Environmental & LCA Claims
A key motivation for clients to conduct a life cycle assessment is to increase their knowledge and understanding of the environmental impact of their products. Completing an LCA also provides clients with insight that can then be communicated with stakeholders. Often, when we are approached about LCA, clients want to know exactly what they can claim, and with whom they can communicate these claims following its completion. The answer to this is not straightforward as it depends on the type of LCA that has been conducted, the scope of the study, and the LCA’s 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 an environmental aspect of a product, a component or packaging”. These claims can refer to any stage of the product life cycle, including how they are manufactured, packaged, transported, used or consumed, and disposed of. Claims can be disclosed by means of symbols, logos, or plain statements within communication materials such as news articles, a digital media post, or on a website.
ISO has classified three types of environmental claims:
- 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 that meet a set of requirements that have been set by a governmental body or a private organisation. These environmental claims can be seen on different products in the form of a logo to show criteria compliance. Examples of these type of claims are the EU Ecolabel, FSC, and Energy star label.
- Type II environmental claims (ISO 14021:2016 Environmental labels and declarations — Self-declared environmental claims): voluntary claims made by manufacturers and businesses, thus “self-declared”. The aim of this type of claim is to stimulate the demand and supply of products and services that cause less strain on the environment by communicating verifiable and accurate environmental product information. These types of claims do not require 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 environmental claims (ISO 14025:2006 Environmental labels and declarations — Type III environmental declarations — Principles and procedures): 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. In particular, it focuses on misleading advertising that could potentially harm consumers’ economic interests or distort their economic behaviour. The directive is applicable to business-to-consumer practices and 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 that indicate that a product might be environmentally beneficial such as “environmentally friendly” must be avoided. The same holds for sustainability claims, for example indicating that one product is “more sustainable than X”. The complexity of the term sustainable gives room for interpretation and cannot be encompassed under such a claim.
Given the ambiguity of such terms and the claims based on them, they are likely to be considered 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 calculation do not support these types of claims and cannot be used to substantiate them.
[1] Delmas, M. A., & Burbano, V. C. (2011). The Drivers of Greenwashing. California Management Review, 54(1), 64–87.
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What types of claims can I make with an LCA?
The results of an LCA, whether a screening or an in-depth LCA, is 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 to legal proceedings against the institution making them.
Claims with an LCA Screening Study
As mentioned on our life cycle assessment page, the results of a screening LCA will allow you to identify opportunities to reduce your environmental impact within the value chain of a product. Additionally, the results of the LCA screening can be used for internal communication and for sharing environmental information with business partners (B2B). Read more about this in our case study of a screening study Ecomatters performed.
To understand what this means, it is important to know what is considered internal communication and what is 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, or oral presentation. For B2B communication, this may include information shared during a business meeting, direct communications, etc.
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 Product A is X kg CO2eq/ kg of product, while for Product B the carbon footprint is Y CO2eq./kg of product”. In business meetings, this information can be used to make sure that the context of the study is made clear to the audience.
For environmental claims that are meant to be disclosed on the company’s website, its product packaging, and with consumers, an in-depth LCA is a more suitable approach than a screening LCA. 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, type II environmental claims do not require the completion of an LCA but rather the consideration of 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 ISO 14021:2016. However, for this specific purpose, the LCA screening should have some level of detail and robustness meaning “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 in the scope of the LCA screening from the beginning.
Our webpage ISO 14021 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
The results of an in-depth LCA allow an organisation to externally communicate its environmental impact in business-to-business or business-to-consumer communications.
The results of such an LCA are suitable to be disclosed publicly on the company’s website, its product packaging, and with consumers. In addition, LCA studies may include 3rd party review and verification, adding more credibility to the study and its validity, and therefore making it less likely to be questioned by external parties.
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 who 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, performed by Ecomatters.
In-depth LCA studies can also be used for type II self-declared environmental claims (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 (ISO 14025:2006).
Comparative Assertion Claims
Making public comparative assertions, and claiming that an organisation’s product is environmentally better than a competitor’s requires a comparative LCA.
Comparative LCAs have additional requirements that 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 has a precise structure, will be highly scrutinised, and must be robust. As a result of this, its completion requires more resources and a review panel is needed. A comparative LCA is a detailed process that aims to avoid potential bias and justifies all decisions that support one product’s superiority over the other.
An example of an environmental claim based on a comparative LCA is “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 needed to conduct it.
For instance, if a self-declared environmental claim is desired, then an LCA screening may be sufficient depending on the availability and accuracy of the company data needed. If you would like a comparative analysis, 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.
Regardless of which type of LCA you choose, the first step is to set the goal and scope of the LCA study and to discuss the reasons behind why you want 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.