by John Henry
John Henry is CFA’s representative on the Standards Australia mirror committee EV-003 Environmental labelling, and an Australian delegate to the meetings of the ISO Environmental Labelling subcommittee, replacing Deni Greene in both roles.
The European Commission has recently included a system for product environmental foot-printing within its package of measures “Building the Single Market for Green Products”. However, the consumer body that inputs into the European Standards system, the ANEC: The European consumer voice in standardisation has recently come out against this move.
That seems a bit strange. Why would European consumers be opposed to an environmental initiative? Well, it’s not as simple as it seems.
Environmental foot-printing involves a supplier declaring how much of a given resource or a given pollutant is associated with the production and use of a product or the delivery of a service. It’s not something that is common in Australia. A local example of carbon foot-printing is with airline travel where your booking receipt will state how much greenhouse gas (GHG) per passenger will be generated by your flight, expressed as tonnes of CO2 equivalent. This is often associated with an opportunity to off-set the GHG emissions by paying an additional fee.
In that case, there is no attempt to claim a difference in emissions between airlines, because there isn’t much difference anyway. The marketing angle is that the airline offers the off-sets for purchase, while its competitor may not.
Water foot-printing is another mode, whereby a consumer can see how many tonnes of water went into producing, say, a pair of leather shoes; and then compare that to a pair of shoes made from synthetic materials. The contrast is quite stark when you think of how much water went into growing the grain to feed the cattle, then the water the steer drank over its lifetime, plus the water used in the leather tanning process. Given the scarcity of fresh water on the planet, a conscientious consumer seeing that type of footprint comparison might never buy another pair of leather shoes!
Of course, the water footprint doesn’t tell the whole environmental story. It doesn’t consider the non-renewable nature of synthetics and the air pollution associated with producing the plastic in the synthetic shoes, not to mention the risks associated with oil spills when extracting the raw materials for the plastic (crude oil), or the fact that after disposal, the synthetic shoes won’t degrade in landfill the way leather would.
The point that ANEC makes is that the goal of environmental labelling, as expressed in the European Commission initiative, is to harness market forces to drive environmental improvements in the way products are designed and made, and in the way services are delivered. However, simply providing consumers with raw environmental data doesn’t necessarily help them to make better-informed choices, especially if the information only relates to one environmental indicator. By buying non-leather shoes, consumers might well ensure that there is no need to build a new dam, but what about the new petrochemical plant needed to supply all that plastic?
ANEC prefers “seal of approval” type environmental labelling schemes, like the EU Eco label (European flower scheme), or Good Environmental Choice Australia (GECA). In that case, an expert panel compares all the environmental aspects of products that perform a certain function; and then sets criteria for awarding the seal-of-approval, based on overall environmental superiority. Of course, such schemes are themselves open to criticism because these expert panels have to be somewhat subjective, for example in where they set the criteria for air pollution and water usage. And they don’t always get the balance right. Foot-printing is meant to avoid that subjectivity, because it’s just a number with no subjective judgement as to whether that represents good or bad performance.
Caught in the middle of these debates is International Organisation for Standardisation (ISO) and its Committee TC 207 Environmental Management. One of the TC 207 subcommittees is chaired by Australia and deals with environmental labelling. While there has been considerable work done in other parts of TC 207 on standards for how to compile an inventory of carbon emitted, or water used, to go into foot-printing, the Environmental Labelling subcommittee has been more circumspect about whether or not these footprints really constitute an environmental label or declaration in the sense that these terms are normally understood. In other words, a tool to assist in making informed purchasing decisions. The following text was recently published by the Environmental Labelling subcommittee in one of its standards:
A product “carbon footprint” is a way of reporting the environmental impact category of global warming or climate change that is being assessed during a life cycle assessment. It does not indicate the overall environmental performance of a product during its life cycle.
And according to another of the subcommittee’s standards, an environmental label or declaration must, at a minimum, use “life-cycle thinking” to avoid burden shifting. It hasn’t escaped the notice of ANEC that foot-printing fails the threshold test.
So, if the footprint doesn’t help you choose the best product for the environment, why bother compiling all that data? Sure, a company might want to use the footprint as an internal decision-making tool, rather than as an environmental declaration. But if it’s only used internally, the methodology doesn’t really need to be internationally standardised. Quite a conundrum.
All in all, it looks like the foot-printing debate has some way to run when Committee TC 207 meets in Gaborone, Botswana in late June, this year.
In my opinion, environmental foot-printing has a place in providing consumer information in a few specialised applications, such as in the airline example I quoted. It may make you think twice about travelling to a meeting when there are other communications options available. But I agree with ANEC that foot-printing hasn’t yet developed into a user-friendly tool to help consumers differentiate between competing products in the marketplace.
Perhaps, that will come with more development of the science and the use of internationally agreed product category rules. If not, the risk is that “environmental footprints” will just be remembered as the marketing buzz-word of the twenty-teens, just as “sustainable” was the buzz-word of the noughties and “eco-friendly” caught the imagination in the nineteen-nineties. These were admirable concepts that ultimately became devalued because every second product was able to claim the attribute, even if there was no appreciable effort by the manufacturer to deliver better environmental outcomes.
At least the rise of foot-printing shows that people are still thinking about product stewardship and are looking for new purchaser-driven mechanisms to stimulate environmental improvement. It will fall to ISO to set some rules that ensure this is what really happens.
If you are interested in finding out more about becoming a CFA Standards Representative please contact the Standards Coordinator standards@consumeraction.org.au