out that there is no explicit and written ISO or LCA standard about what a company can do with the results of an LCA from a legal perspective as this is out of the scope of the standards. However, general communication legislation applies, and as such vague or dishonest environmental claims can be subjected legal proceedings against the institution making them.

Claims with an LCA Screening Study

As mentioned in another of our webpages, the results of a screening LCA will allow for the identification of opportunities for environmental impact reduction within the value chain of a product. Additionally, the LCA screening results can be used for internal communication and for sharing environmental information with business partners (B2B).

A relevant point is what is considered as internal communication and B2B communication. In principle, it is understood that internal communication includes but is not limited to communication within the company in the form of a presentation, leaflet document, oral presentation etc. For the B2B communication, this may include information shared during a business meeting, direct communications, etc.

For example, let’s consider an LCA screening of two products from the same company, Product A and Product B, in which Product A has a higher carbon footprint than product B. An internal document could include statements such as “According to the LCA screening results, the carbon footprint of the Product A is X kg CO2eq/ kg of product while for Product B the carbon footprint is Y CO2eq./kg”. In business meetings, this information can be used making sure that the context of the study is made clear to the audience.

For environmental claims that are meant to do be disclosed in the company’s website, its product packaging, and in general to consumers, an LCA screening is not a suitable approach. This is particularly relevant if comparative assertions among products from different companies, such as Product A belonging to Company A and Product B from Company B, wish to be disclosed to the public.

What about Environmental Claims Type II (ISO 14021:2016)?

As mentioned in the previous section, environmental claims type II do not mandate to perform an LCA but rather to considerate relevant life cycle stages of a product to identify the impact along the value chain. Therefore, the LCA screening results (depending on the goal and scope) can be used for a self-declared environmental declaration whenever they are compliant with the ISO 14021: 2016. However, for this specific purpose the LCA screening should have some level of detail and robustness and thus some “LCA back of the paper calculations” will not be enough. Therefore, if a company is interested in this type of environmental declaration, it is better to include this into the scope of the LCA screening since the beginning.

Our webpage Environmental claims type II describes in detail what the requirements are in order to make an environmental claim type II compliant with ISO 14021.

Claims with an In-depth LCA Study

As mentioned in another of our webpages, the results of an in-depth LCA allow an organization to externally communicate their environmental impact in business-to-business or business-to-consumer communications.

The results of such LCA are suitable to be disclosed publicly on the company’s website, its product packaging, and in general to consumers. In addition, LCA studies may include 3rd party review and verification, adding more credibility to the study and its validity, and being less likely to be questioned by external parties.

Therefore, for external communication meant for website display, packaging display, public leaflets, and EPDs among others, it is advisable to use the results of an in-depth LCA. An example of this is done by Teijin Aramid which communicates on their website and in their HSE report the carbon footprint of their Twaron yarn based on a 3rd party verified in-depth LCA, which Ecomatters performed for them.

In depth-LCA studies can certainly be used for self-declared environmental claims type II (ISO 14021:2016). However, they are most likely to be used for other, stronger, types of communication claims such as environmental product declarations type III.

Comparative Assertion Claims

Making public comparative assertions, and claiming that an organization’s product is environmentally better than a competitor one requires a comparative LCA.

Comparative LCAs for comparative assertions to be publicly disclosed, have additional requirements to guarantee the full comparability of products and must include a critical review by an external review panel. A comparative LCA is more challenging, time-consuming, and resource-intensive than a regular LCA. It will be very structured, more scrutinized, and very robust, and therefore requires more resources to perform in addition to a review panel. It is a detailed process to avoid potential bias and to justify all decisions made that support the superiority of one product over the other.

An example of an environmental claim based on a comparative LCA would be something like “For X market, Product X with the characteristics XXX, and manufactured in XXX performs better than the alternative product of the same capacity and characteristics in the considered environmental categories if the assumptions taken on XXX are representative of the market situation”.

So where to start?

The type of claim you want to make will determine the type of LCA and the corresponding budget to be conducted.

For instance: If a self-declared environmental claim is what you want, then an LCA screening may be sufficient for the purpose, depending on the availability and accurateness of company data needed for the LCA. On the other hand, if you want a comparative analysis or want an Environmental Product Declaration or an environmental assessment to communicate externally through all your communication channels, an in-depth full LCA study with detailed data collection and validated assumptions is more suitable.

In any case, the first step is to set alongside your consultant the goal and scope of the LCA study and to discuss the reasons that are driving you to perform the study.

Ecomatters Support

Ecomatters has a long track record of supporting various companies in various sectors in developing LCAs. We can advise and guide you through the process of determining which LCA claim would be most relevant for your situation.

Contact us

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