Washington, DC 20460
             ^•^,-"-r \c-^ :%>:/'••&:&';-J*~*:;~- 'K'r^fefeftte^ ^%<-^S;^-?
             La be Is Wo rl 
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     STATUS REPORT ON THE USE OF ENVIRONMENTAL LABELS WORLDWIDE
                                    September 8, 1993
                                       prepared for:

                                    Julie Winters Lynch
                                Pollution Prevention Division
                           Office of Pollution Prevention and Toxics
                            U.S. Environmental Protection Agency
                                          (7409)
                                     401 M Street, SW
                                  Washington, DC 20460
                                       prepared by:

                                     Abt Associates Inc.
                                      55 Wheeler Street
                                   Cambridge, MA 02138
                                     Contract No. 68-DO-0020
*<

Ol

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EXECUTIVE SUMMARY
                              TABLE OF CONTENTS           ,

                                                                    	. .  . .  i •
1.     THE STATUS OF ENVIRONMENTAL MARKETING IN THE 'UNITED STATES ........  i .
     .1.1   Environmental Marketing Terms ....... ........ ...... ...... -••'.'•'"'•...
      1.2   Consumer Confusion  . . ... ...... ......... • :  ••• • • -, > .•••••••••••••
      1.3   Marketers' Difficulties .......  ........ • • • .  ........... • • •'•• •.•••••  4
      1.4   Reversing' Growing Skepticism T :\ ......  .....  .....  ' ' ' '  ........  ' ' '

                                                                               -8
References for Chapter 1 ...... .,...........••, .............. ............

2. •   DOMESTIC AND INTERN ATTONAL ENVIRONMENTAL LABELING INITIATTVES;, ... 9
      2.1   Introduction . . . -... . ..... ....... ....... ...... ....... ......... •  9 .
      2,2   Seals-of-Approval  . . , .  .-.' ..... • • -• -..- •  • • • • ••••'•••- ....... • ,.,...'.. ... .  ,' • •  |_
           2.2.1  Overview  . . . . .  ... ......... . : .  . . ... ... ....... .....  • •  • • •  |^
           2.2.2  Common Processes . . .  . .....  • • • ....... .:......,......-  •,•  • • -15
           2.2.3  Retailer cnviroratiental labels ......  ........ ...... ........ ....  20
           2.2.4  Summary  ........ ..... . .... .....  .............. ........   |
      2.3   Single Attribute Certification Programs   ...  .'..'. ..'• . . . • ; • • • •  • • •  • -, •  .....  ^J
•''  -  •   *   2.3.1  Environmental Choice Australia  ........ ......... ........ ......  21
         ..  2.3.2  SCS EnvironmentalClainis  Certification ..,............•••••••••  22
      2.4   Report Cards . .......... . • • .........,•• ..... ...... ..... •  .....
',            2.4.1  SCS Environmental Report  Card  ...... . ........... ............  i~>
            2.4.2 Council on Economic Priorities - Shopping For A Better World ' .  ........  24
     ' 2.5   Information Disclosure Labels :  ..............•••••••'•••-•' ........ 24
      2.6'   Hazard/warning labeling  . . . ........... • ........ ........ ........  J
      2.7   Books  . . ..... . .  : . ..... .............. ...... • • ...... • ......
                    '    •      '..'•..          •               . ' .       '27
 References for Chapter 2 ......... . ..... ... .  - ........••••• ..... • • •  • ......

 3.     ...._.,...,,:.... ..... ....,.:...;....................  ...-29
     '  3.1   Effectiveness as Defined by Market Activity ..... .... .......  .......... 29
            3.1.1  Effectiveness  As Defined By Market Activity . ..... ............'...- 30
            3.1.2  Extrapolating Effectiveness From Other Labeling Studies ..... ......... 31
            3.1.3  Summary of Effectiveness  Discussion  ..... .-....' ........ ........ 32
       3.2   Hannonization Issues .......... . ..... • ..... ...... . . ..,...<.,...
  References for Chapter 3

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                     'APPENDLX TABLE OF CONTENTS

AlTIiNDIX: ENVIRONMENTAL LABELING PROGRAM SUMMARIES	39
     OERMANY-S BLUE ANGEL . . 'iV. . ."".'	."...'	44
     CANADA'S ENVIRONMENTAL CHOICE" PROGRAM: THE ECOLOGOM	  50
     JAPAN'S ECOMARK	". ......'-	56
     THE NORDIC COUNCIL'S WHITE SWAN	:	64
     GREEN SEAL ,"	: .	72
     SWEDEN'S GOOD ENVIRONMENTAL CHOICE	78
     ENVIRONMENTAL CHOICE NEW ZEALAND	82
     INDIA'S ECOMARK PROGRAM  ...... '.	 86
     KOREA'S ECO^-MARK SYSTEM  ../.....	 .".	90
     SINGAPORE'S GREEN LABELLING SCHEME	'....'	94
     EUROPEAN COMMUNITY :".' . .  '. . ... . '.['. . . .	.98
     STICIITING MILIEUKEUn OF THE NETHERLANDS   ..'..-	 .	 104
     FRANCE'S NF-|NVlRONNEjMENT	 108
     FLIPPER SEAL OF APPROVAL  . . .". '.,. . . ... .'..".'.	'.'	 114
     SCS FOREST CONSERVATION PROGRAM	 118
     SVAL-MART ."I	,.,'..:...,;.'......'...'.../..	• • 122
     VfHOLE EARTH ACCESS ".!... .... .. ^..	• •".	 126
     scs'ENVIRONMENTAL CLAIMS CERTIFICATION	,. 128
     ENVIRONMENTAL CHOICE AUSTRALIA	 132
     EPA ENERGY STAR COMPUTERS PROGRAM	 136
     COUNCIL FOR ECONOMIC PRIORITIES' SHOPPING FOR A BETTER WORLD	 140
     SCS ENVIRON^IENTAL REPORT CARD  . ". .... .".' . . . . . .:...'	 144
     PESTICIDE LABELING UNDER THE FEDERAL INSECTICIDE, FUNGICIDE, AND
          RODENTICIDE ACT   .  .	152
     PRODUCT LABELING UNDER THE TOXIC SUBSTANCES CONTROL  ACT (TSCA)  . 160
     CALIFORNIA PROPOSITION 65  	'. ...."! '.'.'...'.".'	 164
     VLRMONT HOUSEHOLD HAZARDOUS PRODUCT SHELF LABELING PROGRAM  . 168
     EPA'S OZONE DEPLETING SUBSTANCE (ODS) WARNING LABEL	 172
     THE  ENERGY  GUIDE:  HOUSEHOLD APPLIANCE  ENERGY  EFFICIENCY
          LABELING	;.....	:	 176
     FUEL ECONOMY INFORMATION PROGRAM	 180
     NONTOXIC, NATURAL & EARTHWISE	• • : I84
     THE GREEN CONSUMER and THE GREEN CONSUMER SUPERMARKET GUIDE . . 188
     OTHER ENVIRONMENTAL CERTIFICATION PROGRAMS	 192

 SELECT BIBLIOGRAPHY ON ENVTRONNIENTAL LABELING	 206

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 EXECUTIVE SUMMARY

       The past several years have seen a marked increase irfthe public'.s'awareness of and
 concern for a range of environmental  issues both in the United States and abroad.  One way in
 which ihe public, as consumers/seeks to lessen the environmental impacts of daily activities _is
 by purchasing and using products perceived to.be less environmentally  harmful.  Marketers, in
 turn, have responded to consumer demand by labeling particular products and packaging with
 environmental attributes (e.g., "package made from 35%.post-consumer material"), advertising
 these environmental attributes, introducing new products, and redesigning existing products and
 packaging.   "The  U.S.  marketplace  also  faces  the  introduction  of  several  third-party
 environmental certification programs as well as continued development of such programs in most
 of our. major trading  partners.1  Government and .private parties alike  have acknowledged that
 this trend  offers -an  opportunity to not  only  decrease  the  environmental impacts, of  the
 consumption patterns of;the American public, but also to increase consumer  education  and
 sustain interest in environmental issues.  This report provides extensive background research on
' the range of third-party environmental certification initiatives, both domestic and foreign.  ,

        In  1991, several petitioners requested .1)  that the. Federal Trade  Commission (FTC)
 establish uniform national guidelines  for environmental marketing terms, and 2) that efforts be
 made to ensure uniformity across all  federal agencies that might have jurisdiction or interest in
 this area. .To address federal-uniformity, staff from the U.S. Environmental Protection Agency
 (EPA), the  White House Office  of Consumer Affairs (OCA), and the FTC met as part of the
 Interagency Task Force on Environmental Marketing Claims. In July 1992, the FTC responded
 to  petitions from  industry and  testimony from interested parties, including  state and local
 governments and environmental groups, by formulating (in consultation with the task force) and
 issuing voluntary guidelines for  the use of environmental marketing claims.  Prior to the FTC
 guidelines ..individual state and local governments had enacted their own sometimes conflicting
 laws and regulations that define and restrict different environmental marketing terms.  Because
 of this patchwork of state regulation and consumer protection enforcement, many corporations
 found it too risky to make what many considered to  be, legitimate .environmental marketing
 claims. At present, no research has been published to determine what effects the  FTC guidelines
 have in the marketplace.and ultimately on environmental quality.

        Beyond the use of environmental marketing claims, an increasingly common marketplace
 approach to pursuing environmental policy goals  is third-party environmental certification
 programs (ECP),  where an independent group evaluates products within a category according
     1  For the purposes of this paper, "environmental labeling" will refer to the broader practice of labeling products
  based on environmental considerations, including hazard/warning (negative) labels, certified marketing claims appearing
  on a product or shelf label, and neutral information disclosure, labels. "Environmental Certification Programs (ECPs)
  will refer to third party, positive, voluntary programs.                                  .

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(0 tlK-ir (relative)burden  on the environment.2  Such programs are  active in more than 21
countries', of which some are major trading partners and competitors (e.g., Canada,  Germany,
Japan)   Several ECPs are now active or will  soon  become  active in the U.S.  The state of
California is also considering a  limited program.  These programs  provide  a  market-based
incentive for producers to develop new and less environmentally harmful products and processes.
In the context  of an increasingly global marketplace,  U.S.  manufacturers may need to meet the
award criteria of foreign ECPs  in order to compete effectively  overseas; thus,  foreign ECPs
could be "exported" to the U.S. market.
 ' ''        •     ••'jf!  •        ' :    ' ,  '~   '  •"''••'   •  • , •'  ,.••••'  -..•'.'":"' i
       For  the purposes  of this study,  fundamental elements have  been identified that are
common to  all types of third party product labeling, and  five types of environmental labeling
programs have been identified and categorized accordingly.   First, all  labeling programs are
conducted by  groups independent from marketers, and are considered 'third party' as opposed
to 'first party' environmental  claims made by marketers themselves.  Second, participation in
these programs can be voluntary or mandatory.  Third, labeling programs can be positive,
neutral, or negative; that is, they can promote  positive attributes of products, they can require
disclosure of information that  is inherently neither good nor bad, or they can require (negative)
warnings about the hazards of products.

       The table below illustrates the five types of environmental  labeling programs identified'
by this classification system,  and the properties they have.   Books  about  the  environmental
 impacts  of consumer goods, although  not programs  per se, are  included in  the report because
 they compile  and present some of the  same information as environmental labeling programs.
Program
Seal-of-Approval
Single Attribute
Certification
Report Card
Information Disclosure
Hazard Warnings
Books
Positive
X
X



X
Neutral


X
• X


Negative




X
X
Voluntary
X
X
X


—
Mandatory



X
X

        Seal-of-approval programs identify products or services as being less ^ harmful to the
 environment than similar  products or services  with  the same  function.  Single  attribute
 certification programs typically indicate that an independent third party has validated a particular
    1 The FTC has acknowledged that Its guidelines do not preclude or prohibit the operation of an ECP. The guidelines
 do apply to ECPs inasmuch as the programs make claims for products.
                                             11

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envrnetal claim  made  by the manufacturer.   Report cards, offer consumers neutral
information about a product'and/or a company's environmental performance in multiple impact
categories ('e.g., energy consumption,  water pollution),  In this way, consumers can weigh for
themselves^ what they think the most important environmental impacts are.  These  three types,
of programs, by virtue of their voluntary nature, have been grouped together as environmental
certification programs (ECPs).

       Information disclosure labels, like report cards,  are neutral, disclosing facts about a
product that would not otherwise be disclosed by the manufacturer.  Unlike report cards, _ they
are required by law.  Hazard/warning labels, or negative labels  (similar to health advisory
labels found on cigarette packaging) are mandatory warnings concerning the product's adverse
environmental or health impacts.  Books about the environmental impacts of consumer products
tend  to advocate for or against specific  products or categories, and 'so are either positive or
negative for each product rated.

       In its 1992 appropriations package for the U.S. Environmental Protection Agency (EPA),
Congress stated that "confusion in ecolabeling has negative implications for consumer protection,
environmental improvement, and trade with other nations,which have already established their
own  standards in this area." To address potential problems, Congress directed the Administrator
 "to, develop a comprehensive, uniform, and national environmental labeling strategy  that'is
 consistent with international standards."         -             ,   -

        Unlike ECPs in the U.S., ECPs are viewed by many foreign'governments as  one of
 several policy tools available that can be used to achieve environmental quality goals, where they
 supplement traditional .regulatory controls and fiscal incentives.' Studies have shown that ECPs
 may significantly influence consumers' purchasing decisions, allowing governments to  further
 their environmental agendas. This report addresses two of the major policy issues surrounding
 the  development of new  environmental certification programs,  as well  as  the  operation of
 existing ECPs:  the measurement of program  effectiveness and international harmonization.

        As part of its background research on the numerous initiatives  worldwide, the Agency.
  is interested in determining the potential benefits'and limitations of consumer-oriented -initiatives
  such as ECPs.  Consequently, it is important to make the distinction between the popularity ot
  ECPs  and the evidence  of their effectiveness as agents of change  in  consumer behavior,
  ultimately improving environmental quality. The effectiveness of an ECP can be examined in
  terms  of its impacts  on consumer awareness,  consumer acceptance,  consumer  behavior,
  manufacturer behavior, and environmental benefit. Each of these  elements is dependent on the
  others  and provides important insight into the driving forces behind the success or failure of an
  environmental label.  Unfortunately, there is very little in-depth mformation in these areas.
  While  extrapolations  can  sometimes be made from  studies of other types of  labels,  the
  conclusions  drawn from  them are  tenuous at  best;  additional research  regarding  ECP
  effectiveness is needed.                             ,

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   ;,!    Another  issue cunfronting  the  various  ECPs around  tlie  world  is  harmoni/ation.
DifTcrenccs in product category definition and stringency of standards could potentially cause
COiWimcr confusion, and  act  as' trade barriers.    International organizations  such as  the
International Chamber of Commerce, the rntemational Standards Organization, and the United
Nations Environment Programme, have made recommendations on  ways to standardize ECPs
arid increase  the exchange  of information and primary research  being  conducted by various
programs.  If successful, the European  Community's (EC)  program will address this problem
within Europe by narmonizing environmental labeling throughout the 12 EC states.

       Tills report examines public policy issues related to environmental labeling and the status
of ECPs worldwide.  Chapter 1 gives an overview of the status of environmental marketing in
the U.S.  Chapter 2 and the Appendix summarize  existing ECPs in  the U.S.  and abroad.
Chapter  3 addresses  existing research  relevant to projecting the effectiveness of U.S.-based
environmental labeling  initiatives.   The Appendix provides details for each of  the,labeling
programs included in the report as well as a select bibliography covering a number of labeling
initiatives as  well as  life cycle analysis  issues.
                                           IV

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1.
      THE STATUS OF E.WIRON-MENTAL MARKETLNG LN THE UNITED STATES

 '  .   News coverage of environmental concerns has been increasing steadily since the latter
half of the 1980s.   Global  is-sues such as climate change and  stratospheric ozone depletion,
national news stories such as the Exxon Valdez oil spill, and local issues such as drinking water
contamination  and  municipal  solid waste management have  increased public awareness  and
concern about environmental matters facing the. United States.  National events such as Earth
Day  have emphasized choices  that individuals can  make to,  decrease their  impact on the
environment- a large number, of consumers have responded by  purchasing and using products
they perceive to be less environmentally harmful.  Several surveys  indicate that a majority of
Americans consider themselves to be environmentalists and would prefer tc.buy products with
a lessened environmental impact when quality and cost are comparable. (Abt, 1990, Gutfeld,
.1991)        .'.'             ,            ;   .         •  '  - '

       Since 1989  the U.S. marketplace has seen a dramatic rise in the number of new products
 making environmental claims (e.g., ""ozone friendly," "recyclable").  Despite the fact that
 virtually all products  have  some adverse environmental impact, consumers are often confused
 about the meaning  of specific environmental marketing claims, and often m,stake product claims
 as generically "good for the environment.'"  Also, some claims made by marketers have been
 blatantly unclear and  misleading. Consequently, marketers have been^subject to.litigation and
 reoulation'by  a growing  number of local, state,   regional and  federal agencies, and are
 Screa ingly wary of miking.new-claims.  (EPA, 1993)  The FTC's Guides far the  Use of
 Environmental Marketing Claims, released on July 28, 1992, are expected tp alleviate much of-
 the confusion for  consumers and marketers alike.  The guidelines are also intended to provide
 (nationally) consistent meanings and interpretations in the marketplace, thereby reducing legal
 risks for marketers  wishing to make environmental claims.  However, no studies of the
 guidelines'  effectiveness have yet been published.           ,

        An  additional development in  the  marketplace  is  the rise  of  third-party  positive
 environmental certification programs  (ECPs), which are  now  actively reviewing  products and
 issuing awards in the United  States.   These  programs,  known  in  countries abroad as
 "ecolabeling"  programs,  strive to make credible,   unbiased, and  independent: judgments in
 cS^ng a clL or product.   They  are expected to provide  the consumers with information
 and/or assessments that are often not apparent or not .available to the consumer, that can help
 the consumer make purchasing decisions based on the environmental  impacts of product^
 Because private U.S. programs are  not associated  in any way with the federal or any  state
  government, their activities are not now linked directly to U.S. •environmental policy;goals  In
  contrast, ECPs in other countries are either controlled by the government or by an independent
  body with government oversight.  They are often used as "soft policy tools,' harnessing market
  forces to help reach certain  national environmental goals.
                                           "  1

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       For the  jniqjoses of this study, a classification system was prepared  defining various
lyrv* of environmental marketing/as il!ust ruled in Figure 1-1.  First party activity, performed
b> marketers on their own  behalf,  includes claims, cause-related marketing, and other acti\ Hies
designed to promote the environmental  attributes of cither specific products or the company
generally.  A major part of third party activity, and what this report is primarily concerned with,
is environmental labeling programs.  Participation in environmental labeling programs can be
voluntary or"mandatory for marketers.  Mandatory programs, usually under state or federal law,
require either hazard/warning labels (such as pesticide warning labels) or information disclosure
labels (such as  EPA's Fuel Economy Information label).

       Voluntary programs, categorized as environmental certification programs (ECPs) in this
report, are associated  with positive or  neutral labels; that is, they act either as a positive selling
.rioint in  encouraging  the sale of the product, or as a  neutral disclosure of the environmental
impacts of the product. The three approaches to environmental certification "identified are seal-,
pf-approval, report card and single attribute certification.  Environmental labeling programs are
discussed in greater detail in Chapter  2.      •

1.1    Environmental Marketing Terms

       Marketers have responded to consumer demand for "green" products by advertising the
environmental attributes of their products, introducing new products, and/or redesigning existing
products and packaging to enhance their environmental characteristics.  Generally, in the absence
of ECP programs, such as those in Germany  and Canada, marketers in the United States have
used environmental  marketing  terms  on  product  packaging  and  in  advertising.   The
environmental  marketing  claims used to describe products and packaging range from vague,
general terms  such as earth-friendly  or natural, to more specific claims such as contains no
chlorofluorocarbons or made with x percent postconsumer recycled materials.

       The rapid proliferation of poorly-defined or ambiguous environmental terms over the last
 Several years has led to consumer confusion and skepticism. FTC guidelines were formulated
 in response to  increasing  amounts of  legal activity related to environmental claims.  While not
 legally enforceable themselves, FTC  guidelines "provide guidance to marketers in conforming
 with legal requirements." (FTC,  1992)  The  guides do not define terms, but give examples of
 more and less  acceptable  ways to present the following claims: general environmental benefit
 claims;  degradable,  biodegradable and photodegradable;  compostable;  recyclable; recycled
 content; source reduction; refdlable;  and ozone safe and ozone friendly.

        The success of market-driven environmental initiatives depends in large part on consumer
 awareness and knowledge of environmental issues,   to  use the  market  effectively  as an
 environmental policy tool, there must be some assurance  that environmental claims made on
 products are truthful  and result in real environmental quality improvements. Furthermore, some
 advocates of environmental marketing initiatives point out that such activity should be linked to
 national environmental policy goals  as  well as to  consumer concerns. When consumers are
  misled by trivial or false advertising, environmental policy goals  driven by those concerns are

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,unJcnritned.  Tjje effectiveness of all environmental marketing activities as policy tools can be
UHUred through several means: industry self-regulation, governmental intervention by regulation'
Of voluntary initiatives, or third party certification by public or private groups.

1.2    Consumer Confusion

      •Consumer confusion over environmental marketing terms  is  exacerbated by several
factors  characteristic of environmental attributes.    Advertising claims that cover  easily-
discernible attributes of a product, such as soft or tasty, are readily evaluated by a consumer who

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       State-level activities include a number of initiatives.  In addition to the enactment of state
laws specifically regulating the use of environmental marketing activities over the past few years,
state attorneys general and others have initiated a, greater number of truth-in-advertising  legal
actions  against allegedly  misleading  advertising   related  to   products'  and  companies'
environmental attributes 'and; performance.  A task force of state'attorneys general has jointly
issued, two status  reports, the Green  Report I and //,  including their recommendations for
federal, state, local, and industry ac.tions.  At the same time, different advocacy groups'have
organized local, state, and national publicity campaigns to increase scrutiny of marketers' claims.

       Federal activity has  been-concentrated in the FTC,  the  U.S. EPA, the Office, of
Consumer Affairs  (OCA), and Congress.  The FTC held hearings to gather information and to
assist in responding to petitioners' requests for guidance.  The. hearings,  in combination with
other joint research by the Commission, undertaken with EPA and OCA, resulted (in July 1992)
in the development of guidelines for the use of environmental  marketing claims,  with specific
guidance  for eight categories of claims.:  The U.S.  EPA also held  hearings  and  proposed
definitions for recycling  terms.  Congress proposed but did not act on the Environmental
Marketing Claims Act of 1.991.  Provisions in this bill would specifically authorize the  U.S.
EPA and  FTC to jointly regulate environmental terms, and would also define and set  standards
for a number of the same  terms FTC covered in its guidelines, with these definitions having the
force of law.  The bill was  included in the Resource  Conservation and Recovery Act (RCRA)
reauthorization bill in 1992,  but this too was not enacted.

       Before issuing guidelines, the Federal  Trade Commission chose  to review .deceptive
environmental advertising on a case-by-case basis, with the expectation that settlements against
misleading marketing would serve as examples to marketers.  The large number of legal actions
resulted in a great demand from industry groups, as well as consumer and environmental groups,
for guidance to help avoid  costly and time-consuming b'tigation. Between October  1990 and
June 1992, at least 48 separate actions were taken against marketers for misleading or deceitful
environmental advertising.3' These', actions include those brought by the  Task Force of State
Attorneys General and individual attorneys general (10 cases),  the New York City Department
of Consumer Affairs (15  cases), and the FTC itself (11 cases).  (EPA, 1993)   '
                                                                       •         i .
       The most  prominent private  activity has been the voluntary  self-regulation of the
advertising industry by  the National Advertising Division  (NAD) of the Council  of  Better
Business  Bureaus.  The  NAD has heard more than 3,000 complaints about unfair advertising
practices  since 1972 (EPA,  1992).  Between October 1991  and June 1992, it .heard 12  cases
pertaining to environmental advertising  claims.  Although its'  oversight  relies  on  voluntary
changes  by the parties involved, it has been willing to refer cases where  agreement  could not
be reached to the  Federal Trade Commission. (EPA, 1993)
    3 The highest number of actions were taken against claims of biodegradability in plastics, followed by actions against
 environmentally safe/friendly, nontoxic/nonpolluting, ozone friendly, recycled, recyclable, and degradable. All but six
 cases ended in agreements by the manufacturer to modify or discontinue the claim in question; three we're found to be
 substantiated, one was dropped, and two were pending as of Spring 1993.

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       .Ml t. f this reguUtary and enforcement activity has succeeded in decreasing mislein':ng
       wg activity, but it has also caused some marketers to stop using terms that are generally
i0n«!;!ered to  be acceptable.  For  many corporations,  the risk of legal  action and adverse
pub'-: iiy outweighs the expected benefit from  increased consumer  response.  As  might be
exfK.-v.lcd, some marketers are dropping terms over which other corporations  have been sued.
Others  are  wary  of making  new claims  when  they  have  been  challenged on previous
environmental marketing claims. (EPA, 1992b) Procter and Gamble, Kraft, and several other
major consumer product  companies  announced  that  they  will  no  longer  make  certain
environmental claims due  to the lack of consensus as to  which terms can be used legitimately
for their products. (Lawrence,  1992)  As the National Food Processors Association (NFPA)
argued in its petition to the FTC, marketers need  "safe harbors" in which they  can make real
environmental claims without fear of being sued. (NFPA, 1991)

1.4    Reversing Growing Skepticism

       The confusion and growing marketplace complexity surrounding environmental marketing
terms has begun  to  create indifference and distrust  among consumers  toward advertised
.environmental  attributes,  and  a reluctance among companies  to advertise  environmental
attributes. Some marketers are now adding complicated language to their product labels to avoid
]he  liabilities  associated with increasing  numbers  of  federal, state,  and local  actions and
regulations. (Lawrence, 1992)
              1 ii    ,          .  .  •,  *•f: i   •  :  ,  •.'.,'  ~  ,   " •''•','
       There is some evidence that consumer skepticism, marketer doubts, and fear of litigation
have resulted  in declining environmental  marketing  activity. A recent U.S. EPA study found
that the rate of new  environmental marketing claims declined in the first half of 1992, after a
steady upward trend. (EPA, 1993)  A spokesperson for Church"'& Dwight, maker of Arm &
Hammer products, explained that "The risks of getting involved in green advertising until [the
labeling controversy is] sorted out are too high." (Reitman, 1992)
              1 v|i i     , •;	,  '„, •  '.  ,  •. •• •  ' : •' 'i   ' •;. , • :  ..;     :,;,,;<
       If the  current mistrust of environmental marketing  by  both consumers  and marketers
Continues, there is a danger that environmental marketing could lose its potential to be  a viable
environmental policy option in the U.S. Consumer skepticism may be reversed if the credibility
and standardization of environmental marketing information can be ensured. In general, two
approaches  have been suggested by some stakeholders for the U.S. marketplace:

 •      promoting the existing guidelines  for individual environmental marketing claims linked
        with responsible monitoring and enforcement; and/or

 *      developing guidelines for (and supporting) domestic ECPs.

        In the time leading up to the release of FTC guidelines,  there was strong consensus
 among  marketers and state and  consumer groups that some type of federal  guidance  on
 environmental marketing terms was needed. Because of the  immediacy of the problem, most

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 advocated ih;iflVdv.-hil guidance, should take .the form of voluntary guidelines ratter than enforced
 bUndards; guidelines are more flexible and can be implemented more quickly.

        Although it is too early to discern their effect!venevs, there'has been widespread-.industry
 support for the FTC  guidelines.  At the  same time, industry has a number of reservations, about
 third-party ECPs.  A prominent concern is that companies are not willing to let an1 independent
 private  party dictate standards for industry.to  follow.  Some of  the criticisms  are that:  1)
 companies will lose some control over their pwn production processes and marketing decisions;
 2) an independent certification company may not be stable and credible, and the reputation of
' companies associated with it may be tarnished; 3) competing private labels will compromise the
 effectiveness of each; and 4) lack of a label or seal will be equated with being denied an  award.

        On the other hand, there have been some calls  for federal action to 'level the playing-
 field' for ECPs.  Proposals for additional research and investigation include: public review, of
 ECPs; development of uniform  program  operating principles; guidance on product evaluation
 methodologies; assistance in developing data sources; and harmonization with programs in. other
 countries.   •                      . .                ,  •

         Support for an effective  ECP  has  come from consumer and environmental.groups.   As
 one consumer advocate, indicated, "the ultimate solution for all of our green consumer dilemmas
 would be to have .one commonly accepted seal-of-approval on packages, certifying that a product
 had met a set of standards for environmental responsibility.-' (Makower et al., 1991)

         Another cause  for interest, in building a coherent U.S. ECP is the fact that other nations,
 including prominent American  trading partners,  have active ecolabeling  programs.   Among
 countries  involved -in environmental marketing,  the United States is virtually alone in its
 emphasis on defining  individual terms rather than developing a national program.  Germany,
 Canada,  Japan,  the  European  Community and  the  Nordic Council, among  others,  have
  government-run  or government-associated ECPs' in place.   With  heightened interest in trade -
  issues due to the General  Agreement on Tariffs and Trade (GATT) and North American Free
" Trade  Agreement (NAFTA)  negotiations, ECPs are being examined both as potential barriers
  to trade and as an  option to avoid barriers to  trade.4   An ECP,  for example,  can effectively
  export its award criteria to foreign manufacturers wishing to enter its market.
     4 An EGP could impede trade where its award criteria relate ^manufacturing processes or waste management
  (which are not attributes of the product itself). Companies exporting to a foreign market with such award criteria might
  therefore need to alter-th'eir domestic production or waste management processes before they can receive an award and
  be able to compete. - One condition for certification by the European Community ECP is compliance with relevant
  European Community environmental laws. Unless greater harmonization occurs, this requirement could present a bamer
  to the entry of foreign products into the EC market.                                     .

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                               References for Chapter 1

 Abt Associates Inc., 1990.  Consumer Purchasing Behavior ami the Environment: Results of an
.Event-Based Siudy, November.

 Cude, Brenda, University of Illinois,  1991.  Comments prepared for July 1991 FTC public
 hearings on environmental marketing and advertising claims, July 11.

 Environmental'Research Associates, 1990. Environmental Report, Fall.

 Federal Trade Commission,' 1992. Guides for the Use of Environmental Marketing Claims, July
 28.   .       "!:       "'   '   """   , '  ;;   ""'    '  "'  '  ,

 Fisher, Christy, 1992. "Green Seal Product Will be  Revealed," Advertising Age, October 26,
 P-'18-                           ,   ,  '       '      ',   ''.""'
 Gulfeld, Rose^ 1991. "Shades of Green: Eight of Ten Americans are Environmentalists, at Least
 They Say So," Wall Street  Journal, August 2 p. i.

 Lawrence, Jennifer, 1992.  "Marketers Drop 'Recycled,'" Advertising Age, March 9, pp. 1, 48.

 Makower, Joel; Elkington, John; and Hailes, Julia, 1991.  The Green Consumer Supermarket
 Guide, New York: Penguin Books.

 National Food Processors Association, 1991.  Petition  for Industry Guides for Environmental
 Claims Under Section 5 of the Federal Trade Commission Act, presented to the FTC February
. 14.'        ' "l!!     ,       '"'    : '  "  ' '.',';'

 Reitman, Valerie, 1992.  "'Green' Product Sales Seem to Be Wilting,"  Wall Street Journal, May
 18, p. Bl.

 U.S.  Environmental Protection Agency, 1992.  Environmental Labeling Workshop Summary-
 Draft, October 30.

 U,S.  Environmental Protection Agency, 1993.  Evaluation of'Environmental Marketing Terms
 in the U.S., prepared by Abt Associates Inc., February, EPA 741-R-92-003.

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2.     DOMESTIC AXD INTERNATIONAL ENVIRONMENTAL LABELING
       INITIATIVES                   ,                         '

2.1    Introduction                      ......

       While product labeling has been used in marketing since "Underwriters Laboratories began
operation in 1894, the newest developments in labeling have been in the area of environmental
certification programs (ECPs).  In recent  years,  particularly since 1989, the number of and
interest in ECPs have grown.  Currently,  at least 13 programs are in operation in upwards of
"21 countries (see Appendix).

       Third party consumer product labeling  can serve three functions in the marketplace: 1)
as an independent evaluation and endorsement of a  product, 2)  as a consumer protection tool,,
and 3) as a method of achieving specific  policy goals.  As an  independent endorsement of a
product, a program can offer companies a selling point-that is more credible than claims made
•oil their own behalf.  'For consumer protection, labeling can provide product information that
is not readily apparent or easily discerned,  or is not a positive selling point and thus would not
necessarily  be supplied  by the marketer.  As a policy  instrument, labeling can  influence
marketplace behavior, guiding consumers  and producers to act toward public policy goals.  A
variety of approaches to product labeling have been developed,  prompted by health and safety
concerns, concerns about hidden operational costs and, more recently, about the environmental
 impacts  of products.

       All third party product labels assume that better information will enable consumers to
•make more informed purchasing "decisions. ECPs operate on the assumption that information
 on the environmental impacts of products tends  to be  more complicated than other  kinds of
 product information, and that, in order to make purchasing decisions based on environmental
 considerations,  consumers are in need of a-clearly  reported, expert analysis of those impacts.
 While other types of environmental labels focus on  specific single issues, such as gasoline use,
 energy efficiency, and toxic substances, ECPs often, try to convey information about multiple
 environmental impacts of products.        ,

        Another key difference is  that  participation in environmental certification programs is
 voluntary, and certification by an ECP is intended to be a positive selling point, encouraging the
 sales of products bearing the certification.   In contrast, hazard/warning labels typically highlight
 a negative product attribute.  As such, they either promote the safe use of labeled products or
 discourage sales of labeled products, thereby  promoting the use of safer  alternatives.

        In addition to guiding consumer behavior,  an ECP can  provide  a clear incentive for
 manufacturers to change to less harmful materials and production processes.  In theory, if the
 market  shares of products certified by ECPs increase,  manufacturers of products that did not
 receive or seek  the label will be  induced  to change or  risk losing market share.  Those
 manufacturers of products without a  label may  seek to qualify for the ECP's label, thereby
 reducing their adverse environmental impacts. Alternatively, they may try to differentiate their

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-products en  another basis, such as lower price, greater couvcmehce,  or higher quahty.  To
 ena-untoe- continual technological and environmental improvements, several LCPs continuously
 raise the standards for an award so that only a select minority of products on the market meet
 the programs' requirements.

        For the purposes of'this study, certain fundamental elements have been identified that are
 common to all types of product labeling.  As illustrated by Figure  1-1 environmental marketing
 •performed by marketers themselves can be considered 'first party'  activ.ty, while that perfon led
 or required  by  an outside program can be called 'third party.'  All environmental  labeling
 oroarams  are considered in  this report to be  third party programs, as shown in Figure 2-1.
 Participation in these programs can be mandatory or voluntary; most, if not all  mandatory
 labeling programs are required  by state or federal  law.  Labeling programs can be posiUve,
 neutral! or negative;  that is,  they can promote positive attributes of products, they can reqmre
"disclosure of information that is inherently neither good nor bad,  or they can require (negative)
 warnings about the hazards of products.
                                         Figure 2.1:
                                        Third  Party
                                 Environmental Labeling
                                         Programs
                         Mandatory
                Hazard or
                Warning
               (e.g. Pesticides,
                03, Prop. 65)
Information
Disclosure
(e.g EPA fuel
economy label)
                      Voluntary
Environmental
 Certification
  Programs
                                           Report
                                            Card
                       Seal of
                      Approval
               Single
              Attribute
             Certification
         Labeling programs have these elements in different combinations, causing some overlaps
   in the categorization illustrated in Figure 2-1.  For example, the Environmental Report Card
   program run by Scientific Certification Systems (SCS)  is a voluntary information disclosure
                                             10

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program  \Uiile  EPA's  Fuel Economy ..^formation  Program  is  a mandatory information
disclosure program.  Table"2-1 illustrates how the different categories of environmental labeling
programs identified in this report share the basic elements.          •                  .„

                            •          'TABLE 2-1
Program
Seal-of-Approval
Singly Attribute
Certification
Report Card
Information Disclosure
Hazard Warnings
Books5
Positive
X
X



X
Neutral
>

X
X'


Negative




\
.'•X
Voluntary
" X
X
X


—
Mandatory



x • •
X
—
       ' Seal-of-approval programs  identify products or services as being less harmful to the
 environment than similar  products or services  with  the  same function.  Single  attribute
 certification programs typically indicate that an independent third party has validated a particular
 environmental  claim made by  the manufacturer.  Report cards offer consumers  neutral
 information about a product and/or  a company's environmental performance in multiple impact
 categories (e.g., energy consumption,  water pollution). In this way, consumers can  weigh _for
 themselves  what they think the most important environmental impacts  are.   Information
 disclosure labels, like report cards, are neutral, disclosing  facts about a product that  would not
 otherwise be disclosed by the manufacturer.  .Unlike  report cards, they .are required by  law.
 Hazard/warning labels, or negative labels (similar to  health advisory labels found on cigarette
 packaging)  are mandatory warnings concerning the product's adverse  environmental or health
 impacts  Books about the environmental impacts of consumer products tend to advocate for or
 against specific products or categories, and so are either positive or negative for each product
 rated.                                                _

         Most  of the  existing  or  planned  government-supported  programs,  including  those
  instituted by Germany, Canada, the Nordic Council, the European Community, France, Japan,
  the Netherlands, New Zealand, and  Austria, are seal-of-approval programs.   Green beal,  a
  private seal-of-approval program  in  the U.S., also falls  into this category.   In general  the
  programs judge products  based on several award criteria  using some abbreviated form of life
      5  Although books on the environmental impacts of consumer goods compile and present some of the same
   information as do ECPs, they are not programs per se; thus, they are not included in Figure 2-1 but are covered in tins
   chapter. .Programs require either the voluntary or mandatory participation of marketers.

     ••••''         ' '                      11                                •

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€)cle assessment'.''If the product passes,  the marketer is'allowed to use the program's logo in
promotion and "advertising for the product.  Other labeling .programs,  such as one operated by
SCS. Scientific Certification Systems, certify particular single attributes.  SCS also offers the
Environmental'Report Card, a broader information disclosure label showing pollution releases
and resource use for products and companies.  Information disclosure labels mandated by the
U.S. government include the Energy Guide program for electrical appliances and EPA's Fuel
Economy Information Program for cars and trucks.  The U.S. EPA,  California, and Vermont
have mandatory negative labeling programs for hazardous and toxic materials. Books rating the
environmental attributes of products include Tfie Green Consumer and Nontoxic, Natural and
Earthwise.

       This report focuses mostly  on seal-df-approval, single attribute certification, and report
'card  type  labeling programs, categorized together as  environmental certification programs
(ECPs).  Most of the ECPs in this report share three main objectives:  1) to prevent misleading
environmental  advertising  by'  providing  an 'objective, expert assessment  of the  relative
environmental impacts of products;  2) to raise the awareness of consumers and to encourage
them to take environmental, considerations into  account  in their  purchasing decisions  by
providing them with accurate information on the environmental consequences of products; and
3) to preside manufacturers with market-based incentives to develop new products and processes
with fewer environmental impacts.
 2.2    Seals-of-Approval

 2.2.1  Overview

       Seal-of-approval  programs  award  use  of a  logo to  products  judged to  be less
 environmentally harmful than comparable products, based on a specified set of award criteria.
 First,  product categories are defined based on similar use or  other relevant characteristics.
 Award criteria are then developed for a product category.  All products within  a product
 category are compared against the same set of award criteria. How these product categories and
 evaluation award  criteria are set defines  the most important differences among the seal-of-
 approval programs currently in existence.  It is a complex task requiring  the consideration of
 many factors, including environmental policy goals, consumer awareness of environmental
 issues, and economic effects on industry.
                                           12

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      Table 2-2-summarizes eleven seal-of-approval ECPs currently in operation.

                .   -.'-   .           ,  TABLE 2-2
Countries/Regions
in which a program is active
Germany
Canada
Japan •
Nordic Council (Norway, Sweden,
Finland, Iceland)
European Community (EC nations)
US
France
International
International
India
Singapore . •
Korea • . '
Program
Blue Angel , . ' ' •
Environmental Choice
EcoMark . • '
White Swan.

Ecolabel •
Green Seal-
NF-Environnement
Flipper Seal-of- Approval
SCS Forest Conservation Program
Ecomark -
Green Label
Ecomark
Type
gov't
gov't
gov't
gov't'

gov't •
private
^gov't ,
private
private
gov't
gov't
gov't .
First award
given
1979^
1989 .'
'1989
1991

1993 (expected)
1993
. 1993 (expected)
1991
1993
1991
1992
1992
       Other countries planning programs include Austria, New Zealand, and the Netherlands.
Plans for EGP  schemes have been dropped in Ireland and the United Kingdom  in order to
participate in the European Community scheme.  During 1992, California EPA assembled a task
force to begin consideration of a positive ECP; the State of New Jersey has also studied the
issue.  These programs and others are described, in greater detail in the Appendix.

       In general, seal-of-approval programs tend to have similar administrative structures.  In
atypical program, the government's environmental agency is involved to some extent, ranging
from actually administering the program to simply providing advice or funding. The bulk of the
responsibility rests in a central decision-making  board composed of. environmental groups,
academics  and scientists,  business  and  trade representatives,  consumer groups,  and/or
government representatives.  Such board members usually serve for fixed terms (two to five
years).  Technical expertise is provided by the government, standards-setting organizations,
consultants, expert panels, and/or task forces established for specific product categories.

       Virtually all seal-of-approval programs follow the same overall certification process, with
some minor variations. .First, product categories are defined and  chosen.   With Japan's
EcoMark as a notable exception (see Section 2.2.2),  most of these ^programs then set  award
criteria using a form of life cycle study,  in which potentially significant environmental burdens
of a product are examined.  Award criteria for that product group are then set to reduce those
impacts considered to be the most important or relevant.  Once the award criteria have been
finalized and published, manufacturers are  invited to  submit products for testing  and then,  if
accepted, apply for a license to use the logo.
                                           13

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	  ,    -me United Nations Environmental Programme (UNEP) held a "Global Environmental
Labeling" seminar  in September 1991,  where experts  defined  the following  basic  features
         to seal-pf-approval ECPs:
              I1'!1'1     „    ' •   '„  ' •  '  ' '  i'1''1'     ' '•  " , •' • " ', •''  ' '  „ '•',,•,,
             determination of award criteria based on life-cycle review of a product category;

             voluntary participation of potential licensees;
              ':,:ii    !|"-w»',.  , •     "          •,,",,;',      „,      . •  •        '
             nfn by a not-for-profit organization, including governments, without commercial
             interests;                            ,                 •    ,             '
               (I      '   ,   •,': •  , '    "" -  ,      •     • ' . . •   .- ' ',-  '  .             '
             recommendations  for product  categories  and  environmental  award  criteria;
             ftptermined'b'y ari  independent, broadly-based board;

             a legally protected symbol or logo;

             open access to potential  licensees from all countries;
              endorsement from government;6
       •      award criteria levels established to encourage the development of products and
              services that are significantly less  damaging to the environment; and

       •      periodic review and, if necessary, update"of both environmental award criteria
              and categories, taking into account technological and marketplace developments
              (UNEP, 1991).                                                  .

       The International Chamber of Commerce (ICC) has proposed several requirements for
 ECPs from the perspective of the business community. In particular, they emphasize that there
 should"be no more than one label in each market to avoid consumer confusion, and that the key
 reasons for granting the environmental award should be printed on the product label itself.  ICC
 also suggested that there should be a certain amount of harmonization among national programs,
 and that business should have a voice in the ECP process. ,(ICC, 1991)
            "! IE   '           '    :'     .,!•••   . '  ; •: 	•' i       '          fj
       Seal-of-approval programs also need to consider the incorporation of national policy goals
 into  the program, appropriate  and reasonable  definition of product categories,  inclusion of
 industrial  and commercial  products and  services  in the  program, and the need  to put
 environmental award criteria into context, recognizing important product attribute tradeoffs (e.g.,
 reduced packaging vs. packaging needed for consumer safety, as with many food products).
    4 This point had majority, but not universal, consensus.

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2.2.2  Common Processes  '                    "                              •

       Virtually all  scal-of-approval, programs follow .the  same process,  with some minor
variations.   First, product  categories  are chosen and  some  form of. life  cycle review  is
performed.  The review determines which points in a product's life cycle, from manufacture to
disposal, contribute the greatest environmental burden. The programs vary widely in  the rigor
of their quantitative analysis. Based on this analysis, programs set criteria that products'must
meet in order to qualify for an award.  There is usually a public review of program operations.
After criteria are set, applications are received and awards are .made.

       Defining Product Categories

       How product  categories  are defined can vary greatly  between programs,  and reflect the
goals of the individual programs.  With varying language, most of. the programs-state that they-
intend to promote  the design, production,  marketing, and use of products that have a reduced
environmental  impact and  provide consumers with better  information on  the environmental
impact of products. Nevertheless, the programs have differing ideas as to what environmental
'benefits can be gained through an.ECP.  Given the  lack of consensus on product evaluation
methodologies, the way product categories are defined may be the most important distinguishing
feature between existing programs.  There are significant differences in the effects created by
a product .category that is  limited, for  example,  to compact fluorescent lightbulbs,  versus  a
product category for all. lightbulbs (whose energy efficiency:  would be just one of several award
criteria).'

       The procedure  for  selecting product  categories range frorri extensive  research  to
'determine the potential benefitsj)f a new product category, to the selection of a product category
based on  loose guiding principles.  One example is  a Blue Angel  product category  designed
specifically for low-noise mopeds. While noise may not appear to  be a moped's most serious
environmental  impact, the  standard suggests  that the reduction of  noise pollution  is a higher
priority in Germany  than in other countries. This is borne out by the fact that Blue. Angel has
no  fewer than seven, low-noise product  categories  in  its program,  including  one for
"Sound-proofed Glass Collection Bins for Noise^sensitive Areas." "Once a product category has
been chosen, label award criteria for that particular category can then be developed.

       The. European Community's attempts at product assessment have been the most ambitious
of any  program.   Product  categories are decided upon  by  the Commission  and assigned to a
"lead country" for evaluation and standards setting.  So far, 14 product category assessments
have been assigned to member states.  The  EC program is  currently  the most intensively
engaged, in original research to gather environmental  information on product categories, and at
least two  studies  have been completed.  While  this strategy may provide a very  thorough
analysis, possible  drawbacks include a long turnaround time and'high costs.    •

        In the middle range of the research spectrum is Canada's Environmental Choice Program.
Environmental Choice does not perform .original  research to determine the environmental


            ''-.'-'.•           .15                          ' •'

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        of  pitnjuas.   Guidelines  are  set  by "a  review of  currently available  life cycle
       luMi."  which  is presented  in technical  briefing  notes  written for the program  by
      .iiUS and reviewed by Environment Canada (Canada's environment ministry). These notes
arc literature reviews of research on the environmental impacts of a particular product category,
an assessment  of the industry and marketplace, suggestions for areas of possible environmental
improvement and recommendations for how to set standards for the products effectively. A new
consideration,  recc -tly added to the program by the Environment Minister, is an assessment of
the economic impact of the label on an industry. (Hilliard, 1992)

       At the opposite end of the spectrum from the European Community is Japan's EcoMark
program.   EcoMark  follows "guiding principles"  in its  selection  of product categories,  its
development of award criteria, and in the awarding of its  labels:

       •      Products incur a minimal environmental burden w'hen used.;

       *      Products improve the environment when used;7

       •      Products incur a minimal environmental burden when discarded after use;

       •      Products contribute to environmental preservation in other ways;

       •      Appropriate environmental pollution control measures are provided at  the stage
              of production;

       •      Energy or  resources can be conserved  with use of the product;

       •      Products comply  with laws,  standards, and regulations pertaining to quality  and
              safety; and

        •      Price is not extraordinarily higher than that of comparable products.

       The Promotion Committee, with advice from the expert Committee of Approval, "guided
 by the basic principles listed above, and aided by information provided by the applicant, decides
 whether to  approve the category."  Apparently there is no analysis or consultation with a group
 specifically assembled for that product category.  One drawback of this process is that it  runs
 the risk of awarding a product based on one attribute, when that product may have another
 environmental attribute that should not be promoted.  For example, a paper  product that is
 manufactured using a chlorine bleaching process (which generates dioxin-containing wastes)  may
 receive an award based on its post-consumer recycled content.  On the other hand, the program
    1 According to Mr. Hashizume of the Japan Environment Assoc., "improve the environment" means "the reduction
 of the pollution, e.g., a kitchen sink strainer which has fine mesh, can catch fine materials in the waste water from a
 kitchen and prevents water contamination of rivers and lakes. Most of household waste water [flows] directly to rivers
 and lakes in Japan."
                                            16

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 is able to move very quicklv. awarding over 1,800 products in 47 product categories in less than
 three years of operation. It is also the only ECP that is currently self-financing.  (Hashizume.
 1992a)     •                 ,'  "   *            '..-_•            '

       According to Shigeyuki Hashizume of the Japan Environment Association, in the past,
 "product categories were selected by satisfying one ... environmental requirement. _.., Now we
 are  studying to introduce the life cycle assessment method to-.product-categories  selection.
 '(Hashizume  1992b)  Some criticism of EcoMark implies that  its credibility has suffered from
 a lack of more stringent research method.  (Business and Tfie Environment, 1993) It may also
 be that the program has set award criteria for the simplest product categories (i.e.,  categories
 that can be set without much analysis) and that future product categories, will  require more
 research.                                                    .           -              .

        Finally, two programs, the Flipper Seal-of-Approval and the ,SCS  Forest Conservation
 Program are, in a sense, single issue seal-of-approval programs.  Flipper, run by the non-proiit
 environmental group Earthtrust,  certifies "dolphin friendly" tuna while SCS certifies sustainable
 timber and  forest management operations.   The Flipper program focuses exclusively  on.
 discouraging fishing  practices that maim and kill dolphins, and-encouraging tuna companies to
 engage in "dolphin-friendly" activities.  The program examines all facets  of a tuna  company s
 corporate  policy that  may affect' dolphins, including  fishing techniques of tuna suppliers,
 activities of subsidiaries and parent companies,  and involvement in dolphin  protection efforts.
 So far, Earthtrust has approved several major tuna companies, including  Starkist.  (Earthtrust,
  1992)  The SCS Forest Conservation' Program evaluates timber operations  based on the
 sustainability of timber resources, forest ecosystem maintenance and  socio-economic benefits^
 the surrounding community.  Eacb timber operation examined is awarded a score on  a 100 point
  scale; those scoring  more than  60 can claim to be "Weu%Managed" while those in the top 10 •
 percent can identify themselves as "State-of-the-Art." (SCS, 1993)

        Setting award criteria

        After the principal environmental impacts of products have been identified, award criteria
  (also called standards) are set to address these impacts. To date, seal-of-approval programs have
  been granted on a pass/fail basis, rather than,on a rating system. In general,  standards are set
  so that only a few products in a category (a frequently used goal  is 10 to ,20  percent of the
  market) can meet them.  The idea is to provide incentives for manufacturers making products
  in that category to  improve their products to meet the award criteria and receive the ECP s.
  award. Programs also allow for changing the award criteria.  When the percentage of products
' within a product category receiving labels- increases, standards can be raised to limit the number
  of awards.  In this way, a program can provide an incentive  for continuous improvement.

         In practice, standards are often set for just one award criterion, even though research has
  been carried out identifying multiple environmental impacts.  This  is done for a variety of
  reasons:  it is easier to implement, and set standards for one attribute, it focuses  the attention of
  manufacturers on specific environmental goals, it educates consumers on specific environmental
                                             17

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         of a product category, and  it can be less confusing to consumers.  This simplified
 approach has some drawbacks as well: most importantly, such a seal does not reflect the overall
 inirtict of a product accurately; consumers may interpret the award to be a general  seal-of-
 approval rather than an award for a specific attribute; it can limit-the incentive for manufacturers
 to  improve their production processes overall by targeting only one problem;  and  it can
 jeopardize the  credibility of a program if it is promoted or interpreted as a general  seal-of-
: approval.  The report card approach to labeling, discussed in Section 2.4,  addresses some of
 these problems.

'.       The European Community is trying a more  comprehensive approach. Its program first
 performs the most in-depth life cycle study of any  program and then sets award criteria.  The
 award process consists of two levels. The first'level is known as a "hurdle"  test, where certain
 award criteria are mandatory to qualify  for further consideration.  If  a product passes these
 hurdles, it then faces a variety of other award criteria.  It needs  to pass  a certain percentage of
 these secondary award criteria  to  qualify for a label.8  The standards for copier paper set by
 Denmark, for example, require that virgin pulp must come from sustainably managed  forests,
 and that manufacturing processes and contents must meet quality standards in all EC states.  If
 products meet these requirements, they are scored for the use of energy and natural resources,
 and for the amount of chemicals emitted to water and soil during manufacture (see Table 2-3).
 If a product does not exceed maximum allowable values for any category, and If it scores within
 the overall limit, it qualifies for a label.

       The main advantage of this approach is that it is a more comprehensive assessment of the
 environmental impacts of a product.  Also, it gives a company the flexibility to choose among
 different manufacturing processes and operating practices (with tradeoffs in emissions and energy
 consumption) arid still meet the program's standards.  One problem with this approach is that
 it  may be prohibitively  expensive.   In order to  set realistic standards for scoring, industry
 averages  must  be  determined.    This  may involve  collecting  detailed  information on
 manufacturing and chemical use  from a significant portion of the industry,  of which some
 members may not want to participate.  For example, in the evaluation of detergents conducted
 for the EC by Germany, the study was "hindered by...  limited support to the lead country with
 respect  to submitting necessary raw  materiais/product/production-related data."   (Poremski,
 1991)

        Public review of award criteria

        Public review of a program's award criteria and process is assumed to be important in
 maintaining the program's integrity  and its ability to address issues relevant  to those parties
 affected by its actions.  All  other things  being'equal, a program that is "transparent,"  or open
 to public scrutiny, will have greater credibility in the eyes of consumers and manufacturers than
 will a program with little public review.
    1  The UK National Advisory Group on Environmental Labeling also recommended this approach in a white paper
 written for the House of Commons.

               '•i   -.     ''  "   •'';"   •   :  •' is

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•- •• • Table 2-3 ' . - " "
Copier Paper Standards for the EC Program
Aspect of manufacture
Energy and natural resource use
Sulphur dioxide emissions •


Organic s to water (COD)
• - - , ' ' ; •

Chlorinated organics (AOX)


Emissions to soil

Emissions
Virgin fib^r
Recycled fiber :
less than ,0.2
0.2-0.5
0.5 - 1.5
1.5-2.5
less than 1
1-10
10-40
40-60
less than 0.1
0.1 - 1.0 - ..'.-.
1.0 - 2.0
2.0-3.0
no deposits
controlled
uncontrolled .
Points
6
2
0
1
2
, 4
0 -"
1
- . 2 .
' . . 4
-.'-' 0 '
1
2
4
0
1
4
       Almost all programs'attempt to be transparent to the public in their operations.  Canada's
Environmental Choice allows for a sixty-day public review period in the process of establishing
criteria for  a given product category.   During  this time, announcements  of the  proposed
standards  are sent to the press  and to an  "extensive  mailing list,"  and" are  published in
government  publications,  in  the   program's  newsletter,  and   in  major  newspapers.
Recommendations taken from this review are considered by the Environmental Choice board
before final rules are promulgated.

       In  the U.S., Green Seal seeks public participation using press releases and mailings of
proposed award information to interested parties.  Although it does not publish in government
publications, and its standards are not automatically published by any newspaper or magazine,
its guidelines'and activities tend to be fairly well covered, in the American trade press.

       Awarding labels                                  „

       Once award criteria  have been set, the  awarding  body accepts  applications from
manufacturers and awards labels to those, products meeting  the award criteria.  Information on
the products is usually provided by the manufacturers, or from third party testing organizations
                                           19

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  tthoie  tecs arc paid b> the manufacturer.   Programs can often request additional  testing  if
;l needed. Manufacturers whose products pass then pay a fee to license the label for a specified
•: lime, usually three years.  At the end of the licensing period,  the manufacturer can re-apply for
  the ECP's label, under current standards that may have been revised to reflect the state-of-the-art
  within  the product category.                                     •

  2.2.3   Retailer environmental labels

         Many retailers  in the U.S. and abroad have  started  their own programs to promote
  products with perceived environmental benefits. These efforts consist of shelf labels, m-store
  consumer education materials such as brochures and posters, and retailers' own 'house brands'
  that identify  and  promote products with  certain environmental attributes.   Retailers with
  environmental initiatives  in the U.S. have included grocery,  department and hardware stores,
  both mainstream national retailers such as Walmart and smalleralternative stores such as Whole
  Earth Access in California.  Loblaw's, a large  chain of grocery stores in Canada, has its own
  brand of "G-R-E-E-N" products, and Tesco Stores of England has a "Green Choice" product
  line. (House of Commons, 1991)  In addition,  a number .of stores have opened that specialize
  in products with environmental features,  such as the Body Shop or the Nature Company.9

         Walmart was one of the first large retailers to promote environmental claims through in-
  store  signage,starting in" 1989, but was  criticized by  several environmentalists for  having no
  means of independently  verifying manufacturers'  environmental claims.   Walmart has since
  stopped its program. (Fisher,  1991; Walmart, 1992)

         Whole Earth Access is a small chain of department stores in the San Francisco Bay area
  originally associated with the Whole Earth" Catalog, a long-time source of environmental  and
  socially conscious products. Whole Earth Access does some shelf labeling "to highlight products
	that are an alternative to mainstream  America." (Tong, 1992)  The labeling is determined  by
  each  merchandise buyer  based on manufacturer  claims, combined with  whatever additional
  information each buyer deems necessary to verify the claim.  Whole Earth stores have promoted
  certain products as being "environmentally friendly" for the  15  years of their existence.

         In general, retailer labeling programs are not very systematic or comprehensive. Because
  of this, it is difficult  to categorize them as  seal-of-approval, single attribute  certification, or
  report card types of ECPs^  Since existing retailer programs do not systematically set  award
  criteria or standards ahead of time, their intent is to draw attention to products, not necessarily
  to certify marketer claims or evaluate the environmental impacts of products.  In this regard,
  they  are  similar to the  final format  of a seal-of-approval type of labeling program,  though
      '  Since this paper is concerned primarily with third party ladling programs, retailers with environmental product
   lines such as Loblaw's and Tesco will not be discussed here, nor will specialty stores carrying environmentally-oriented
   products. Two retailers' environmental product labeling efforts are described in the Appendix: those of Walmart and
   Whole Earth Access.

                                              20

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'.vithout the standards setting, evaluation, and authority of a more comprehensive seal-of-approval
ECP.                 •'"..'

2.2.4  Summary         .                •                                 •

       A seal-of-approval program differs from those that certify manufacturers' claims because
it is based on a broader assessment of a product's life cycle.  In spite of this, a  seal-of-approval
program will often make awards based primarily on only one attribute, which it deems the most
important, the most practical, or the easiest to improve.  Germany's  Blue Angel often makes i
awards based on a single attribute that is considered to  be the most  important environmental
attribute of the product.

       A seal-of-approval is also different from a neutral information disclosure program, such
as the  Food and Drug Administration (FDA) nutrition label, because it makes value judgments
as to what  is good and bad  for the environment.  It is different from SCS"'s  Report  Card
approach, in that a seal-of-approval program selects what it defines as the most important
environmental impacts from among the many  impacts associated with  a product.  If such a seal
is controlled by a federal government, as is true for most foreign programs, it is used as a policy
instrument where the implicit value judgments are provided by the national environmental policy.
A major exception is the United States' Green Seal, a private non-profit program not associated
with, the U.S. government.                       ,-          '

       Overall, the variations among programs are the result of different philosophies, different
environmental policies, and different  expectations  of what  is feasible.  For the  most part,
countries  pursuing ECPs  have converged  on  the seal-of-approval label  model  as being
sufficiently comprehensive and, above all, practical. Environmentalists, among others, however,
have called  fora more complete analysis of products, taking into account the inherent trade-offs
in environmental impacts.  As the body of knowledge about life cycle assessment, increases, it
is more likely to become an integral part of seal-of-approval labeling programs.
 2.3   Single Attribute Certification Programs

       Single attribute  certification  programs certify that claims  made for products meet a
 specified definition.  Such programs define specific terms and accept applications from marketers
 for the,  use  of  those terms.  If the programs  verify that the product attributes meet their
 definitions, they award the use of a logo to the marketer.  The two single attribute programs
 currently operating  are Environmental Choice Australia and Scientific Certification Systems'
 Single Claim Certification, a private program in the U.S.

 2.3.1 Environmental Choice Australia

       The stated goals of Environmental Choice Australia are to ensure  that "environmental
 claims made about products and services are both meaningful and truthful"  and that "consumers

      '           ..'•'•'                  21              ;       '                      '

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'and the providers of products1 and serxices are educated and."informed on  the environmental
: Impacts of products and serv ices." To this end. Australia is initiating education and information
	programs and environmental legislation that encourage manufacturers to lessen environmental
 impacts in their design and production processes, as well as the environmental claim verification
 program.

        Environmental Choice Australia is administered and  funded  by the Australia and New
 Zealand Environment Conservation Council (ANZECC), and includes a scientific committee to
 define terms and verify claims, as well as a broad-based advisory committee to  consult on
 decisions.  The program  is expected to coordinate  closely  with Environmental  Choice New
 Zealand- (Doyle, 1992)
                                         '     *  •  •  . '   !	*      , , '               ,1
        Environmental Choice's  verification process gives  government  approval  to product
 environmental claims that can  be tested and quantified. If a product passes the required tests,
 its manufacturer may display "an agreed fonn of words" on the product.  The Environmental
 Choice program categorizes environmental claims as follows:

        •      .Claims that can be quantified;
        •      Claims dependent upW common understanding of terms used:
        •      Meaningless claims; and
        •      Misplaced or misleading claims.

        Manufacturers applying for verification are not allowed to  use claims that are meaningless
 or misleading"  Environmental Choice Australia states that  it will undertake random testing of
 products'and "services to ensure that providers of products  and  services remain in  compliance
 with  the program's requirements.  Fines up to 5100,000 (companies) and 520,000 (individuals)
 may  be levied on those parties who misuse the Environmental Choice Logo.

  2.3.2 SCS Environmental Claims Certification

         According  to  SCS,  Environmental  Claims  Certification is  designed  to  provide
  "independent assurance that specific environmental claims made  by manufacturers" are accurate
  and represent "significant environmental accomplishments." (SCS, 1992)  To date, more than
  500 individual products have been certified for claims in the  areas of recycled content, recycling
  rates, biodegradability, energy and water efficiency, volatile organic chemicals content, and
  sustainable forestry.

         'During  the certification process,  the manufacturer is expected to release to SCS all
  information'.relevant to its claim. SCS then performs on-site inspections as  well as a  detailed
  records audit to verify information.  SCS also consults independent databases to compare the
  manufacturer with the industry average.  Based on  this research, certification is then issued or
  denied.  After  a  product  has been certified, its  manufacturer may display an  "authorized
  certification emblem" accompanied by an exact description of the verified claim.
                                             22

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   2.4    Report Cards

          The report  card  approach to labeling involves categorizing and  quantifying various
   impacts that  a-product  has  on the environment.   Values for  each impact category  (e.g.,
   kilograms of carbon dioxide released during manufacturing) are listed on the label and displayed
   in  a  bar  graph.  At this time, only Scientific Certification Systems is using this method of
   labeling,  although the Council'on Economic Priorities has published a book ranking companies
   on environmental as well as various social criteria.  To date. Scientific Certification Systems has
   issued report  cards to nine products.   '

          Because report card labels provide the consumer with more information than standard
   .seal-of-approval labels,  the consumer has more specific information to consider when choosing
   a product.10   Whereas  a seal-of-approval  program  might label  two  products with similar
   recycled  content in the same way, a report card  may highlight rneasurable.differences in-other
   impact categories between the two products.  Consequently, the consumer does not have to base
   his or her decision completely on the  analysis and judgments of the seal-of-approval labeling
   program.  Another advantage of the report card is that it neither advocates nor condemns a
   product,  but  only provides information about the product.  To  some extent, this reduces the
   possibility of a consumer basing a purchase decision on a label awarded  because of one or two
   specific environmental  benefits of a given product,  which may cause consumers to  infer its
   superiority across all impact categories.
         >   „ "               •             -           '                   '"             --
          The major advantage of the report card approach is, that  it  provides manufacturers and
   consumers with a large  amount of information. Criticisms "6f the report card  fall into two basic
   categories: concern over the  difficulty of obtaining information, and the difficulty in displaying
,   information clearly and simply.

   2.4.1  SCS Environmental Report Card

          SCS's "Environmental Report Card" is an information disclosure labeling program based
   on a life cycle inventory  (LCI).  The life cycle  inventory'is  the first  step in the more
   comprehensive life cycle assessment (LCA) described in Chapter 3.  SCS Report Card evaluation
   is a multi-step process,  involving identifying and quantifying inputs and outputs for every stage
   of a  product's life cycle, site inspections, records audits,  emissions sampling and testing, and
   quarterly monitoring.   Under SCS's LCI,  characteristics  under the following categories are
 •  quantified for each stage of manufacturing, use, reuse, and disposal:.

          •      Resource Consumption     .-",.•.-
          •      Energy Use               .
          •      Air Emissions                                                .      , •  •
          •      Water Emissions           "
          •      Solid Waste Generation
      10  Seal-of-approval programs are selected for comparative purposes because 1) they are most similar in terms of
   underlying analysis, and 2) a private seal-of-approval program exists in the U.S.

                                              23                                   '

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 0:uc the LCI has been completed, the results are presented on an label or in public information
'isuuca'tls in a table of figures accompanied by a bar-graph (see^Appendix).  The  manufacturer .
"{UV'i for looting" fees but Joes, not pay any licensing or royalty  fees.

 2.4.2 Council on Economic Priorities - Shopping For A Better World

:       ,The Council on Economic Priorities  (CEP), a New York-based non-profit group:,  has
 produced  a book catted'Shopping'For A'Better  World, which  rates major manufacturers on a
 variety of social issues such as environmental  awareness, minority  advancement, charitable
 giving, and animal testing.  Although CEP's report card reduces complex environmental issues
 down to  a stipple ranking within a  single category  (e.g.,  a  corporation's  environmental
 performance is"graded as good, bad, or average), its wider scope may influence future product
 report cards designed to assess a manufacturer's performance  on issues beyond environmental
 impacts.


 2.5    Information Disclosure Labels

        Like report cards,  information disclosure labels are neutral, simply reporting facts  that
 can be used by consumers as one"piece of information in making a purchasing decision. Since
 the facts disclosed are not always positive selling  features, and may not otherwise be reported
 by marketers, information disclosure programs  are usually mandatory.

        Perhaps  the  best  known  information disclosure  label  is  the  Food  and Drug
 Administration's (FDA) nutrition label. Amended under the Nutrition Labeling  and Education
 Act of 1990  the new food label is required to  appear on all processed food sold in the U.S.,
 with voluntary labeling on all unprocessed fruits and vegetables. (FDA,  1992) The government
 has  required two other information disclosure  labels that can be considered environmental in
 focus  One is the automobile  Fuel Economy Information Program, which requires a label on
 all hew cars  and trucks sold.  Begun as  a voluntary program  in 1973 by the  Environmental
 Protection Agency, it soon became mandatory  for auto makers to report the mileage rating of
 new vehicles.  (Abt Associates, 1976)

        Another information disclosure label is the Energy Guide program, which requires a label
 disclosing the cost of energy consumption of certain household appliances.  Mandated by the
 Energy Policy and Conservation Act of 1976, the program is  run by the Department, -f Energy
 and The Federal Trade Commission.  The appliances covered  include refrigerators, freezers,
  water heaters, clothes washers, dishwashers, and  room aix conditioners. These appliances tend
  to have a wider range of energy efficiencies than other appliances; consumers are thus more in
  need of a disclosure label to help them make purchasing decisions.
                                            24

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 2.6   Hazard/warning labeling                          .       .

       Hazard/warning labels are mandatory  negative labels that appear on certain products
 containing harmful or hazardous ingredients.  Well known hazard/warning labels include the
 Surgeon General's warnings, on cigarettes  and the skull,and crossbones  label  on poisons.
 Warning labels are also being applied to products to point out environmental hazards presented
 by the products.  .Labeling programs  warning  of toxic ingredients  are currently  being
 implemented by  the States  of California and Vermont, as well as the U.S. Environmental
 Protection Agency.                                      •                        :"

       The State of California, by voter initiative, enacted1 the Safe Drinking Water and Toxic
 Enforcement Act in 1986.  The  Act, known as Proposition 65,  creates a  labeling program for
 products containing one or more of a list of chemicals  determined to be carcinogenic and/or
 teratogenic, and prohibits the discharge of these chemicals to drinking water supplies.  The'law
 also provides an unusual enforcement mechanism, offering a bounty to any individual or group
 able to prove a violation of the law.  In six years of operation,  more than 500 chemicals have
 been listed,.with  warnings appearing on a wide variety of consumer goods.

       The State of Vermont passed a state law in 1990 requiring all retailers stocking household
 products containing hazardous ingredients to so  identify the products with shelf labels.   The.
 program's  goal is to prompt consumers to avoid purchasing such products, thereby sending a
 signal  to  manufacturers to  produce less hazardous products.   The state  also:gives certain
 products deemed  less toxic or nontoxic an "exempt" label, so that retailers can offer officially-
 sanctioned alternatives to'the labeled products. After nine months of implementation, 58 percent
 of retail  stores in Vermont had  installed shelf labels.  Along with  the shelf label, there is a
 consumer education  program that creates  posters  and brochures and  is  planning a media
 campaign.  The state has a companion program for pesticides and commercial fertilizers.

       The U.S. EPA, under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA),
 requires warning  labels on pesticides. Under the Toxic Substances Control Act (TSCA), the
 Agency may require  warning labels  on  products  containing specific  hazardous  substances,
 although in the 17 years since TSCA became law,  only four product categories have been so
 regulated.  Under the  Clean Air Act Amendments of 1990, EPA recently began a  labeling
 requirement for  products made with or containing ozone depleting  substances  (such as
chlorofluorocarbons, or CFCs).

       Proponents of warning labels  claim  that  manufacturers would remove the offending
chemicals rather than suffer the market setbacks (adverse publicity and loss  of market share) that
a hazard/warning  label might cause. They argue that this approach provides a stronger incentive
to reformulate products (to avoid hazardous ingredients) than would a voluntary -environmental
certification program.   If true, the results/benefits of such a hazard/warning  labeling program
would be more certain, with more certain results.
                                          25

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2.7    Books

       The increase in public interest in environmental issues has been reflected by an increase
in the number of books published on various environmental topics.  Among the most papular
of these has been books on how to be an environmentally conscious consumer. Three of these,
TJie Green  Consumer (and a successor. The Green Consumer Supennarket Guide), Non-Toxic,
Natural and Eanhwise, and Shopping for a Better World offer guidance on and ratings  of the
environmental impacts of  specific  consumer  goods.   The  former  two  offer  considerable
background  information  on  manufacturing  techniques  and  packaging,  essays  on  the
environmental impacts of consumption,  and general advice.   The latter, discussed above in
Section 2.4, presents  a report card  grading products and their producers o.n eleven different
Environmental and social  standards.

       Although  these  books  do  rate  products,  they  are  considerably different  from
environmental certification programs.  Producers do not apply to the books for consideration,
nor of course  is  there any government requirement.  An obvious difference is that the books'
ratings «lo not appear  on  products or in advertisements.  Only Shopping for a Better World is
designed to be taken  to  supermarkets to guide consumer purchase decisions  at the point of
purchase.  It is unknown  how effective the books are at guiding point-of-purchase decisions of
consumers.  The authors often cite sales of the books as proof of their effectiveness; they are
undoubtedly effective  as educational materials.
                                           26

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                              References for Chapter 2      '  ,  .    .   •

Abt Associates 'inc., 1976.  Impact of the  FEA/EPA Fuel Economy Information Program.   ,
Prepared for the Federal Energy Administration by Vince Scardino, James Birch, and Cathy
Vitale. June.    ,       •                       .  .    .          -,-'..

Applied Decision Analysis, .Inc., 1992.  Memo to Eun-Sook Goidel, EPA, from Julie Langel,
Adam Borison,  Mike, Freimer, February 6.                   ,

Business and the Environment,  1993.   "Why green  marketing  must be part of a corporate
environmental management system," May 1993, p,3.

Doyle, Kevin, 1992. Personal communication with Abt Associates Inc., September.

• Eaithtnist, 1992. Flipper Seal-of-Ap.proval Information Kit.

Fisher, Christy, 1991. %"Tending Wal-Mart's Green Policy," Advertising Age,  January 29, p.
20.                                 ;.          "•.••".•'

 Food  and Drug Administration  (FDA), 1992.  "The New'Food Label,"  Nutrition  Today,
 Jan./Feb., p. 37-39.         '                                               .  .   :   /•

 Hashizume, Shigeyuki, Japan Environmental Association, 1992a.  Environmental Labeling in
 Japan: Tfie Eco Mark, January.

 Hashizume, Shigeyuki, Japan Environmental Association, 1992b. Personal communication with
 Abt Associates Inc., May 12.                                     '  •  •

 Hilliard, Joe,  Environmental Choice  Program,  1992.  Personal communication  with Abt
 Associates Inc., May 18.          '

 House of Commons, Environment Committee, 1991.  Eight Report, Eco-labelling, Volume I,
, September.                                                  .                     .

 International Chamber of Commerce, 1991.  Environmental Labelling Schemes (ELS), ICC
  position paper, Paris, June.                                                 •

  Poremski  H.J., P. Rudolph, K.  Lemme and E.  Six, Federal  Environmental Agency,  1991..
  Detergents in Western Europe:  Environmental Labelling, prepared for the Comrmssion  ot the
  European Communities,  General Directorate XI, Berlin, October.

  Scientific Certification Systems (SCS), 'l993.  "Fact sheet:  The SCS Forest Conservation
  Program."                                                              .
                                           27

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Scientific Certification Systems (SCS), 1992. Informational material.

Tong, Brenda, Whole Earth Access,  1992.  Personal Communication with Abt Associates,
September 25.

United Nations Environment Programme, Industry and Environment Office,  1991.   Global
Efi\irontneniaTLabeiling: 'invitational "Expert Seminar, Lesvos, Greece, 24-25 September 1991,
Working Group on Policies, Strategies and Instruments of the UNEP/IEO Cleaner Production
Programme.

Walmart staff member,  1992.  Personal Communication with Abt Associates, August 6.
                                          28

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3.     SELECTED   ISSUES   AFFECTING  'ENVIRONMENTAL  CERTIFICATION
       PROGRAMS (ECPs)

       In this age of global marketing, the operation of environmental certification programs in-
domestic and international markets may have far-reaching effects.  Two key issues stand out as
being  important.   First, there is  an underlying  assumption that  a voluntary and positive
environmental certification program will be effective in changing the behavior of producers
and/or consumers, leading to specified environmental .benefits. -There is, therefore, an interest
in determining the effectiveness of such marketplace  initiatives.  Second, with the proliferation
of ECPs in many countries worldwide, there is the concern that they may  act as intentional or
incidental barriers to international trade. Interest in the  "harmonization" of program standards
and procedures is rising as more programs become active and the activity of existing programs
increases.                       .          '           .              ,              -

3.1    Effectiveness as Defined by Market Activity

       An important  distinction - should be made  between the popularity of ECPs and their
effectiveness. ECPs are undoubtedly growing in popularity,  as is evidenced by the increasmg
-number of countries developing programs  and the  number of manufacturers proposing product
categories and applying for  labels.   One question that arises,  however, is,  "are such programs
effective?"  This question is difficult to answer at present because many ECPs are just gettmg
under way, and  there1 is a  lack of research and• information on this subject.  Nevertheless,
discussed below are some of the possible ways to  measure ECP effectiveness.       ;

       One way  to measure the effectiveness of an  ECP is the extent to which it achieves  its
 stated objectives.  All ECPs have approximately the same principal goals:  1) to  circumvent
 misleading and false environmental advertising by providing an expert, .objective assessment of
 the relative environmental benefits of a product; 2) to raise the awareness  of consumers and to
 encourage them  to take environmental considerations  into account when making purchasing
 decisions; 3) to provide a market-based incentive to manufacturers to develop new products and
 processes  that are less  harmful to the environment;  and 4) to cause market changes that
 ultimately result in decreased environmental impacts from consumer products.

        Attainment of this  last goal  is  in some  sense the ultimate measure of a label's
 effectiveness.  For example, -a. United Kingdom House of Commons report,on labeling noted that
  "sales in Germany of paint labeled [by Blue Angel] as containing below  10, per cent solvents
  have grown to the extent that they now account for about 25  per cent of the non-trade sector of
  the market." (House  of Commons,  1991)  Also, the German  government reported that the Blue
  Angel award criteria for paints, lacquers, and varnishes have reduced air emissions of organic
  solvents by 40,000 tons. (Federal Minister..., 1990)   In theory, therefore, the best way to
'  measure  effectiveness  is  to  assess the  environmental   benefit  gained from  program
  implementation.  In  practice, however, it is  extremely difficult to link environmental benefits
  to specific actions or programs, and aside from  a  few anecdotal examples there is very little
  information in this area.  Programs have therefore measured indicators of effectiveness that are


                                         •  29  ,           ,

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au-rc easily quantified, such as changes  in product formulation,  the market share  of certified
products or consumer awareness of the program.

3.1.1  Effectiveness As Defined By Market  Activity
            ' j       ••  ": •  "* ":  • .'  •:'.' "•"•'•••""  - ••.'•'  '•:•"' •;'.  ; "  .;!' ;'" ' '    '      '  '      •   ' '
       The effectiveness of environmental certification programs may be measured by assessing
their manifestations in 1) consumer awareness, 2) consumer acceptance, 3)  consumer behavior
change, 4) manufacturer behavior change, and  5) environmental benefit.  The first four elements
in the list above represent the steps that  eventually lead to the fifth element and ultimate goal
of an environmental certification program, namely environmental quality  improvements.  In
other words, an increased level of consumer awareness of a program may lead to increased
consumer acceptance, which in turn leads to changes  in consumer and  manufacturer behavior.
A shift in manufacturer behavior means that manufacturers offer and promote environmentally
preferable goods that carry ECP logos, while a  change in consumer  behavior means  that
consumers buy these goods instead of uncertified ones.  Once consumer behavior changes,
presumably the environment will profit  from the decrease in the production,  purchase,  use,
reuse,  and disposal of goods  that are  more environmentally  harmful than their  certified
alternatives.         •                                        ...         •

        If manufacturers change their processes to achieve ECP certification, then the issues of
whether consumers actually prefer certified products, or whether environmental change actually
occurs become secondary  concerns.   In  this view,  an ECP is a tool that operates  on  the
manufacturers' desire to maintain or increase  their  market share, and is assumed to benefit the
environment if it can establish itself in the market.  Even absent  consumer demand, companies
may seek certification for their products to foster  good public,  stockholder, and/or employee
relations.  Measuring this kind of effectiveness could involve determining how many products
are  evaluated for certification,  as well as the  manufacturers' motivation to  seek certification.

        Unfortunately, there is very little in-depth information on the interactions among ECPs,
the  marketplace and environmental quality.  Although there have been several consumer surveys
that measure3 issues such as logo recognition, there are no known studies on ECPs that address
changes in the market or benefits to the environment due to ECP certification.11  Studies done
on consumer jperception of environmental marketing claims  (not certification programs) suggest
that there is a demand for and  an awareness of environmental product information. According
to an Angus, Reid Group survey, a national-level system of standards (for environmental  claims)
    11  For instance, a survey in 1992 on awareness and  recognition of the Canadian. Environmental Choice logo
 performed by the Environmental Monitor suggested that approximately 42 percent of Canadians have an awareness of
 the Environmental Choice logo.  (International Environmental Monitor Limited, 1992)  Paul Turcotte of Environmental
 Choice related that the Program couldn't afford to do a market changes study or environmental benefit study. (Turcotte,
 1992) Japan's EcoMark program also performed an EcoMark awareness survey on Japanese citizens.
        On the issue of consumer acceptance, Environmental Research Associates states that their survey revealed that
 when consumers were presented with the question of "Who can you trust [to give you accurate and unbiased
 environmental information]," environmental groups led all choices with a 37 percent acceptance rating. The government,
 on the other hand, fared badly, with only a 7 percent acceptance. (Environmental Research Associates, 1990)

            ;•••;;     ,    .    •••    ' i    •::  .      30

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 would 'instill the most confidence in consumers, and an ECP would increase the credibility of
 environmental marketing. (EPA.  1993)  These studies also find,  however, that this interest in -
 environmental- information  does  not  necessarily  reflect the actual  purchasing  choices  that
 consumers make.  Because manufacturers use a'wide spectrum of marketplace information, they
 may  not wait for  measured change in consumer demand resulting from  certification actions.
 Published award criteria from an ECP alone may prompt manufacturers to change their products.

       Examining this issue from a manufacturer's point of  view,  an ECP's effectiveness can
 be measured as a function of its benefits to manufacturers and its related ability to change their
 behavior to accommodate the program'. If a manufacturer works to qualify for an award,  if only
 to avoid losing market share to its certified competitors,'then the program has been successful '
 in changing the attitudes and actions of the manufacturer.  An example of this scenario occurred ,
when .Blue Angel  released  award criteria for  recycled paper.  The  Gentian paper industry
 collectively boycotted the program,  evidently feeling that the cost of modifying their paper-
 makine  processes  outweighed .the increased market share that they might gain from Blue Angel.
 certification.  However,-after'Scotl Paper Co., an.American paper company, applied for and
 received the Blue Angel for  its imported paper, the number of German paper companies applying
 for certification rose dramatically.

        Some manufacturers also see  that there is a market  niche  that they  can fill  with their
 "green" -products., .They may  see ECP certification as a valuable aid in capitalizing  on that
 market, and use it as a way to  boost sales, rather than simply'keeping-up with competition.  A
 •1990 study found that slightly  more than half of the respondents considered the environmental
 attributes  of a product  and/or company.(and could name .the product and its environmental
 attributes) when selecting a product in the past six months. (Abt, 1990)               -

        Although some of these indicators of effectiveness are hard to measure directly, some
 conclusions can be drawn using available data.  For instance, a shift in market share or a change
 in consumer and manufacturer behavior could be an indicator of the success of an ECP.  On the
 other hand, many.other factors (product promotion, media exposure, etc.) could also affect the
 market share, and it is difficult to isolate,the effects of a program from other market forces.
 Other valuable  information may include market surveys  and  feedback from  the .programs
 themselves as they try to accommodate  to the market, manufacturers,  and the public.


 3.1.2  Extrapolating Effectiveness From Other Labeling Studies

         Another way of looking  at the potential effectiveness of an ECP  is to extrapolate from
  effectiveness studies done  on other types of product labels.  A number of these are covered in
  the  1.989  EPA report, including food and nutrition labels, household appliance energy efficiency
  labels, cigarette  labels,  automotive fuel economy labels, and drug and  chemical labels.  The
  report summarizes studies  of the effectiveness of these types of labels by  looking at their effects
  on consumer awareness, acceptance, - and behavior change.- It also takes into account the indirect
  effects of consumer behavior  on manufacturer behavior.

                                .            31

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       However,  many of these other  types of labels have characteristics that are  inherently
different from  those of environmental  certification programs, making  such comparisons
problematic.  In particular, mandatory hazard/warning labels may have very different effects on
the consumer than a voluntary, positive environmental certification  program.  For instance,  a
1986  study performed  on the  effectiveness -of nutritional  information  found that posting
information for positive, beneficial ingredients "had no significant impact on food Purchases
but that posting information on negative, detrimental ingredients " had significant impact.  (EPA,
1989)  In another example, mandatory cigarette warning labels cannot be easily compared to
ECPs because they do not present a choice to consumers: since all cigarette brands must carry
the labels,  no single brand stands out because of the label.

       The original FDA  nutrition  information  labels,  which  have since been revised
significantly, were more similar to environmental certification programs than are warning labels.
For instance, they were not mandatory; they were required only for  foods'whose advertising or
packaging  make nutritional claims,  or  if the'product was fortified with nutrients.  In add.tton
they scared the non-negative (i.-e., not a disincentive) approach of ECPs.  Consumer research
has indicated that while there was widespread support for the old FDA labels,  very few people
actually used them in their purchasing decisions. Research has been conducted to find out why
this is the  case, and theories include:  consumers found the labels too time-consuming to use;
consumers do not have the necessary  skills or information to effectively use the labels; and
consumers do not feel a need for nutrition labeling. (EPA,  1989)   On a related issue,  focus
group studies performed by  the FDA suggest that consumers are more  likely to respond
positively to simple labels. (Lewis and Yetley, 1992)

        It should be noted that even the  oid nutrition labeling program differed quite substantially
 from most environmental certification  programs. Whereas all ECPs are completely voluntary,
 the FDA labels were still mandatory under certain conditions, as noted above.    In addition,
 the FDA nutrition label is an information disclosure label, providing neutral information  to the
 consumer, while an ECP performs  an advocacy role by recommending certain products over
 others.13
            '"'I   .'   •    '':• •' '  '   „  ,' "  *':••. !, ;."  :•• '  •  .' 'v i   , :'t. .',••.                 ••
 3.1.3  Summary of Effectiveness Discussion

        The effectiveness of an environmental  certification program can be examined in terms
 of its impacts on consumer awareness, consumer acceptance, consumer behavior, manufacturer
 behavior, and environmental benefit.  Each of these elements reinforces the others and provides
 important insight into the driving forces behind the success or failure of an  ECP.  Conclusions
 regarding the effectiveness of ECPs  are tenuous,  however, due to the lack of effectiveness
 studies for  most programs  and to the problems  associated with isolating  their  market  and
     11 The newly revised FDA labels are mandatory for most foods.

     13 It should be noted that the SCS Environmental Report Card in concept does not advocate any product, but rather
  acts as an information disclosure program.

           •   \       ,     "  ;      •    :  '•  •  32

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                                                                              ••*---'!- "-' "-» -
 environmental effects.  Some limited information may also be extrapolated from effectiveness
. studies performed on  other types of labeling programs, although most  of these-labels are
 sufficiently dissimilar from ECPs to make comparisons difficult.   .

 3:2   Harmonization Issues

       ECPs are currently operating in 24 countries, with more expected  to be operational in
 the near future.  Included in countries with active or planned programs are some of the major
 trading nations of the world. These programs differ in some fundamental ways, such as methods
 of operation, selection of products, how much public review is involved, and stringency of the
 award criteria.   Consequently,  there is  some concern that the proliferation  of  ECPs, both
 domestic and foreign, could cause  consumer confusion and,  although voluntary, may act as
 barriers to trade. For example, manufacturers with a product already certified by one ECP may
 have to reformulate their product to meet the award criteria of another (country's) program. The
 harmonization of programs is therefore considered essential to the long-term success of ECP
 initiatives worldwide.  Harmonization issues include information exchange (such as data sources
 and original research) and -standardization of program elements (such as the use of terms,
 definitions and symbols, award  criteria, and testing and verification methodologies).

        With negotiations for the General Agreement on Trade and Tariffs (GATT) and the North
 American Free Trade Agreement (NAFTA) high on the agenda of trading nations, harmonization
 issues are becoming increasingly  important'as  any potential barriers  to  trade  are  being
 scrutinized.   Harmonization of programs can encourage trade among countries,  or at least
 eliminate the programs as barriers to trade.  Some have suggested, that voluntary. ECPs may be
 a preferred means of achieving environmental, improvements  compared with other,  less trade-
 friendly approaches.  ECPs can give consumers the information they need to be more actively
 involved with international environmental issues, without governments taking  unilateral action
 against trading partners.                       .          _

         One example  of how an ECP could bypass trade barriers is the  Mexico-U.S. dispute
  about tuna fishing.   The U.S. Marine .Mammal Protection Act bans imports of  tuna when
  incidental dolphin kills  exceed certain Limits.  Since Mexican fishing fleets employ  purse-seine
  fishing practices, a practice dangerous to dolphins, the U.S. government is currently enforcing
  an embargo against  importing Mexican tuna. • In September 1991, a  panel  of the General
  Agreement on Tariffs and Trade (GATT) agreed with Mexico that the U.S. tuna import embargo
  violates the GATT agreement and recommended, that the GATT Council rule against the U.S.
  The  Council has  yet to hear the case.   A  GATT decision against the  U.S. could result  in
  Congress being forced  to repeal the law. (U.S.  OTA, 1992)

         Some have suggested that voluntary ECPs are an effective means of pressuring foreign
  companies and countries  to change environmentally damaging practices (so they  may continue
  to compete effectively).  At the same time, an ECP may avoid the danger of  attempting to
   regulate business practices  in  other countries.  -According to Professor  Jagdish  Bhagwathi of
   Columbia University,  the Economic Policy  Advisor to the  Director General of  GATT,  the


            "•...•'..             33

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•Marine Mammal Protection Act was perceived as a unilateral action not supported by GATT.
 GATT fears th'a't such actions could lead to the protectionism that was rampant in the 1930s.
1 "We therefore need something like a proper labeling, because it would be hard for me to boycott
 Mexican dolphin-unsafe tuna If I didn;t know it was [unsafe].  To make voluntary boycotts
 effective  you need labeling, and  labeling  can be required"  without running the risk  of
 protectionism.   (Bhagwathi,  1992)  One private ECP, the Flipper Seal-of-Approval program,
 already awards a seal to products made with tuna caught without harming dolphins.
            • ; •;(. •• ,      -   ' ,   ' ,  ;' : V	,: '  '"- ,   '.(j., ; j •   ;/ !  ;.    ,:
        Some groups, such as the International Chamber of Commerce, have emphasized the
 importance of having only one ECP, or one set of harmonized programs, in each market. (ICC,
 1991) The United Nations Environment Program (UNEP) Industry and Environment Office has
 held seminars to bring together representatives of ECPs, in  order to encourage the promotion
 of "Cleaner Production" technology, especially in Eastern and Southern Europe and developing
 countries.  (UNEP, 1991)  In addition, the International Standards Organization (ISO) has set up
 an Environmental Labeling Subgroup under  its Strategic Advisory Group on the Environment
 (SAGE) to consider approaches to international standardization of national ECPs and to make
 recommendations on how to organize such work. The Subgroup met in Geneva in October 1992
ho discuss  standards for  ECP terms and definitions, symbols,  and  testing and verification
 methodologies,  as well as for environmental advertising. (ISO, 1992)  In May 1993, SAGE met
 in Toronto to finalize recommendations to ISO on the formation of a new Technical Committee
 on Environmental Management. (ISO,  1993)  U.S. EPA, the U.S. Trade Representative's
 Office, members of the U.S. delegation to ISO-SAGE, the International Chamber of Commerce,
 and the individual programs are all participating in formal and informal discussions surrounding
 harmonization issues.  (EPA, 1992)

        The  European Community  has addressed  these concerns by introducing a single EC
 environmental certification program that is operated by the twelve member states while giving
 the European Commission final say on disputes or inconsistencies.   The EC "environmental
 labeling programme"  was established to ensure the integrity of a single European market and
 to achieve uniformly high levels of environmental standards across the EC.

        To be effective, harmonization would cover most but  not all elements of a program, such
 as product category definition, background research, product evaluation methodologies, award
 criteria, funding and fees, and program oversight.  There is, however,  little or no need to
 develop similar administrative structures across programs.

        In addition to improving the transferability of awards  and eliminating potential trade
 barriers, harmonization could reduce the operating costs of programs.  By exchanging expertise
 and research among programs, duplicative efforts can be avoided. Harmonization of product
 category development and product evaluations would establish consistent methodologies,  test
 methods,  award criteria, and quality assurance procedures.  With award criteria development
 costing up to $100,000 or more for brie product category, and outside funding of programs
 expected to decline in the long-term, strong financial incentives exist for greater harmonization.
  (Holmes, 1991)

              ,.  "    •   .   ,'   .••  , :: ".    34-

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      According  to one  expert,  however,  there  may  be a  number  of  impediments  to
harmonizing ECPs.  For example, harmonization would require programs to. relinquish a certain
amount of autonomy and authority to the collective process, a political decision that may not be
realistic  (Salzman,  1991)  Harmonization could be viewed not as a negotiation of common
program elements, but rather as a dynamic process leading to a consensus approach to labeling.
                                           35

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                              References for Chapter 3
 Abt Associates Inc., 1990.  Consumer Purging Behavior and the Environment: Results of an
 Event-Based Study, November.
>ag*a,hi, Jag
-------
Turcotte, Paul, 1992. Environmental Choice Canada.   Personal communication  with  Abt
Associates,  Inc.        .
US  Congress, Office of Technology Assessment, 1992.  Trade and Environment:   Conflicts
and  Opportunities, OTA-BP-TTE-94, Washington, D.C.,  U.S. Government Printing Office,
May.    •      .            -                           .                        .
United Nations Environment Programme, Industry and Environment Office,  1991   Global
Environmental Labelling: Invitational Expert Seminar, Lesvos,  Greece, 24-25 September 1991,
Working Group on Policies, Strategies and Instruments of the UNEP/IEO Cleaner Production
Programme.
U.S. EPA, 1993.  Evaluation of Environmental.Marketing Terms in the United States.  Prepared
by Abt Associates, Inc., February, EPA 741-R-92-003.        •••-.-•    "   <

U.S. Environmental Protection Agency, 1992. Environmental labelling Workshop Summary -
Draft, October 30,                               ,
 U S  EPA 1989  Environmental Labeling in the United States: Background Research, Issues,
 and 'Recommendations - Draft Report. Prepared by Lori K. Carswell, Julia J. Langel, and Adam
 B.Borison, Applied Decision Analysis, Inc., December 5.
                                           37

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                             APPENDIX
            EN^nDRONIVIENTAL LABELEVG PROGRAM SUMMARIES

      The program summaries that follow in this appendix were compiled from documents
provided by each of the programs, communication with program staff,  and  other publicly
available materials.  Each program  was offered the opportunity to review and  comment on a
draft summary.  Every attempt was  made to verify the information provided, but independent
verification of such information is often difficult.

      Most program summaries present information using the following format:

      •     Introduction
      •     Administrative Structure
      •     Award Process
      •     Public Review
      *     References
                                      39

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                 &" Oveiview of Environmental Labeling Programs '(as of Mid-1993)
Program Name
Seal of Approval
Blue Angel	
Environmental Choice Program
_—.	.	—  ———————
IIcoMark
	•
White Swan
 Green Seal
 Good Environmental Choice
 Ecomark
 Ecomark
 Green Label Singapore
 Environmental Labeling Programme
 _Stichting Milieukeur
 NF-Eaviroanement
  Whole Earth Access
   Information Disclosure
   Energy Guide
Nordic Council
(Sweden,  Norway,
Iceland, /Finland}
 Flipper Seal of Approval
 SCS Forest Conservation Program
 "Wal-Mart   	
  Single Attribute Certification
  SCS Environmental Claims Certification
 ^Environmental Choice Australia
  EPA Energy Star Computers Program
  Report Card
  Shopping for a Better World
  SCS Environmental Report Card
  Negative Labeling
  Pesticide Labeling	
  Toxic Substances Control Act (TSCA) Labeling
  Proposition 65    	__	
  Household Hazardous Product Shelf Labeling

  Ozone Depleting Substance (OPS) Label
   Fuel Economy Information Program
   Books
   Nontoxic, Natural & Earthwise
   Green Consumer Supermarket Guide
                                                                                                  «»•
   n,a. = not available,  —  = not applicable

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GERMANY'S BLUE ANGEL

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GERMANY'S BLUE ANGEL
Introduction

       Germany (formerly the Federal Republic of Germany) introduced the Blue Angel labeling
program in 1977, making it the first country to implement a national ecolabeling program. The
program was launched by the Federal Minister and the''Ministers for Environmental Protection
of the  Federal States with the  stated goals of 1) guiding  the consumer  in purchasing quality
products with smaller Adverse environmental impacts, 2) encouraging manufacturers to "develop
and supply environmentally sound products,"  and 3) using,the ecolabel  as a "market-oriented
instrument of environmental policy."  (Umweltbundesamt,  1990)   Most  other ecolabeling
programs  in existence today  are based to some extent on the Blue Angel program.

       The German government sees the ecolabel as a "soft  instrument" of environmental policy,
since the program cannot establish binding requirements or bans and because participation in the
program  is  completely voluntary.  The Federal Minister for the Environment attributes the
success of Blue Angel to "the growth of environmental awareness on the  part of consumers and
producers." (Umweltbundesamt, 1990)  In a 1988 survey  of 7500 German households,  79
percent were at least familiar with the ecolabel, and 68 percent correctly linked the ecolabel with
the concept of environmental protection. Similar opinion polls have been performed on a regular
basis,  showing that the Blue Angel is perceived as  "a reliable ecolabel." (Breier, 1993) The
program grew slowly at first, issuing only 500 ecolabels in  33 product categories as of'1984.
By mid-1993, however, the ecolabel appeared on 3503 different products in 75 categories.  Most
of the  awarded products are from German manufacturers, with about 12 percent of all ecolabels
awarded to  non-German companies. (Salzman, 1991)

Structure                                  .                       •  ,

Three  institutions participate in the four-stage award procedure.

       •      The Environmental  Label Jury (ELJ) is a broadly based group made up  of
              representatives from citizen, environmental, industry, and union organizations.
              Although the  other institutions have considerable influence over the selection of
              product categories and award criteria, the Jury makes the final decisions on these
              issues.  The Jury also has the authority to require the Umweltbundesamt (see
              below) to subject a product group to, thorough examination and testing.

       •      The  German Institute of Quality Assurance and Labeling (RAL)  is a non-
              government, non-profit organization whose membership consists of 140 private-
              sector associations.  RAL is responsible for organizing and  chairing the expert
              hearings  at which the standards for proposed product categories are discussed.
              After a .product  category has  been approved  by the  Jury,  RAL  receives
             -                 *
                  .        '       '          44

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            applications'from manufacturers and checks whether their products meet all Blue
            Angel requirements. RAL also completes civil law contracts with the individual
            manufacturers whose products qualify for ecolabels.

      •     The  Umwelibundesamt,  or Federal  Environmental  Agency  (FEA)  is the
            government agency in charge of environmental protection.  Its role is to make the
            initial decision as to whether a new ecolabel proposal should be pursued, and
            then  if the ecolabel has been approved for further development by the Label
            Jury' to carry out the necessary  testing and to draft an award criteria proposal.
            The Umweltbundesamt  delivers its opinion to RAL, which then organizes expert
             discussion hearings.

      The ecolabel  is the property,of the Federal Ministry  for the Environment, Nature
Conservation, and Nuclear Safety. The Umweltbundesamt usually acts  for the Mirustry.

Award Process

       The Blue Angel award process consists of four stages (see diagram) in which all three
institutions take part.  New product categories may be proposed by any  interested party.  Once
proposed, the  Umweltbundesamt, RAL, and the Jury  work out the  award criteria   define
appropriate tests, and set up expert hearings to discuss and develop the criteria proposal. The
Label Jury makes the final decision on proposed  categories and criteria.  Once the category has
been approved, RAL is in charge of working out  civil law contracts for ecolabels with mdwidual
manufacturers.

Stage I: Choosing Product Categories

       Product categories may be proposed to the Umweltbundesamt by any interested party.
In practice, however, most are proposed by manufacturers seeking Blue Angel ecolabels for their
oroducts    The Umweltbundesamt  reviews these  proposals  for suitability, and plausibility
 regarding  the claimed environmental benefits.  The  Umweltbundesamt then passes these
proposals on to the Jury.  The Label Jury decides which new ecolabel proposals ought to be
purged further, and  orders the Umweltbundesamt to perform a  close examination  of the
 environmental impacts of the products under consideration. The Jury orders between five and
 fifteen of these tests every year.

 Stage EC: Setting Standards

        As ordered by the Label Jury,  the Umweltbundesamt performs tests on the new award
 category proposals to determine the  most important  environmental  impacts  of the product
 category  TheUmweltbundesamt then drafts award criteria for the product category based on
 the data from those tests. The award criteria are then presented to an expert hearing organized
 by RAL.
                                            45

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       Establishment of these criteria is a' very involved process/  The German  government"
states that "the 'basic criteria'  for the award of the ecolabel demand the consideration of all
aspects'of a product."  As stated,  these aspects include  "the various  'phases'  in the life of a
product cycle  (i.e.,  from  manufacture  to use  and consumption to disposal)"  and "the
environmental damage caused by the product on the various environmental sectors  (e.g., waste
aspects, hazardous substances, emissions into air, water, and soil)."  (Umweltbundesamt,, 1990)

       While a product's entire life cycle is examined initially in a life cycle matrix (similar to
the EC  matrix), award criteria cannot  be practically based on every attribute that a product
possesses.  Instead, only the greatest points  of divergence between products within a product
category are considered. The final result of the matrix approach is the distillation of all possible
environmental impacts to a  few criteria,  identified as the most important in distinguishing
between a superior product and an inferior one in environmental terms. Safety and health issues
are also considered in drafting criteria,  but they are secondary to the environmental issues.

Stage IH: Jury Decision on Product Category Proposals

       Once the Umweltb.undesamt has completed the draft criteria, the proposal  is discussed
at a closed door "expert hearing" organized by RAL.   Experts are drawn from consumer,
environmental, manufacturing, and trade union organizations,  The expert  panel critiques  the
ecolabel proposal and sends it to the Label Jury for review.

       The Label Jury  may accept, reject, or amend the proposal.  The Jury aims for a
consensuSj but decisions are made by majority rule.   Between 3 and 6 new product categories
are approved each year, and it takes between 6 arid 24  months to develop criteria  for a new
product category.

Stage IV: Awarding Ecolabels to Manufacturers,                                       '

       Once the award criteria for a product category have been established, a manufacturer may
apply for an ecolabel.  The manufacturer pays RAL a fee of 300 Deutschmarks (or about  US
$190) as an application fee.  If the product meets all of the ecolabel's requirements, then RAL
and the manufacturer work out a civil contract defining the appropriate use of the  logo.  In
addition to the application fee,  there is an annual contract fee based on product  sales, and  a:
mandatory contribution to the Blue Angel's Advertising Fund.

       The Blue Angel logo may be used  only on the  approved product  itself and in direct
advertisement for that particular product.  The logo may not be used by a manufacturer to imply
that other products have been reviewed by Blue Angel or have been awarded an ecolabel.

       An award  is valid for a maximum_of three. years, after which the  manufacturer must
reapply for the ecolabel, whose requirements may have  changed in the interim.   The validity
period may be shorter for products whose technology is advancing rapidly.  In theory, once a
                                           46

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                    otGemian
 Stage I: Establishing Product Categories
Anyone may suggest
  product categories
    to the Federal
EnvironmentajAgency.
    The FEA reviews
 proposals and passes
     them on to the
Environmental Label Jury.
                              ; The Jury decides on the
                              !  labels and requests
                              I additional testing from
                               the FEA to set criteria.
  Stage II: Setting Award Criteria
 The FEA performs
1  tests and drafts
      criteria.
 'The RAL convenes an expert  ;
  hearing with paneilstis'drawn1' !""
 from consumer, environmental, :_
  ,... manufacturing and trade    •
  organizations.  The experts
recjdmmend changes to the Jury.'
                             ', The Jury may accept,
                             ;' reject or amend the
                             ~\  proposal, voting by
                             !     majority rule.
   Stage 111: Award Process
 I Manufacturers apply for
 1 award to RAL, paying fees
 '    for product testing.
   _*.! Approves!
       Rejects  i
                            Manufacturer signs civil
                           contract with RAL, paying
                          licensing fee based on sales,
                           as well as a contribution to
                                                the program's advertising fund

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product category's award criteria have become the industry norm, they should be raised to push
the market toward-greater.improvement.   .-'.-•.        •                '    •

Public Review Process

      While consumer, environmental, manufacturing, and union organizations all take part in
designing new product categories and award criteria, there is no official public review process.

Enforcement of Program

    •  It is the responsibility of both the Umweltbundesamt and RAL to act against those who
misuse the ecolabel.  RAL deals with parties who have signed and broken a contract, while the
Umweltbundesamt deals with all other unauthorized uses.  According to a report by the OECD,
"most problems from contracting parties occur when their advertisements imply that a whole .line
of products, rather than just one, qualifies for the label." (Salzman,  1991)

References                           '

      Breier, Nicola, FEA, 1993.  Personal communication with Julie Lynch, U.S. EPA, May
       11.         •

    "  • Environmental Data Services,  1989. Eco-labels: Product Management in a Greener
      Europe, London. .                          ,                                 .

      Federal Environment Agency [Umweltbundesamt], 1990.   Twenty Arguments Against
      'the Environment Label... [20 Argument gegen das Umweltzeichen... undwas man davo.n
       lu halten hat].                                                               .

       German Institute of Quality Assurance and Labeling .  (RAL), [Deutsches Institut  fur
       Gutesicherung],  and the Federal Environment Agency [Umweltbundesamt], 1991. Tlie
       Environmental Label Introduces Itself.                         -   .

       Salzman,   James,  OECD,   1991.    Environmental Labelling  in  OECD Countries,
       Organization for Economic Cooperation  and Development, Technology and Environment
       Programme, Paris.
                                          48

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CANADA
S ENVIRONMENTAL CHOICEM
    PROGRAM
             ^/RO

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CANADA'S ENVIRONMENTAL. CHOICE" PROGRAM: THE ECOLOGO*
Introduction

       "The Environmental  Choice Program was created by Environment Canada to  help
consumers  identify products which ease  the burden on  the environment."  (Consumer .and
Corporate Affairs Canada,  1991)  The Environmental Choice Program is a voluntary  eco-
labelling program operating under the authority of the Canadian Environmental Protection Act
(CEPA). It was founded in 1988 in response to, growing consumer interest in environmental
issues following the publication of the UNCED  report  "Our 'Common  Future" and a multi-
stakeholder report prepared by the Canadian Council of Resource and Environmental Ministers.
A government  position paper written in response  to  the  UNCED  report urged industry,
government and consumers to "appreciate the collective drain _we are imposing on our finite and
fragile resource base" and  challenged Canada  to "bring environmental concerns into the
mainstream of our thinking and decision-making." (Environmental Data Services, 1989) These
reports and press reports of major environmental degradation world-wide  provided a responsive
climate for the announcement of the Program.

       In  the .first four years of operation, Environmental Choice  has  published 27  final
guidelines and has awarded the  EcoLogo to over 750 products. The program's goal is to release
approximately ten new and/or  revised  guidelines  each fiscal year. It has received a generally
favourable response from consumers and industry, with a June 1992 survey finding recognition
of the EcoLogo at 42 percent among consumers.   (Environmental Monitor, 1992)  A licensee
survey conducted in 1992 indicated that the majority  (71 percent) of licensees either agreed or
strongly agreed the Environmental Choice. Program licensing was  a good business investment.
(Polak, 1993)                              -       .
                                    " '          - f                       '
Administrative Structure

       The Minister of the Environment has responsibility for the operation and activities of the
Environmental Choice Program under  CEPA paragraphs 5(l)(a) and (b)  and 8(l)(b).

       The Environmental  Choice Advisory Board is an independent volunteer body which
oversees the development  of  Environmental Choice Program product category  guidelines.
Sixteen members including a chairperson are appointed under CEPA Section 5(a)(a) by the
Minister.   The  group has expertise  in a variety of fields  such as  science,  environmental
advocacy, health, manufacturing,  retailing, law, communications and economics.

       The primary role of the Board is to  provide the  Minister with arms-length, objective
advice and recommendations on the formulation of product- and service-specific environmental
guidelines. The Board also recommends to the Minister proposed final guidelines for approval
by the Governor-in-Council.
   "This section was submitted by Environmental Choice Program Canada and incorporated directly into the appendix.

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       As an initiative under the Government of'Canada's Green Plan, the federal Department
of Environment provides both general support and direct  management of the Environmental
Choice Program.  Specifically, Environment Canada provides core funding for the Program
scientific and technical advice; on-going liaison  with provincial  and other governments  and
Environmental  Choice Program staff who are responsible for the day-to-day  management and
operations of the Program.

       The Environmental Choice Program's Technical Agency  is retained under contract to
Environment Canada.  Under the direction of Environmental Choice Program staff, it checks
products and relevant processes before and after  licensing to determine whether they meet the
Program's environmental criteria.  It also administers the verification program mcluding the
provision of testing services when required.

       Product category-specific review  committees areconstituted1 under the Environmental
Choice Program as advisory groups to assist in the development of technically and scientifically
defensible guidelines.   Committee membership includes various  independent experts  and
stakeholders having an interest in or being affected by the development of product-specific
guidelines.

Guideline Development Process

       Five environmental principles have been adopted by the Environmental Choice Program
 to help rank product categories for the development of environmental guidelines. They are also
 used to determine technical criteria that a product must meet in order to be considered a good
 environmental choice.  These principles  are to:

               encourage the efficient management  of renewable  resources  to  ensure their
               availability to future generations;  ^

               prtSrnott the efficient  use of non-renewable resources, including fossil fuels;
               facilitate  the reduction,  reuse and   recycling  of industrial,  commercial and
               cdiftuirier waste;
   -"    <  • '      ffj  :: ':  "'   sr•'':•:':  ;=,  -  ": '':.• ,/"•:'.    ! ••;:•.:'• • ;.'.'•' ;;FV-   '       -,          •'  '
        •      encourage the protection of ecosystems and species diversity; and

        •      etidourage the proper management of chemicals in products.
               1 t.jjfi  ' , •,  •  '•:  •  .,	     ' ..  .;: -   :  '  " ••'•.-.'  - v   !> •     •  •
  Stage I:      Selecting Product Categories
   ,..| '             	',
-------
Stage El:     Developing Guideline Criteria        ,
, • ,   -            •                        '•  . -        \
       Once the product categories are identified, the Environmental Choice Program engages
a consultant to develop a detailed assessment of the product category in the form of a technical
briefing note.  The briefing note includesan environmental review  spanning the product's life
cycle,  a profile  of the  industry, an  assessment of potential  economic  impacts and of the
consumer market for the relevant product type.   -

       The Program staff then develop the draft guideline, based on the information contained
in the  technical  briefing  note, -with the assistance of product-specific technical  review
committees. Once a draft is complete and approved by the Board Technical Subcommittee,  it
is released  for a 60-day public review.. Although the Canadian,government is responsible for
the Program, there is considerable public involvement through  the public  review of guidelines
and the Advisory Board membership.  The .public review period is "the Program's opportunity
to hear from manufacturers; consumers and any member of the  general public with suggestions
as to how to improve the criteria."  (Environmental  Choice,  1991)

       Comments from the public may  be incorporated into a final draft guideline which  is
presented by the Board to  the Minister  for consideration and  approval.  A final guideline  is
subsequently announced in  the Canada Gazette,

Stage D3:     Certifying Products and  Services

       Once  a guideline  is established,  manufacturers of products or purveyors  of services
covered  by the guideline are free to  apply for certification  of their product(s) or  service(s).
Certified products may bear the Program's  symbol of certification —  the EcoLogo.  .The
following are the steps in the certification — the EcoLogo.  The following are the steps in the
certification process:                                             '     .

a) .    Application — Manufacturers of products apply to the Environmental Choice Program
       for use of the EcoLogo and technical compliance verification testing of their products by
       the Technical Agency.

b)     Verification — A Technical Agency inspector visits plant sites  to assess products and
       processes against Environmental  Choke criteria.  Based on findings,  the Technical
       Agency makes a recommendation to the Environmental Choice Program, on  whether  to
       certify the product(s).

c)     License — The  license agreement  authorizes the use of the EcoLogo on  and/or  in
       association with products found to meet Environmental Choice criteria  (i.e., "certified
       products").  The licensee agrees to pay an annual license fee and to maintain compliance
       with Environmental Choice Program licensing requirements, and guideline criteria.
                                           52

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•-r
             • • ts « chafed separably by the Technica. Agency, on
          in the May 11, 1992 issue of Maclean's magazine.
          For more information about the Program, contact:             .

                Environmental Choice Program    (613) 952-9440 (telephone)
                ^7 ^rks Street, Suite 200      (613) 952-9465 (facsm.de)
                Ottawa, Ontario
                K1AOH3

          References
               '  consumer'kd Corporate Affairs Canada; 1991 / Guiding Principles for 'Envt
                 Labelling and Advertising.
            '••    Env^nniLl Daa Services,' 1989;  Eco "tibA:" " Proi&fMamgement  in a Greener'
                 Europe, London.
                 Environmental Choice, 1993.  Press release on appointment of John Polak as director,
                 May 3.
                 Environmental Choice, 1991.  Information sheet, May.
                 Environment Monitor: 1992:  Omnibus Report, prepared for Environment Canada by
                  International Environment Monitor, Ltd.
                                                     53
                                        ini ,. .-il"!!!!, .ulri'm'lh.;, hlJ'i.ii lil'ilil IN ri.yl'i, .,|	

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            Diagram of Canada's Environmental Choice Program
  Stage I: Establishing Product Categories
Anyone may suggest product
  categories to the Board.
  Board selects categories
 and assigns to Consultant.
| Technical Briefing
I Note prepared by
j    independent
•    consultant.
 Paper is reviewed by Board
!
j  and Environment Canada.
•; If approved, it is passed on
I
j  to Program Management
j   Staff to develop criteria.
  Stage II: Developing Guideline Criteria
  Program Staff develops draft  j
  guideline with assistance from j~
  an ad hoc Review Committee, i
   .Board recommends final. i
   draft guideline to the     i-
   Minister of Environment  !
   Draft guideline reviewed
   and approved by Board
   Technical Subcommittee.
             Sixty day
           public review.
                 Minister of Environment      ;
              considers criteria, and upon     '•
         '! approval, releases guideline as final. !
  Stage llj: Certifying Products and Services
    Manufacturers apply to Env.
  Choice, paying fees for product
 testing/verification and certification.
          Testing and verification performed
       by Technical Agency, includes site visits.
         Certification performed by Program.
              Approves
              Rejects
  !   Manufacturers enter into license
 "; agreement with Env. Choice, paying
  j  annual license fee based on sales
  i,      of certified product(s).
                                   54

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JAPAN'S ECOMARK

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JAPAN'S ECOMARK
Introduction                     ,

       The EcoMark program was started  in February 1989  to "recommend environmentally
friendly products to  consumers and contribute to environmental protection."  The program is
implemented by the  Japan Environment Association (JEA), a non-governmental organization,
under the guidance of the Environment Agency.15  Within4the JEA there are two committees
responsible for running the  EcoMark program:  the.EcoMark Promotion Committee and  the
Expert Committee.  The Promotion committee sets product criteria, allowing for input from
interest groups.  The Expert Committee is an expert panel that judges products and awards  the
use of the logo.                                                 . •

       EcoMark has several goals:
       •  Heighten the environmental awareness of consumers,
       •  Recommend products which contribute to environmental protection and conservation,
      • •  Symbolize an "ecological" lifestyle, and
       •  Promote "clean" innovation by industry.  (Environmental Data Services, 1989)

       EcoMark is the second oldest ecolabeling program  after Blue Angel and by far the fastest •
acting program, having issued over 2,300 awards in 49 product categories as of the  end of
August 1992.  The  development  of award criteria is faster  than Blue Angel (Germany)  and
Environmental Choice (Canada) because products are judged using a rather different process.
While other programs try to assess environmental impacts  of products throughout their life-cycle
and evaluate products within a product category, EcoMark often awards ecolabels to products
that are inherently  'environmental;'  not distinguishing  so  much the  specific manufacturing
processes of individual products within a category.  In this way the logo is used to call attention
to products that are part of "an ecological lifestyle," more than to  weigh the relative  impacts of
general consumer products.  The program  is  guided by "basic principles" that define EcoMark
products as those  that:                .    .-                .

       •  incur a  minimal environmental burden when used,
       •  improve the environment when used,16
       •  incur a  minimal environmental burden when discarded after use, and
       •  contribute to environmental preservation .in other ways. (Hashizume, 1992c)
    15 The JEA is also described as "a public corporation under the guidance of the Environment Agency."

    16  According to Mr. Hashizume  of the Japan Environment Association, "improve the environment" means "the
 reduction of the pollution; e.g., a kitchen sink strainer which has fine mesh, can catch fine materials ia the waste water
 from a kitchen and prevents water  contamination of rivers and lakes.  Most of household waste water [flows] directly
 to rivers and lakes in Japan."        '                                           .
                                            56

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   •    At present, program criteria are set to promote specific activities or product attributes,
based on these general guidelines.  However, the JEA is studying,approaches to using life cycle
analysis, which would bring its evaluation approach closer to that of Blue Angel and Canada's
Environmental Choice Program.

       Two studies  have been conducted to evaluate the influence of EcoMark.  One was a
survey Of local governments, distributors and companies with EcoMark-approved products,
conducted by the JEA in the Spring of 1991. More than half of the companies who had acquired
the logo did so to Improve their  corporate image, citing also "requests from customers and
increased sales." Almost all local governments were aware of the program,  but only 40 percent
of distributors] The other, a public opinion survey conducted by  the Prime Minister's Office
in July 1990, found that 22 percent of those polled were aware of the program.  A report by
JEA  concludes, "Because  of a low recognition factor  and the  small number of approved
products, few consumers look for the EcoMark [logo] when  they shop." (Hashizume,  1992c)
EcoMark hopes to include some questions in another public opinion poll on environmental issues
to be conducted by the Prime Minister's Office. (Hashizume, 1992b)

   i°"':            "'/'''I   ;    • "' i  ''''"' ••  " ' " ' '':'! ;l"!'" •'' /; '  '"' ;"  ' I'1' '' '  ' ',! ' '!:                   •
Administrative Structure

       The EcoMark Secretariat is located within the Japan Environment Association, as are the
two committees responsible for administering  the program:

•      "The Promotion Committee acts primarily in  a supervisory capacity, approving the
       guidelines for  the  programme's operation, advising on  day-to-day  operations,  and
       selecting appropriate product categories and criteria.  It is a nine-member committee,
        with representatives from consumer, manufacturing, industry and distribution groups, the
        Environment Agency, the  National Institute  for Environmental  Studies,  and  local
   "Sj1.  • governments"."

 .      "The'&pe/f 'Committee judges''whether" applicant products qualify  for the label.  This
        five-person committee is more technically-based, with consumer protection organization
        representatives, environmental science experts, as well as technical experts from the
        Environment Agency  and  the National Institute for Environmental Studies."  (Salzman,
   •:•   ' 1991)    "'_

        Members of the committees do  not receive a salary;  The government's Environment
 Agency acts only to "supervise" the JEA, to advise on both committees and give "guidance" for
 the nomination of committee members.  Although start-up costs were paid by the government,
 the program is now self-financed  from the fees assessed to licensees.  It is the only government-
  related environmental certification program to be self-financed.
                                           57

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Award Process
                                     •''••*•
      EcoMark's award process is much simpler than any other seal-of-approval program. The
result is that it is faster and-less expensive to operate than more complex programs such as Blue
Angel, but it has less public participation and the award criteria are less stringent. To qualify
for an award, a product must meet the following guidelines:

       • -    Preventative  measures are  taken against  environmental  pollution in  the.
             manufacturing stage;

       •      Processing is  not difficult at disposal;  .

       •      Energy or resources can be conserved with use of the product;

       •      The product  and  manufacturer  comply with laws,  standards  and regulations
             pertaining to quality and  safety;  and

       •      Price is not extraordinarily higher than comparable products.  (TEA, 1991)

       These criteria set minimum standards for selected evaluation criteria but should  not be
mistaken for a form of life-cycle analysis.  It  is  not clear how products that  have conflicting
benefits and impacts as  defined in these guidelines are evaluated.

Stage I          '   -.   •        ' •       ''   •  •

       Product categories are selected by the Promotion Committee, but can also be proposed
by industry and consumers.  The Committee, following the basic principles listed above, based
on information supplied by manufacturers, approves a product category for  inclusion  in the
EcoMark program.  Then, with the assistance of the Expert Committee,  they establish  award
criteria for the product category.                  .

Stage H

       Once award criteria have been  set, product applications are accepted.  Manufacturers
must supply relevant information  to the Expert  Committee, but the Committee may request
-further testing by a third party.  Since products are judged  on  as few as a single criterion and
not  on a lifercycle analysis, occasionally whole  categories of products are  approved.  For
example, there is an award for composting containers, regardless of how they are made or what
they are  made of, because composting can mitigate solid waste disposal, an important concern
In Japan.  EcoMark has been considering approaches to LCA, and is currently considering using
life  cycle analysis as a "qualitative" rather than "quantitative" tool.  The reasons given  are:  1)
there is no standardized method for. LCA; 2) they have had difficulty getting correct data from
manufacturers; and 3) results fluctuate widely  according to the method of analysis and type of
data. (Hashizume, 19925)

          !         '•"•'.        ."  ."58         -   '

-------
                                   EcoMark Labeiinjg_P.rQgLam
  Stage I: Establishing Product Categories
  Product categories are proposed
by the Promotion Committee, industry j-
     and members of the public.     i
                                           '!•'  'promotion Committee, guided   ,
                                                 by basic principles, with      ;
                                           "'information from Expert Committee,
                                           ' and manufacturers sets categories.;
  Stage II: Setting Award Criteria
               1 Criteria are set by the Promotion Committee
               1  in consultation with the Expert Committee.
   Stage 111: Award Process
   Manufacturers apply for
      award to the Expert
i Committee, providing relevant
;  information^ The Committee
i  may request additional third-
|   party testing. There are no
   application or testing fees.
                                Approves 'r
                                 Rejects
|  Manufacturer signs two-year   ;
!contract with Japan Environment;
|  Association, paying a licensing ;
i.  fee based on the retail price  ;
i         of the product.        "i
                                      59
              	 i|	I,,,,!, 'ii,"1 >,, , l,i,;, „,	,,, MlLliiillll',,1, Jtjn,.,Sn|iiu,	i,,j,<||ii'uiliiiliPiuihl!!i.i J,,:,'I	I,,, ,: i 	i",,,'	i"'Mi!!.11!'',!,:„,ii,•"	,;• 'Jlj'i .;• iiliLJiii'liC'i.!.,:!,!' • , i

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       If a product is given an award, a contract is signed with the TEA, and use of the logo is
certified for two years.  Unique among enviro-certification programs, the fee charged for use
of the award (between 80,000 and 200,000 yen) is based on the retail price of the product, not
the number of units sold or the market share.  There is no application fee and no advertising fee,
so it is often the least expensive program for manufacturers.
"X            ""*."•              '                 '
Public Review Process

       According to the Japan  Environment Association,  "There  is no public participation on
the criteria setting process."  The EcoMark office asks for feedback on proposed criteria from
"several groups concerned with  the product category." (Hashizume, 1992a) JEA did not identify
the groups, but they are likely  the same groups represented on the committees.  EcoMark has
been criticized  since  "...the programme provides  for less  public participation than  in the
Canadian  programme,  and the  criteria  are generally  less  complex  than the Gentian
programme's." (Salzman, 1991)                                  ,
References

       Environmental Data Services,  1989.  Eco-labels:  Product Management in a Greener
       Europe, London.

       Hashizume, Shigeyuki, Japan Environment Association, 1992a. Personal correspondence
       with Abt Associates, May 12.

       Hashizume, Sh'igeyuki-, Japan Environment Association, 1992b.- Personal correspondence
       with Abt Associates, September 18.

       Hashizume, Shigeyuki, Japan Environment Association, 1992c.  Environmental Labeling
       in Japan:  The EcoMark, January.

       Japan Environment Association, 1991. The Ecomark System, September.
           -,.^                        '                        ,      ,               '
       Salzman,  James, OECD,  1991.   Environmental Labelling  in OECD  Countries,
       Organization for Economic Cooperation and Development, Technology and Environment
       Programme, Paris.        .

 Additional Reading

       CERES On Principle,  "Valdez Society of Japan Grows," Fall 1991.

       Earth Day News, "Rewriting  Social Commitment to Include Ecology," Tokyo, Japan,
 ,      August 1991.              .

                                          60

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Kilburn, David, 1991.  "Japan Goes Green", Advertising Age, Oct 7, p. 41.



Stillwell, E. Joseph, R. Claire Canty, Peter W. Kopf, Anthony M.  Montrone (1991).

Packaging  for  the  Environment, Arthur  D.  Little,  Inc.,  American Management

Association, New  York.
           '
                                   61

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THE NORDIC COUNCIL'S WHITE SWAN

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THE NORDIC COUNCIL'S WHITE SWAN


Introduction

       In  1989  the Nordic Council of  Ministers  introduced  a  voluntary,  positive,  and
harmonized Nordic environmental certification program. The logo for the program is based on
the emblem o? the Nordic Council, and displays a white swan Hying against a green background^
The words "environmental label" appear above the logo in Swedish, Finnish, or Norwegian  and
a short description of the relevant environmental attribute  appears  below,   pie first set of
criteria, created for low mercury/cadmium button cell batteries, was approved in. June 1991.
As of April 1993, criteria for 14 product categories had been established, with another 23 under
consideration:  Over 200 products  currently carry the White Swan logo.  (UNCTAD, 1993,
Nordic Council, 1993)
       According to the Nordic Cou^s  November  1991 position report,  "[t] he Nordic
 environmental label is  a neutral, independent label which guarantees a certain  environmentol
 standard.  Only  products  which satisfy strict environmental requirements  on the basis of
 objective assessments will be allowed to display the, environmental label.   The stated objective
 of the program are 1) to provide consumers with guidance in choosing products least hazardous
 to the environment, 2)  to encourage product development that takes into account environmental
 as well  as Gnomic and  quality considerations,  and  3) to deliberately  use market forces to
 complement environmental legislation.  (Nordic Council, 1993)

       The Mordic program is noteworthy because of its noVel administrative structure. While
 final  decisions  are  made  by  a Coordinating Group,  selection of product categories  and
 establishment of award criteria take place at the national level.   Currently, Norway, Sweden
 Finland, anc| Iceland are participating in the program.  Denmark is holding back,  pendmg the
 EC's decision on the development of an EC ecolabel.
 Structure
        The Nordic Coordinating Group for Environmental Labelling acts under the authority of
 the Nordic Committee of Senior Officials for Consumer Affairs and oversees the White Swan
 program.  The  Coordinating Group makes the final decisions on the  selection of product
 categories and award criteria. Each participating country has two representatives in the Group,
 and the chair rotates among the countries.

        Product categories and award criteria are established at the national level (see descriptions
 of individual Nordic country programs  below), although product categories are  occasionally
 developed in joint efforts between two or more countries.

        The program's agency in Norway is administered as a foundation,  while the Finrush and
  Swedish agencies are incorporated into the their national standardization organizations. Because
                                            64

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of Iceland's recent entry into the White Swan program, there is currently very little.information
on  its"program.  The four programs are highly harmonized to ensure smooth operation.  Fees,
structures, and processes are quite similar among the prograrns.
Award Process

       The Nordic ecolabel award process can be broken down into roughly four steps. Usually
only  one of the participating countries works on the development of a White  Swan product
category, ajthough occasionally two or more countries will work on one together.  Throughout
the process, the  individual agencies cooperate closely with the Nordic Coordinating Group.

Stage I: Choosing Product Categories

       Proposals for new product categories are handled by the program agency.in each country.
"Letters of interest" from manufacturers and importers are included as input by the program hi
-the decision making process.   Once a proposal has been made, the country from which the
proposal originated consults with the other Nordic countries to avoid duplication of effort. The
selection, of a new category must then be sanctioned by the Nordic Coordinating Group,  which
also decides which country will be responsible for preparing a proposal.  According  to the
Nordic Council, priority is given to proposed product categories which will affect significant
environmental problems.                                                             ~

Stage II: Setting standards

       The country assigned the project then performs a  background study and  drafts a set of
award requirements.  The requirements are defined by assessing the cradle-to-grave life cycle
of items in the product category, including "factors such as consumption 'of natural resources and
energy, emissions into air, water, and soil, and generation of waste." (Nordic Council,  1991)
The Nordic Council sets up working groups composed of "qualified experts," who "target and
determine the most important  environmental  impacts"  of the product  group in question.
(Norwegian Foundation  for Environmental Product Labelling, 1992)  In order to stimulate
progress in the development of environmentally sound products, the Nordic Council states that
the "criteria will be set as high as possible...and at least higher than the most stringent national
requirements."  These criteria include requirements for testing procedures and data reporting.
Criteria are developed with internationally standardized test methods in mind,  in order to
maximize test compatibility between White Swan and other programs.

        After product requirements have been drafted, the country sends the proposal to the other
participating countries for comment.  The original country then revises the proposal on the basis
of those comments and sends it to the Coordinating Group. _„

Stage HI: Coordinating Group Decision

        The Coordinating Group may accept, reject, or;.modify the proposal.  All Group decisions
must be unanimous. If a decision cannot be reached, the issue may be  referred  to the Council


                                           65

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         BJ§gram of the Nordic Council's White Swan Labeling Program
    Stage I: Product Categories
     Product categories are proposed i
     in each country by manufacturers I
    and importers (Norway), trie public"
         (Sweden) or the Board.      ,
             In consulation with the other countries,
                 the Board chooses categories
                 to pursue and assigns expert
                groups to establish draft criteria.
     Stage II: Setting Award Criteria
 Draft criteria are sent to the
other countries for comments.!
 The Board of thei originating >-
   country then makes any
          cfianges.          '
  "> Draft criteria are sent to the :
  j Nordic Council Coordinating!
-»j  Group. The Coordinating
   '  Group accepts, rejects or
   i   modifies the proposal.
          i   Once approved,
          •!   the criteria are
          1 valid in all countries.
     Stage III: Award Process
 Manufacturers in Nordic Council
  douritrief | pply for the award
   to the program in their own

        Approves;
   country.  Importers apply to
  ••»;the	program	In'trie"	country	
  that composed the criteria for
      that product category.
    In some countries, an applicant
!  rrtust submit data with the appliation. j
:}.' All	countrles	Rave	a	processing fee.
                                    Rejects
 Manufacturer signs three-year
   contract with the program
 that awarded the label, paying  j
a licensing fee based on product
 sales. The award is valid in all
   Nordic Council countries.
                                      66

-------
of Ministers at the request of a country.   •         •..,.•.     '.      -                ,

       Once approved.by the Coordinating'Group, a product category and its criteria are valid
.in all of the Nordic Council  countries.                                -

Stage IV: Awarding ecolabels                  .

       A manufacturer from  within a Nordic Council country seeking a product certification may
send an application to the program  agency  in his/her own country.  A foreign manufacturer
seeking an award applies to the country that developed the product category.  The individual   ,
countries manage the application and approval processes for specific products.  Once an award
has  been made to a product  by one. country, it may display the White Swan logo in any of the
other participating countries.                                                      .

        Criteria for a product category remain valid for three years.  After this period,  the
 criteria may be "changed, rescinded, or renewed for one year at a time," (Nordic Council, 1991)

 Process in Norway

        In Norway  the White Swan program is administered by an independent foundation set
 up  by  the Ministry of Family and  Consumer  Affairs in  1989.  The foundation consists of a
 Board, a Council, and a Secretariat.          •                                         .

        The Board is responsible for actual operation of the program and makes final decisions
        (at the national level) on product categories and criteria.  The Board's eight members are
        drawn from government (4 members), an environmental group (1), a trade union (1), and
        from  the federation of commercial associations (1).  Once the Board has  decided to
        pursue a product category, it appoints a broadly based expert group to define the award
        criteria.

        The Council is responsible for overall management of the program, including budgets
        setting up  activity guidelines, and handling complaints.   The Council consists of 19
        members, drawn from government (8  members), trade and industry groups  (5), and o
        more from environmental  organizations, trade unions,  youth organizations,  and the
        housewives' association. ,

  •     The Secretariat is responsible for day-to-day administrative activities.           .

         In Norway,  manufacturers and importers may propose new categories,  along  with
   supporting data.  If the Board  feels that a new category is worth pursuing  it will appoint an
   ex^rt group to establish  criteria for the category.   It should be noted that the  foundation
   receives no technical support from the government, aside from the expertise of sitting Board and
   Council  members.  All draft  criteria are sent out for review  on a broad basis  in Norway,
   Finland  and Sweden.  After the criteria  has been commented on by reviewers and the  other
                                            67

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'".;,  national  programs,  the proposal is submitted to the Board for approval.- If approved  by  the
    Board, the proposal is sent to the Nordic Council Coordinating Group for final approval.

         .The Board (through the Secretariat) also evaluates individual applications for certification. '
;'! i  Testing fees are paid by the applicant."" There is a certification fee of NOK 10,000 (about  US
    S1S50J and an annual sales, fee equivalent to 0.4 percent of annual turnover, with a minimum
    of NOK lOftO and a maximum of NIK 250,000.

    Process  in Sweden

          The White Swan program is administered in Sweden by the Swedish Standards Institution
    (SIS), a government  agency.   The SIS was chosen to run the program because  of 1)  its
    reputation for objectivity, 2) its' experience in establishing criteria, 3) economic efficiency, and
    4) the fact that  the SIS had already started to work with other  programs, thus easing future
    harmonization.

    The ecolabeling program consists of an Environmental Labeling Board, a Reference Group, and
i^,   • 'i1    , ' ' '  •  I!11"1!!!'!'!1'! •    ,    „    ,  ,  , ni '  ' •  , ' ' ,  •   ',",.,'	 "  „      "   ,    .    .              '
]":  "a Secretariat,1
;!»" ;     	      i!!'i:Jjjj:i  '        '! '                                      ' ;   , '          '
i   '          " f i'iiij )''.•!•                            i     I   •.  •    , ,i   :  •'   .•      .
    •      The Environmental  Labeling  Board  is responsible  for initial selection of product
          categories,  final approval of categories and criteria (before Coordinating Group), and
          estaf llshrnertt of regulations and fees. The broadly-based Board has ten voting members,
          drawn from industry, retailers, trade groups, consumers groups, and environmental
          groups. Decisions are by majority rule.

    •      The Keference Group advises the Board and meets twice a  year.  The members of the
          Labeling Board are also members of the Reference Group, which includes representatives
          from a large number of consumer, health, environmental, industry groups.

    •      The Secretariat oversees  individual license applications.

    In Sweden, any group or individual may propose a product category.  The Board decides which
    categories are worth pursuing,  and assembles an expert group to precisely define the product
    category, establish award  criteria, and  the appropriate compliance tests.  Like many other
    environmental certification programs,  the group examines a cradle-to-grave inventory of the
    environmentfl impacts of a product, but selects only the most  serious  impacts when considering
    award criteria, "After"the] award criteria has been ^commented on by the other national programs,
    the proposal Is submitted to the BoarS  for approval.  If approved by the Board, the proposal is
    sent to the j^prdic Council Coordinating Group for final approval.

          The SIS  Secretariat handles the mdividual Ucense apg^         The applicant must have
    test data that proves compliance to the criteria, and must also show that the production process
    complies with government standards.  An application fee of SEK 11,000 (around US  $1850) is
    paid when the application is entered. The applicant must also pay for testing, certification,  and
    a licensing fee dependent on product sales. The program plans to be self-financing within five
    years of the start date.  Sweden funds its program through a  loan.


      ••  • -•  , :,i      ,  ,i  v ' '"';v  ••••• •'••.;;:• ;:;."    68

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Process ,in Finland

       The Program'is administered in, Finland by an independent organization managed by the
Finnish Standards Association,:or SFS.  It began operation in 1990.

  -     The Finnish White Swan Agency consists of an Environmental  Labeling Board,  a
Reference Group, and a Secretariat.

       The Environmental Labelling Board - is responsible  for  initial selection of product
       categories, final approval of categories and criteria (before submission to Nordic Council
       Coordinating Group), and establishment of regulations and fees.  The Finnish Board  is
       similar to those of the other member programs, and has eight voting members, drawn
       from consumer, trade, industry, and environmental groups.  Decisions are by  majority
       nile.                                        "             ^

 •      The Consultative Reference Group is a 19-member grouplhat advises the Board.  The
       Consultative Group includes  representatives  from Government  (4  people), trade and
       ' industry  (6), consumer and environmental organizations (7), and research institutes (2).

       The,Secretariat is staffed by a department of SFS,  and processes individual license
       applications.    ,            .

 The Finnish award process and fees  are very similar to those of the other two programs,

 Iceland

        As Iceland  has only recently  started their program, there are very  few details available
 about it.

 References

        Nordic Council, 1991.   Environmental Labelling in  the Nordic Countries — Position
        Report,  November.

        Nordic Council, 1993.  Environmental Labelling in the Nordic Countries, April.

        Norwegian  Foundation  for Environmental   Product  Labelling,  1992.   Personal
        communication with Abt Associates, September 18.

        United  Nations Council on  Trade arid Development (UNCTAD), International Trade
        Division, Trade and Environment Section, 1993. Eco-labelling and International Trade:
        Preliminary Information from Seven Systems (Draft), prepared by  Veena Jha,  Rene
        Vossenaar and Simonetta Zarrilli, Geneva, Switzerland, May 19.
                                            69

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GREEN SEAL

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GREEN SEAL
Introduction

       Green Seal is an independent, non-profit organization "devoted to environmental standard
setting/product labeling and public education" in the United States.  It was established in 1989
and is,currently chaired by Denis Hayes, director of Earth Day.  According, to the Green Seal
organization, the program "helps identify, environmentally preferable  products  in order to
encourage and enable consumers to purchase such products and reduce their impacts on the
Earth."  The program in turn gives manufacturers an incentive to  improve the environmental
attributes of their products.                                                    .
        • •                 f.         '            .            ,      •.            ' •
       To date,  six standards have been finalized, with a number more in various stages of
development.17   In February 1993,  Green Seal announced the release of the fust five Green
Seal Certifications,  which will  appear on.bathroom  and facial tissue products distributed by
Ashdun Industries.  In May 1993, a Canadian-made water-efficient toilet was  certified.

       Since the Green  Seal logo has  only recently appeared on' products,, the effectiveness of
the program cannot yet be assessed.   In preliminary  market research commissioned by Green
Seal, four out of five consumers said they would choose a product with the Green Seal logo over -
a product without it, quality and price being equal.

Administrative Structure

       Green  Seal  employs 14 full-time  staff members  in Washington,   D.C.,  in  four
departments: standards setting, product certification, corporate development, and marketing and
administration.   A board of directors,  composed of business people, public figures and leaders
of  environmental, consumer and public interest groups, decide  overall direction  for the
organization.                                              '        .

       Green Seal has a standing contract with Underwriter Laboratories  (UL)  to be its primary
testing and factory inspection facility.  UL, founded in 1898, has an excellent reputation in the
area of setting standards for product safety. UL has 3,800 employees who conducted more than
74,000 product evaluations in. 1990.  They have more than 500 field representatives inspecting
factories in 74 countries.  (Green Seal,  1991)                               '

       An Environmental Standards Council, composed of independent scientists, academicians,
and other experts, acts as an appeals board for manufacturers and others who disagree with
Green Seal's technical judgements. In some cases, advisory panels composed of representatives
    17 Standards are formulated to cover multiple, related product categories, such as faucet aerators and showerheads.
 The six standards finalized cover a total of 35 product categories.

                                           72

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from businesses, government, academia, and the public interest community may be formed to
assist in the development of specific standards.

Award Process

Stage I: Selecting Product Categories

       Green Seal accepts proposals for product categories  from industry and the public, but
makes the final selection of new product categories for the program.

Stage II: Setting Standards

       At the initiation of the program in 1990, Grben Seal announced that it would conduct Life
Cycle Assessments (LCA) for the product categories it planned to test. However, this approach
is very  expensive (estimates range up to hundreds of thousands of dollars for each produc
Category),  and lacks a consensus opinion for correct procedures. (Holmes, 1991) Green beai
has instead decided to use an "Environmental Impact Evaluation" (EIE) for each product.  An
EIE is a shortened version of a fife cycle assessment designed to highlight the most important
environmental impacts of a product's lifecycle.  Standards are then set for the most important
points in the extraction, manufacturing, distribution, use and disposal stages of a product s We.

       To set a standard for a product category, Green Seal conducts an EEE,  and presents a
proposed standard for public review. The standards address one or more of the following issues:
toxic chemical pollution, energy consumption, impacts on water resources, impact on wiIdMe
natural resource consumption, impacts on the atmosphere, and global warming.  Green beal
enlists UL's assistance in designing standards, and in some cases will set up informal advisory
panels to  advise on  the development of specific  standards.  An independent Environmental
 Standards Council, made up of scientists and other experts,  hears appeals  from anyone who
 disagrees with Green Seal's decisions.

        Proposed standards are sent for comment to relevant parties, such as manufacturers, trade
 associations, environmental and consumer groups, and government officials, as well as to any
 member of the public who requests them.  The standard for compact fluorescent light bulbs, for
 example,  was  sent to approximately 1,000 reviewers.    After receiving  comments on  the
 proposal,  Green Seal revises the standards as necessary to reflect public comment.  As  ot
 January 1993, standards had been finalized for compact fluorescent light bulbs, rerefmed motor
 oU, tissue paper, paper towels and napkins, printing and writing paper, and water efficient
 fixtures   Standards for household cleaners,  windows,  household appliances, and  paint are
 currently  undergoing public review, with a number of other categories soon to follow. (Mager,
  1992)

        The products for which standards are, set must meet or exceed any applicable safety and
  performance standards, as well as all applicable environmental regulatory requirements. Green
                                            73

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Seal plans  to revise standards every  three years to  keep up with technological advances in
product fields and encourage continual environmental improvement,

Stage HI: Evaluating Products

       Underwriter Laboratories is "the primary testing and factory inspection contractor" for
Green  Seal.  They (or,  on occasion, another certified testing laboratory) will perform the
necessary tests and inspections to decide whether or not a manufacturer's product meets Green
Seal's standards.  Information on manufacturing will  be provided by companies who apply for
ecolabels, and proprietary information will be kept confidential.  The manufacturer pays a testing
fee to cover costs incurred by Green Seal and UL.

Stage IV: Awarding the Seal

       If a product passes all of the required tests and fully meets the standard, Green Seal will
award  it. the use of the  logo.  The logo may be used on the product itself and for product-
specific advertising.  It  may not be  used for general  corporate advertising.  If a product  is
awarded, the manufacturer must also pay an annual monitoring fee, in addition to the initial
testing fee.                                                               -•>'--

Enforcement of the Use of the Logo

       Green Seal retains ownership of the logo even after it is applied to a product. Contracts
for the use of the logo contain rules covering its proper use. For example, it  can be used only
on a product or in product-specific advertising.  "Green Seal will actively monitor the use of the
seal... and take any necessary legal action to stop unauthorized use of its mark." (Green Seal,
 1991)   Alsor Green Seal  requires  that manufacturers be monitored periodically to ensure
continued  compliance with the standards.   Green Seal may perform  follow-up  testing and
monitoring, which  may  include unannounced inspections.

References
                           /                  ,   .    .                       -

        Green Market Alert, 1993,  "Green Seal Update," May, p. 11.

        Green Seal, 1991.   "Green Seal/UL Alliance: Questions and Answers," and additional
        promotional materials.                                      ..•'..'..

        Green Seal, 1993.  "Green  Seal Announces First  Certification Mark,"" press release,
        February 10.

        Holmes, Hannah, 1991. "The Green Police,"  Garbage, September/October, p. 44-51.

        Majer,   David,  Green  Seal,  1992.   Personal communication with Abt  Associates,
        September 25.

                                            74

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Additional Reading

     ;  Fisher, Clinsty, 1991  ^'Seal of Confusion," Advertising Age, June 24.

       Hayes, Denis, 1990. "Harnessing Market Forces to Protect the Earth," Issues in Science
       and Technology, Winter 1990-91, p. 46-51.
                                            75

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    SWEDEN'S GOOD



ENVIRONMENTAL CHOICE

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SWEDEN'S GOOD ENVIRONMENTAL CHOICE
  i,' ' ',     :,i','	iil'i •; '"' ' ,                                           ,,        : '       ,.'•,','
  "!   ""  ' "''ll '"",'"'             I    I          I      ll     '         '• . ' •         "   '
       In  additipn to the  Nordic Council's White Swan Program, a private environmental
certification program called "Good Environmental Choice" (Bra Miljoval)  has been active in
Sweden since 1990.   Administered by  the Swedish Society for the Conservation of Nature,
Sweden's  largest environmental organization, the Good Environmental Choice evolved into a
product and shelf labeling program from what was originally a guide to environmentally sound
sapping published by the Society in 1988.  In 1989, the Swedish Cooperative Federation (KF),
one of Sweden's largest retailers, initiated a shelf labeling program that encouraged the purchase
of goods recommended by the Society's guide.  By the end of 1989, the two other largest
Swedish re|ailers, ICA and Dagab, joined  with KF in sponsoring an ecolabeling scheme that
became the Good Environmental Choice Program.

       Lilce many other ECPs,  Good  Environmental Choice  selects product categories and
qualifying criteria. After analyzing a resource impact matrix for a particular product category,
the most important aspect (e.g., bleaching  for paper  products)  is identified as the basis of the
criteria.  	          	      ,	 -	;,

       Good Environmental Choice seems to have been very successful by some measures.
According;'to a report by trie; Organization for Economic Cooperation and Development (OECD),
the retail  stores  at which over 80'percent of all Swedes shop "have environmentally labeled
goods m  tie' paper products;  laundry detergent, and battery categories." (Salzman,  1991)
Despite this success, the current status of the program is  somewhat unclear. While a study by
the  U.N;Commission  on Trade  and  Development  (UNCTAD) reports  that the  Good
Environmental'Choice  program was  initiate^  by  retailers to  provide a more  "dynamic"
alternative to thei'White Swan (which; they feel is overly  influenced by  industry interests), the
OECD: report states'that S» Good Environmental Choice program planned to cease issuing labels
once the White Swan became fully operational. (Salzman, 1991; UNCTAD, 1993)

Structure

       The Good Environmental Choice Board selects the product categories. The Board is
composed of representatives of the  Society for the Conservation of Nature, as  well as  one
 representative from  each of the sponsoring retailers.

        ike Society far the Conservation of "Nature developscriteria for each product category.
 In this process, the Society may consult universities, public authorities, and occasionally private
 businesses.                                                   :'

 Process

 I.      The Good Environmental Choice Board  select the product categories.
                                           78

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H.     The Society for the Conservation of Nature  develops the product category criteria In
       consultation with other organizations.

D3.    Applicant manufacturers must declare the composition of their products to the Society.
       Products that meet the criteria may be displayed on special shelves showing the Good
       Environmental  Choice logo.  As costs are borne by the Society and the participating
       retailers, manufacturers are not required to pay a fee to have their products displayed on
       the Good Environmental Choice shelves. If a manufacturer wishes to  have a product
       ecolabel, however, license fees of SKOR 5000 (about US$600) are assessed for the first
       product under license and SKOR ,1500 for each additional license.  (UNCTAD, 1993)
Product Categories

       As of mid-1993, the Good Environmental Choice program had developed criteria for the
following 12 product categories:

       •      All purpose cleaners
       •      Heavy duty cleaners                                          '    .  >
       •      Toilet cleaners                 -     ,         •
       •      Detergents for white cloths                                         '
       •      Detergents for colored cloths
       •      Stain removers                       .  .   .  ~                        ,
       •      Hand detergents for dishes
       •    ;  Machine detergents for dishes
       •      Shampoos                                                           •'.
       •      Batteries        ,               .         •            .
       •      Diapers
       •      Paper and paper products -.'•._

 References

       Salzman,  James,  OECD, 1991.   Environmental Labelling  in  OECD  Countries,
       Organization for Economic Cooperation and Development, Technology and Environment
       Programme, Paris.

        United Nations Council on Trade  and Development (UNCTAD), International Trade
        Division, Trade and Environment Section, 1993.  Eco-labelling and International Trade:
        Preliminary Information from Seven Systems (Draft), prepared by Veena Jha, Rene
        Vossenaar and Simonetta Zarrilli, Geneva, Switzerland, May 19.
                                           79

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ENVIRONMENTAL CHOICE NEW ZEALAND


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ENVIRONMENTAL CHOICE NEW ZEALAND                           ,  " "'

       New Zealand officially started its  Environmental Choice New Zealand program on July
10, 1990.   The program  is  a voluntary seal-of-approval  program,  much  like  Canada's
Environmental Choice Program or Germany's Blue Angel. The stated objectives of the program
are: provide an incentive for manufacturers and importers to reduce the environmental Impacts
of products sold  in New Zealand; to recognize the genuine moves by companies to reduce the
adverse environmental Impacts of their products;  to provide a clear, credible and independent
guide to consumers wishing to take account of environmental factors in their purchase decisions;
to encourage  consumers to purchase goods that  have lower  environmental impacts; and
ultimately to  improve the quality of the environment and to  encourage  the sustainable
management of resources. (Minister for the Environment, 1992)

       In March of 1992, the  Environment Minister announced the  release of the first three
product categories: products made from recycled plastic,  carbon zinc batteries,  and zinc air
batteries.  He also stated Environmental Choice's intention to work closely with the Australian
Environment Ministry to harmonize the two countries' ecolabeling programs. (Minister for the
Environment, 1992) Since then, product category specifications have been published for refined
lubricating oil,  laundry detergents,  machine "dishwashing detergents,  hand  dishwashing
detergents, lead acid batteries,  and  paints.

       In setting up Environmental  Choice New Zealand, the government wanted to ensure that
the program  be  credible, practical, independent and nonpartisan, and comparable to other
programs such as Environmental Choice Australia and Canada's Environmental Choice Program.
To harmonize and coordinate  with Environmental Choice Australia  and other programs, the
program intends to consider closely  the award criteria and methodology of other national
programs during its own program development.         ,                   .

Structure

       Environmental Choice  New Zealand  is  administered by  Telarc,  the-New  Zealand
Accreditation  Authority  for Quality Assurance,  Laboratory  Testing, and  Industrial Design.
While Telarc is a statutory body and includes government appointees,  it operates independently
and is  self-financing.               ;

       A working group from Telarc  has established the Environmental Choice Management
Advisory Committee  (ECMAC) to provide advice to the Telarc Council.  ECMAC is a ten
member,  broadly-based committee,  with  representatives  from manufacturing,  retailing,
packaging, and environmental groups.  ECMAC also includes representatives from the Ministry
for the Environment and Consumers Institute.
                                           82

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•'!      iiii'ii '    ' '  '  "   	s;1  '   •  '   "   ,'!'" •• ..,:',.,,'•                         i  •     •    ,    .
   Award Process

          According to Environmental Choice New Zealand, "a product may be certified because
   it  is made r a Way  that improves energy efficiency,  reduces  hazardous  by-products  uses
   recycled ma^l^r because the product itself can be reused or  is otherwise environmentally
   preferable." (Minister for the Environment, 1992).
     '•V
   Stage I: Choosing a Product Category

          ECMAC fi Responsible for choosing suitable ^urt^^for^viioninent^ Choice
   New Zealand.  Once ECMAC has decided upon a product category, it sets up a Task Group to
   develop a specification for the category.

   Stage H: Developing the Specification

                 ask Group  set up by ECMAC is responsible for developing  an appropriate
                    the prLct ca&goV" According to Environmental Choice New ™  £
                 in the Specification "are based on information available at  the time and  are
             as  new information  and technology make more stringent ^mcn* ££?£•
    Sets are expected to meet all applicable governmental safety and perfonnance regulations,
    as weU as perform as  effectively as is  "generally expected of products m their category.

           After  the Task Group has completed a draft of the Specification, ECMAC releases the
    documem for pubiic comment.  The public comment period lasts for at least 30 working day£
    ^ S Gro'up then takes these comments and  revises the  Specification, after ^tach the
    document is referred to ECMAC. ECMAC, in turn, recommends the requirements to the Telarc
    Council.

    Stage HI: Telarc Decision on Specification Requirements

            The Telarc Council then decides whether to approve the specification for publication.

     Stage IV: Awarding the Environmental Choice New Zealand Mark

            Product suppliers, which  may  include manufacturers,  importers,  wholesalers,  and
     retailers  may  appfy  for certification  as  soon as product category specification has  been
     published.

            Telarc may require product testing performed by a Telarc-registered laboratory,^ and/or
     examination of the Levant manufacturing records to verify that a product meets the product
     category specification.
                                               83

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      ' If Telarc is  satisfied that a  particular product complies  with  the  requirements, the
applicant is granted a license to use the program's logo, the Certification Mark.  Applicants pay_
an application fee, and if a product is accepted, an annual  licensing fee as well.  Licensing fees
are calculated on a sliding scale depending on the sales volume for that product.

       Licenses are valid for at least two years,  subject to the payment of fees and continued
compliance, which is monitored by Telarc throughout the period.  Telarc will give licensees 12
months notice before revising product category specifications.

       As of April 1993 only one application has been received,  and that applicant has been
licensed to  use the certification Mark for paint;

References                                                                  .

       Minister for the Environment, 1992.  Media Statement March 18.

       Ministry for the Environment, 1989.  Labelling of Environmentally Friendly Goods: A_
       Discussion Paper.

       Telarc,  1992.  Environmental Choice New Zealand: Environmental Labelling in New
       Zealand, Document EC 010, Issue No.  1,  February.

       SaLzman, James,  OECD,  1991.    Environmental Labelling  in  OECD Countries,
       Organization for Economic Cooperation and Development, Technology and Environment
       Programme,  Paris.                       ~
                                          84

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   if-;!!
   . (.:' II!

   ii'.:1'	iii
INDIA'S ECOMARK PROGRAM
   Ir'l"

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INDIA'S ECOMARK PROGRAM
                                   '        '       -          '           ,              '
Introduction.

       A resolution passed by the Indian Parliament on February 20, 1991, instituted a voluntary
"Scheme on Labelling of Environment  Friendly Products."   (Ministry of Environment and
Forests, 1991)  Like Japan's program, the Indian program is called the Ecomark, although its
administrative structure is closer to Canada's Environmental Choice Program, with government.
taking a dominant role.                    .      <  ,

       The program "provides accreditation"  to household and  consumer products that meet
specified environmental criteria,  along  with  quality requirements of the Bureau of Indian
Standards.  The objectives of the program are  1) to provide an  incentive for manufacturers and
importers to reduce adverse environmental impacts of products,  2). to assist consumers to become
environmentally responsible in their daily lives  and to encourage them to consider environmental
factors in their purchase decisions, and, 3) ultimately, to improve the quality of the environment.

       As of May 1993, 16 product categories  had been or were being  developed, although
"response of the industrial sector [was] slow."  Applications had been made for only two product
categories,  soaps and detergents. (UNCTAD,  1993)

Administrative Structure

       The program is administered by three bodies.  The first, a Steering  Committee, has been
set up in the Ministry of Environment and Forests, and will be composed of 12 representatives
of different government offices and "not more  than five" representatives of "industry, consumer
groups or other non-governmental organisations." This committee is responsible for determining
product categories, promotion and general oversight and development of the program.

       A Technical Committee determines the criteria for awarding the Ecomark logo,  and is
composed primarily of representatives  of government research  and  standards setting offices.
Like the Steering  Committee, "not more than five non-officials" join the seven government
employees.  The Technical Committee is based in the Central  Pollution Control Board in New
Delhi.                                                                   .

       The third body is the Bureau of Indian Standards (BIS).  The BIS assesses and certifies
products according to criteria set by the Technical Committee.  It also handles the licensing of
the logo, enforcement of rules, and collection of fees.

Award Process

       In the  resolution,  the Government of India left most  of the  details of the program's
operations  up to the committees to formulate. They did specify that a licensing  fee would be
charged for each period of use, that the certification testing should take less than three months
and that it would be performed  by the BIS.   In the formulation of product criteria, there is a


                                           86                               ,

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public  review period,  in  addition to  Technical  Committee considerations.  The Technical
Committee musTconSider the "main environmental impacts" of a product, mcluding.

       •     potential for pollution in production, use, and disposal;

       •     recyclabiiity, recycled content, and biodegradability;
       •  '  i' •.';;.:,  '-si!  : • •.  i •' i. •  •  .; .;.', ,"•• ' - •;; i ,'.;•'. ti;  ;. •, ';   ••.!./. p.'/  ':,. • it1".; ...         ,    .
             decreased  use of non-renewable  resources,  including  non-renewable energy
                >•  iraii  i  "j
              sources; and
              decrelsed impact in the area of greatest environmental impact for that product
               '. !!• • * i" ....... Ill i  . i, • i'  *[ „ , ,      ,,  ,  „    , , , .,
              category.

       Although the resolution makes no mention of life cycle analysis per se, it does list most
 parts of a product's life cycle in a list of considerations for "determining tta , pnrn.ary cn^ena  or
          " The list includes sources of raw materials, energy used and materials wasted in me
                 ul of recycled, recyclable and biodegradable material, and impacts of produc
                isposal.  (Ministry of Environment and Forests,  1991)   In practice, product
                sefon "oriy a few criteria [that] were found to be -st^Porlant ^espec !ally
 those relating to "energy and resource saving production processes.  (UNCTAD, 1993)

        Fees are chlged by the BIS te^^                                        Although:
 the liceSte "* not very high," testing can cost up to $1,700 depending on the complexity
 of t£S c5NCTAD,1993)  "This figure is quite high for a small scale enterprise,"  but no
 mention is made in the resolution to adjust the fees for small businesses.

 Public Review

        Like Canada's Environmental Choice Program, the Ecomark program allows for a 60-day
 public £Sw£riod  of draft criteria for product categories.  The criteria are P^^m the
  Gazette  of India,  an official government publication.   "So far  the response to  the  gazette
  notification of the criteria has been very low." (UNCTAD, 1993)
  References
         Ministry of Environment and Forests, Department of Environment, Forests and Wildlife,
         1991.  Resolution, published in The Gazette of India, No. 71, Part n, Section 3, Sub-
         section i, New Delhi, Thursday, February 21.

         United Nations Council on Trade  and Development  (UNCTAD)  International Trade
         fifcSm, Trade and Environment Section, 1993.  Eco-IaMOng ana [^ernano^ Trade^
         Preliminary Information from Seven Systems (Draft), prepared by Veena Jna,  Rene
         Vossenaar and Simonetta Zarriffi, Geneva, Switzerland, May 19.
                                             87

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KOREA'S ECO-MARK SYSTEM

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KOREA'S ECO-MARK SYSTEM

      Thq  Korean  Ministry  of  the  Environment  launched its  Eco-Mark  environmental
certification program on June l", 1992, announcing fourrecycled-content products at that time,
with eight other products being added in November.  At the time of this writing, 96 products
within those 12 categories have been awarded the Eco-Mark.  The Korean Academy of Industrial
Technology (KAITECH) assisted  in the development of the program, providing technical
assistance for the development of draft criteria "more than 50" product categories.

      The Korean Eco-Mark's approach to product certification is based on defining the single
most important criterion for each product category. The Eco-Mark has found that the large data
requirements for the life cycle approach are difficult to meet in practice. (UNCTAD,  1993)

Structure	      ^     .      ,  . i	''

       Thekorean Ecq-M&rk systemL is 'admmi&terod'by the Ministry of the Environment.  New
product category suggestions are directed to the; Technology Development Division of  the
Ministry.  The  "EPA" acts  as  a secretariat for the program.   The EPA is  made  up of
representatives   from   industry   and  business,  consumer  organizations,  environmental
organizations, quality testing authorities and  experts.  (UNCTAD,  1993)  The EPA conducts
public hearings on the draft criteria,  accepts public comments, and revises the criteria based on
the received comments.

       the "Eco-Mark Committee makes the final ^election of  product categories, and prepares
the draft criteria for the selected product category.  After the EPA has made revisions to the
criteria bajid on public comment (see below), the Eco-Mark Committee makes the final decision
on the criteria.  The 13-15" member committee is comprised of representatives from consumer
organizations, industry representatives, environmental preservation organizations, inspection
units, scientists, legal experts, and public health experts.

       An Eco-Mark Assessment Committee (EAC)  is set up by the EPA for each applicant to
 review the applicant's product.

 Award Process

 Stage I: Development  of Product Categories

 1.    Suggestions for potential product categories are directed to the Technology Development
       Division of the Ministry of the Environment.   New  categories may be suggested by
       government, manufacturers, business, or the general public.
           nil    •   .•• ., ii	' ':!' i •,, ••; 	sv.n .'.,.' •,?•:,••	,,;;, 	„	v ,, 'iiir-i,,11 '•'• ••••••,,
 2.    With assistance from organizations  such  as the Korean Institute of  Science  and
       Technology  (KlST) and the Korean  Institute  of Advanced  Science and  Technology
                                         : 90

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      (XlAST), the Ministry prepares an advisory document, and submits it to the Eco-Mark
      Committee.                ,'..••-'.

3.     The Eco-Mark Committee makes the final selection on the product category and prepares
      draft criteria for that product category.  These draft criteria are presented to the EPA,

4.  '   The EPA conducts a public hearing on the criteria, publishes the proceedings and
      receives comments.  The EPA then modifies the criteria  based on these comments.

5.     The EPA submits the amended criteria to the Eco-Mark Committee.  The Committee
      makes the final decision on the criteria for the product category.

6.     The EPA publishes  the  final  criteria in the Eco-Mark Newsletter.   The Ministry
      communicates the final criteria to the general press. ',-   ,'"."..

Phase n:  Evaluating Applicant Products and Awarding the Eco-Mark

 1.     The applicant manufacturer submits its product for evaluation to the EPA.

 2.     The EPA assembles  an Eco-Mark Assessment Committee (EAC),  which reviews the
       application.  The EAC is comprised of 6 experts from various testing agencies.

 3.     The EAC assesses whether the applicant product meets  the criteria. The EAC reports
       its decision to the EPA.

 4.     If the product qualifies for the Eco-Mark, the EPA draws up a two-year contract with
       the manufacturer.

 5.     Depending on the sales of the product, the manufacturer pays a fee ranging from 300,000
       won to, 1,000,000 (approx. US$400 to US$1250).

 Product Categories

       As of May 1993, the Korean  Eco-Mark has finalized 12 product categories (see table
 below).
                                          91

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Korean Eco-Mark Product Categories
Prcxluct Category
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
Products made with reused paper.
Tissues made with reused paper.
Reused plastics
Aerosol sprays without CFCs.
Reusable diapers.
Non-asbestos brake lining.
Aluminum cans with stoppers.
Filter for kitchen sinks.
Non bleached and un-dyed towels.
Water valves.
Packaging materials using wastes.
Criteria
Should contain >50% reused
paper.
Should contain >50% reused
• paper.
Should contain > 60% waste
plastics.
Should contain 0% CFCs
Should contain' 100% cotton.
Should contain 0% asbestos.
Should use aluminum.
Should have small holes < =
1.5mm diameter. .
Should be made without dyes or
bleach.
Water should not run after valve is
closed.
Should be made with 100% wastes.
Soap made with waste edible oil. Should be made with >50% waste
edible oil.
Source: UNCTAD, 1993.
References	,	^    ;	•      ,   '        . . ;

Hwang, Kyoo-Won, Korean Academy of Industrial Technology (KAITECH), 1993.  Personal
Communication with Julie Lynch, U.S. EPA, April 28.

United Nations Council on Trade and Development (UNCTAD), International Trade Division,
Trade and Environment Section, 1993. Eco-tabelUng and international Trade: Preliminary
Information from Seven Systems (Draft), prepared by Veena Jha, Rene Vossenaar and Simonetta
Zarrilli, Geneva, Switzerland, May 19.

    •   ••   '•! •!'.   ' • . :  :"!:;   ••'V;'.V:-/ : '""92	

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      SINGAPORE'S
GREEN LABELLING SCHEME

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                            I,/:; a
               SEN'G.AJL'ORE'S GREEN LABELLING SCHEME

               Introduction
              "'•!, •  ,  •	  •   i ; i    : ,    .•  : ,. :;:  ,   /  ••	• .••;'!    . ./• 
-------
 Award Process

       Products that meet the criteria for the appropriate product categories are allowed to carry
 the GreenLabel.  Foreign and domestic companies may participate in the program in the same
 way.                               .                       _          .

 Stage I: Choosing a Product Category

       The  Secretariat identifies and defines potential product categories,  which may  be
 suggested by the public.  The Secretariat legally chooses product categories which cover "mass
 consumer items."  (Loo Hak Jan,  1993)

 Stage II: Developing Draft Criteria

       Once a product category has been defined, the Secretariat organizes a workgroup to
 produce a draft qualifying criteria document. The workgroup is comprised of experts from the
 Ministry of the Environment and various academic institutions.

       The criteria are then provided to the Advisory Committee for discussion.  The Committee
 organizes technical meetings with industry experts to discuss the validity and suitability of the
 draft criteria.                                             .

 Stage El: Soliciting Public Feedback

       The revised draft  criteria are  then  released  to the public for comment.  The public
 comment period is usually 30  days, during  which time interested parties are invited to  submit
 written comments  to the Secretariat. The Secretariat collects the comments and forwards them
 to the Advisory Committee.

 Stage IV: Finalizing Qualifying Criteria

       After considering the comments received from the public, the Advisory Committee either
 revises the criteria or approves the original draft.  The finalized criteria are then sent to  the
Approving Board  for final approval,  after  which the qualifying criteria are published.  The
Approving Board is headed by the Permanent Secretary of the Environment.       ,

Stage V: Awarding the GreenLabel

       After the qualifying criteria have been finalized, companies with products that fall under
the product category specification may apply for the GreenLabel. Applicants  obtain application
kits which lay out the terms and conditions for approval and the use of the GreenLabel.  During
the verification process, the Secretariat may require access to quality control and production
records.  Samples of the  candidate products must be tested by accredited laboratories to  see
whether or not the qualifying criteria are met.  With products where criteria testing in the lab


                                         95

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  is difficult (e.g.  recycled paper content''in a paper" product), a "declaration from  the Chief
  Executive OCfiger or equivalent is required instead." (Loo Hak Jan, 1993)

        An approved product is granted a license to carry the GreenLabel logo for three years.
  From time to time, the Secretariat may opt to review and revise qualifying criteria to keep up
  to date with the latest technological developments.

        If a manufacturer applies for'certification' for a product within a year of the date of the
'(release"of"the"Final Qualifying Criteria, he/she does not pay any  fee for the first five years.
  After ttia| timej ^Annual License Fee is required.  If a manufacturer applies after a year of
  the date of the release of the Criteria, then an  application fee of $20.00  is required.  The
  manufacturer is still exempt from the License Fee for three years,  after which it must be paid
  every year.  "	  '   	 	        ..."     ,  , • '       "L-

  References	11	i  ,   	 	, ,,...'.,

        Loo Hak Jan, Engineer for  Secretariat,  1993.   Personal Communication with Abt
        Associates^  May 29, 1993.

        Ministry of the Environment,  1992.  Resource Conservation Bulletin No.  1, May 1992.
        ISSN \ 0218-3358.

        United Nations Environment Program, Industry and Environment Office,  1991.  Global
       • Environmental Labelling: Invitational ^Expert Seminar,  Working Group on-Policies,
        Strategies and Instruments, held in Lesvos,Greece, September 24-25.

         Wanner Bulletin, 1993.  "Singapore Scheme," p. 2, no.  36, February.
                                             96

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THE EUROPEAN COMMUNITY' S ECOLABEL

-------
              EUROPEAN

              Introduction
             '",,!•    ,•       Hi:1'":!!'  .   ,    • . ' • i i1'1!"1  '"  i ''•   . :.'" \ . '• • '' .!•• •!•' 'i 'T'i' ' -.I ,.,: " i111 .t1 i ' ,,.''.I,,	I!,,.,1 ' •, •("' „ '„    ,•  • • ,           '     , ,
                     On March 23, 1992, the Council of Ministers of the European Community adopted a
              regulation for an EC "eco-label award scheme."  The program is intended to "promote the
              design, production, marketing and use of products which have a reduced environmental impact
              during their entire  life cycle, and provide  consumers  with better  information  on the
              environmental impact of products." (European Community, the Council, 1991) The program
              Will be effective in all twelve EC member states, and individual states will be largely responsible
              for the process of evaluating products and making awards.18
                     The program stresses that the quality of products awarded cannot suffer as a result of
              their reduced environmental impact, and that an assessment of products must be based on a
1   . , i  , '     : t!, : .  : •< ':  ,,:«,  • un ' (	 ,, .1  . ri	I1;1"-	'f	 ! 	 	 .,•	*,	'	
              complete scientific evaluation of product categories from "cradle to grave."  The Commission
              of the European Communities has been given the objective of launching the Community Ecolabel
              Award Scheme in June of 1993.

              Administrative Structure

                     Many parties are involved in setting evaluation criteria and in awarding ecolabels:

              *      The EC Commission is composed of 17 representatives: one per country with two each
                     from the four largest countries, and one president.  The Commission is the center of
                     activity  for  the program, facilitating  the  process, and seeking guidance  from and
                     consensus among all the other parties. The Commission decides what product categories
    ':'   '     ";  ' '    to cbhsiier.       	,  ,'   	.","",  '	','  '   "	'

              *      The  Consultation  Fprum is composed of the principal interest groups,  including
                     Community-level representatives of industry, commerce, consumer organizations, and
                     environmental organizations.   (The  two  former  groups  may include  trade union
                   /.representatives as  well.)   The Commission consults  the Forum  members  before
                     submitting the draft criteria  to the Regulatory Committee of Member  States for final
                     approval.  In addition, interest groups  are consulted hi the earlier stages of preparing
                     proposals.

              •      Competent Bodies are set up within eachi Member State: of the EC. Competent Bodies
                     accept proposals for product  categories,  which they  review and pass along to  the
                     Commission.   The  Commission then assigns specific  product categories  to "lead
             ,i-i       ,.•  ••:•  liiBio ,,T•! •.< •,i"	•:.!il,-j	!..•«	i, "	"V/T,-'	I'm1 |l!'*1;	• •!•.&	*;..	f	    ,          .   .
                     countries"; Competent Bodies in each  lead country investigate  that category with life
                     cycle analysis. From this analysis, they develop draft criteria for product standards.
                 "EC member states are Belgium, Germany, France, Italy, Luxembourg, The Netherlands, Denmark, Ireland,
              United Kingdom, Greece, Spain, and Portugal.
             ''               i'      *       "           ' '   	•       	.

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      Once the criteria have  been considered by  the Consultation Forum voted on by  the
      Regulatory Committee,  and  adopted by the Commission, Competent Bodies can accept
      applications from manufacturers, collect testing fees and conduct tests as necessary on
      products. Awards given to products must be approved by all Competent Bodies, via the
      Commission. Competent Bodies then sign a standard contract with manufacturers, assess
      licensing fees and monitor the proper use of the ecolabels.

      The Regulatory Committee of Member States is chaired by  a non-voting representative
      of the Commission.  The Committee has final approval of criteria for product categories
      and settled any  reasoned objections  made by Competent Bodies to a manufacturer's
      application for the award.

      The Council of Ministers  is  the primary legislative body of the European Community.
      For the eco-labeling program, the Council only acts  to decide on proposed criteria or
      awards rejected by the Regulatory Committee.
Award process

      The EC ecolabel program can be arranged into three stages, as illustrated in the flow
chart diagram.

Stage I: Defining Product Categories

      Any  interested party, any Member State or the EC Commission itself can  propose a
product category. The EC Commission must then approve of categories to be investigated by
member states.  A "lead country" is assigned to perform a life cycle analysis and set  guidelines
for that product category,  with the subsequent approval required of other EC members before
it becomes a community-wide standard.19

      The EC has formulated an "indicative assessment matrix" to evaluate products and to set
criteria for product categories.  This matrix, presented below, indicates the five stages in a life
cycle, and the potential environmental impacts in those stages. (European Communities, the
Council,  1992)
Stage H:  Setting criteria

       After the Competent Body analyzes the product category, it submits draft criteria to the
Commission, which consults with the Forum and passes the criteria to the Committee of Member
States  for consideration.  If approved by the Committee of Member States, the guidelines
   19  One motivation for the requirement of approval of other EC members is to overcome the fear of national
favoritism in awarding ecolabels to products from that country.

                                          99

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	i,	•
Indicative Assessment Matrix
Environmental Fields
Waste Relevance
Soil Pollution and
Degradation
Water Contamination
Air Contamination
Noise
Energy Consumption
Effects on Ecosystems
Product Life Cycle:
Pre-production
„
Production

Distribution
(including
packaging)

Utilization


Disposal

  1      "'  • •"   i1   »"'. "                                 ii   ,            •                 •'• •-•
  become official.  If there is no consensus within the Committee, the Council of Ministers renders
  a final decision.

  Stage JH:  Awarding products
              n!'"#  ,,,r  ""  '."••" "i'1'1 i»"ii.1 "  " .::  .  '""	:"'' "' !'" i1  ,•','"  „ '' ...i,,  , '.ii .,i ',.•!' • ' '",!'  ,'".,
          Applications are accepted by Competent Bodies of member states, in the country where
  the product is "manufactured, first marketed or imported to within the EC. The regulation states
  that the results of independent testing must be submitted with the application. It is expected that
  in the long term, a standard methodology for assessment procedures wUl be agreed to by all the
  parties involved.  In the interim, arrangements  are being introduced on a product-by-product
  basis. (ENDS Report, 199Ic)

          Throughout the award process, the confidentiality of applicants is maintained,  as this is
  considered proprietary information.  Awarded products are listed in the official publication, the
  EC Journal, and may use the flower logo generally for three years.  At that time, they will be
   reassessed in light of any  changes to the standards.  There is an application fee of 500 ECUs to
  cover'administration costs, and, if the product receives the award,  an  annual licensing fee
  calculated as 0.15 % of the annual volume of sales within the EC. These are guideline figures;
   Competent Bodies have the discretion to set actual  fees at levels 20 percent greater or smaller
   than the guideline figures.                      ;

   Public Review Process
      V' •   "   'ill:  '.  ; /'. • h-;;y"••;••.:;',•;•;::uv :.>::•'; <••;, ;•.(;  :,;?  /;.>t-:^      \..        -         •'.. •
          To ensure public access and review  in the ecolabeling process, the EC has included the
   Consultation Forum  of  interest groups,  composed of environmental and consumer groups,
                                               100

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           -Diagram of European Community Labeling Program
     Stage I: Establishing Product Categories'
   Anyone may suggest product
I  categories to EC or Competent
; Body. (Competent Body consults
i             '       - -     '  '
I   • with interest groups in their
!  country before passing it to EC.)
            Commission reviews
                proposals in
              consultation with
           I1'-™
           | Consultation Forum
             of interest groups.
              Commission chooses  !
             categories and assigns !
               them to Competent
             Bodies to conduct LCA
               •'•""
               and create criteria.
     Stage II: Setting Award Criteria
   Draft criteria come
  back to Commission
   which consults with
   Consultation Forum
     about criteria.
 I Sent to Committee [-
•i of Member States j
 i   for approval.   r
-j Approves;
Commission adopts)
   the measures,  r
  Rejectsj-
Commission submits
 proposal to Council
of Ministers. Council
vote is final decision. 1
     Stage III: Award Process
     Manufacturers apply to
   Competent Body in country
 where product is manufactured,
   imported or "first marketed.*
         ! Approves
          ! Rejects
     Passed on to Commission
   which allows other Competent
      Bodies to review award.
   j Objection
  Commission negotiates informal   j—-*»j Rejects  !
   agreement between parties. If
agreement is not reached, application
  goes to Committee of Members.
                                                            [Approves j
    No objection
                                                                i
        Commission allows Competent Body
        to award label, collect fees and sigh standard contract.
                                    101

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   NETHERLANDS' STICHTING MILIEUKEUR
                   i1!!,, •'! ''••• ' .1
I
I11"
i


i •

-------
industry, and commerce.. The original proposal would not have included this group, and w
have given much less  authority  to  the Competent Bodies.   The European  Bureau'of the
Environment (EEB) and the European Bureau of the Union of Consumers (BEUC) lobbied to
have more say given to the environmental and consumer groups, due to the "ethical and societal
choices  involved", recommending even the power "to veto a decision...,contrary to sustainable
development."  They also requested a right of individuals and groups to appeal awards  any time ,
after the award has been given.  Finally, they stated that "every consumer has the right to be
informed of the  principal reasons for granting the eco-label", and to this end  suggested an
ecolabef with "full environmental information, i.e.  qualitative  and  quantitative  ingredients
composition, processing procedures, re-use and/or recycling facilities." (EEB and BEUC, 1991)
The first of these requests was granted by the EC, but individuals per se can only participate
through the Consultation Forum .representatives and by proposing product categories to the EC
and Competent Bodies.

References

       BNA Daily News, October 20, 1992.                               '

      .ENDS Report,  199la.  "Advisers  Criticise Government for Delay on Eco-labelling",
       September 1991.

       ENDS Report, 199Ib. "Delay with EEC Eco-labelling Proposal Prompts UK Concern",
       issue 192, January 1991,

       ENDS Report, 199Ic. "EEC Eco-labelling  Scheme Ready to Roll", No. 203, December
        1991.                                                              -

       ENDS Report, 1992.  "First Product Groups for EC Eco-labelling Scheme", issue 205,
       February 1992.                           •

        European Communities, the Council (1992).  Council Regulation (EEC) No. 880/92, of
       March 23,  1992,  on a Community Eco-label Award Scheme, Official Journal of the
        European Communities (L99) on April 11, 1992.  .

        European Bureau of the Environment (EEB) and the European Bureau of the Union of
        Consumers (BEUC) (1991). Eco-labelling: EEB-BEUC Position, Seminar Proceedings,
        June-

        International Chamber of Commerce (1991).  Environmental Labelling Schemes (ELS),
        ICC position paper, Paris, June.

        Poremski, H.J., P. Rudolph, K..Lemme  and E. Six, Federal Environmental Agency
        (1991).  Detergents in  Western  Europe:  Environmental Labelling,  prepared  for the
        Commission of the European Communities, General Directorate XI, Berlin, October.

        Wentz, Laurel  (1991). "P&G Exec Raps Eco-labels", Advertising Age, July 1,  1991.
                                          102

-------
          Ojagram of European Community Labeling Program
   Stage I: Establishing Product Categories
  Anyone may suggest product
 categories to EC or Competent
6o|y!	(Coirifiipetent	Body	consuls"
   with interest groups in their
 country before passing it to EC.)
           Commission reviews
              proposals in
            consultation with
           Consultation Forum
            of interest groups.

            Commission chooses
           categories and assigns
             them to Competent
           	Bogies	to	conduct' LCA \
           I   and create criteria.   '
                   	i-
    Stage II: Setting Award Criteria
i   Draft criteria come
1  '          •        I
i  back to Commission j
  fvhich consult? with j
I  Consultation Forum
I     about criteria.
 Sent to Committee
 of Member States'
   for approval.
Approves!
Rejects
    Stage III: Award Process

1    Manufacturers apply to
|  Competent Body in country
 where product is manufactured,
   Imported or "first marketed.'
! Commission adopts;
i   the measures.
        -:Approves
         ij 	* ,|II,I*M'N	i' " i i 	„
         -i Rejects
 Commission submits
 proposal to Council
 of Ministers. Council
 vote is final decision.
    Passed on to Commission
  which allows other Competent
     Bodies to review award.
  r Objection
   1 No objection
  Commission negotiates informal
   agreement between parties. If
agreement is not reached, application
  goes to Committee of Members.
               -. Rejects I

               T Approves j
                                    Body
        to award label, collect fees and sign standard contract.
                                                                                i  	
                                    101

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industry, and commerce.  The original proposal would not have included this group, and wou/d
have given much less authority to  the Competent Bodies.   The'European Bureau  of  the
Environment (EEB) and the European Bureau of the Union of Consumers  (BEUC) lobbied to
have more say given to the environmental and consumer groups, due to .the "ethical and societal
choices involved", recommending even the power "to veto-a decision... contrary to sustainable
development."  They also requested a right of individuals and groups to appeal awards any time
after the award has been given.  Finally, they stated, that "every consumer has the right to be
informed of the principal reasons  for granting the eco-label", and to  this end suggested an
ecolabel with "full environmental information, i.e.  qualitative  and quantitative  ingredients
composition, processing procedures, re-use and/or recycling facilities." (EEB and BEUC, 1991)
The first of these requests was granted  by the  EC,  but individuals per se can only participate
through the Consultation Forum representatives and by proposing product categories to the EC
and Competent Bodies.                    •-.'•".-

References  '

       SNA Daily News, October 20, 1992.

       ENDS Report,  199la.  "Advisers  Criticise Government for Delay on Eco-labelling",
       September 1991.

       ENDS Report, 199Ib. "Delay with EEC Eco-labelling Proposal Prompts UK Concern",
       issue 192, January 1991.

       ENDS Report, 1991c. "EEC Eco-labelling Scheme Ready to Roll", No. 203, December
       ,1991.

       ENDS Report, 1992.  "First Product Groups for EC Eco-labelling Scheme", issue 205,
       February 1992.

       European Communities, the Council (1992).  Council Regulation (EEC) No. 880/92, of
       March  23,  1992,  on a Community Eco-label Award Scheme, Official Journal of the
       European Communities (L99) on April 11, 1992.
                                                   *
       European Bureau of the Environment (EEB) and the European Bureau of the Union of
       Consumers (BEUC) (1991). Eco-labelling: EEB-BEUC Position, Seminar Proceedings,
       June.

       International Chamber of Commerce (1991).  Environmental Labelling Schemes (ELS),
       ICC position paper, Paris,  June.

      - Poremski, H.J., P. Rudolph, K. Lemme and E.  Six, Federal  Environmental Agency
       (1991).  Detergents  in  Western  Europe:  Environmental Labelling, prepared for the
       Commission of the European Communities, General Directorate XI, Berlin, October.
        ».                                               .
       Wentz, Laurel (1991). "P&G Exec Raps Eco-labels", Advertising Age, July 1, 1991.
                                          102

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NETHERLANDS' STICHTING MILIEUKEUR

-------
STIUITLNGMILIEUKEUR OF THE NETHERLANDS

Introduction

       Due to a growing interest in- environmental issues  in the Netherlands,  the Ministry  of
Housing, Physical Planning and Environment, and the Ministry of Economic Affairs created a
voluntary environmental certification system in April 1992. Prior to the creation of the Dutch
Ecolabel, the government had established the Environmental Advertising Code to discourage the
"use of false environmental advertising claims.  The Stichting Milieukeur takes the Environmental
Advertising Code one step further by creating a seal-of-approval program similar to Germany's
Blue Angel and Canada's Environmental• Chqiee programs.

       The  Ecolabel program  is governed  by  an independent  organization, . the  Stichting
Milieukcur (the Environmental Review Foundation), which.is-made up of representatives from
government,  consumer and environmental groups, manufacturers, and  retail organizations.
Although the European Community is  currently developing an ecolabel, the Dutch government
proceeded with its own program to better accommodate goods and services unique to the Dutch
market.  As of October 1992, the Stichting Milieukeur had set and published the award criteria
for the following product groups: writing paper and nptepaper, light sources,.and handshpwers.
The first ecolabel is expected to appear in Fall 1993. (Bolger,  1993)    ' -   . -

 Structure

       Although the program was founded  and is supported by the Dutch government,  the
 Stichting Milieukeur operates the ecolabeling program independently of the government. The
 Stichting owns the ecolabel,  sets the standards, awards the ecolabel to  products, and  monitors
 use of the ecolabel.  The Stichting Milieukeur was launched on the  initiative of the Dutch
 Ministries of Environment and Economic Affairs.  The Stichting will be subsidized by these
 Ministries until 1996, starting with 100 percent in 1992  and decreasing  each  following year.
 The  Stichting Milieukeur plans  to be completely, self-supporting by 1997.   The  Stichting
 Milieukeur is divided into four organs which act cooperatively in the implementation of  the
 program.  These four organs, the Panel of Experts (College van Deskundigen), the Supervisory
 Council (Raad van Toezicht), the Board (Bestuur), and the'College for Appeals (College  van
 Bereop), are briefly described below:

        •      The Panel of Experts consists of representatives from government, manufacturers,
               consumers groups, environmental groups and retailers. The Panel determines the
               criteria  which products have  to  meet  in order  to  qualify for certification.
               Individual members contribute their expertise to the standard setting process.  The
               Panel thoroughly  discusses the standards and releases  a  draft "certification
           ..   schedule." (Bolger, 1993)
                                           104

-------

             TlS'socW makefth'e '"final decisions '"regarding ""the adoption or rejection  of
             pKlJuct' -roupHerlmtion and" award criteria.  The  Board may also  refer the
             criteria back to the Panel of Experts for further examination.

             The College "of Appeals  hears  complaints  about the Stichting  Milieukeur's
             decisions, the Stichting Milieukeur is in the process of developing rules that will
             govern the appeal procedures.

                    '      '                                           '  '
A\v a ltd Process
*•  "i    criteria ..... Sill" be developed only for product groups in which there are clear differences
&  enviroarSntal quality among products  in the same category.   If all  products  wUron a
                                                                                 r feel
                    ay
                   simHar withgard to environmental impact, the Stichtmg Milieuteur feel
             o pont in developing, criteria  or certifying products for that category Standards
1  be i/ISion a "cradle to grave" life-cycle analysis and will be reviewed about every 3
Ihrs   Awarfbriteria are based upon the "best available technology," and will always be mom
SenVu^reSvant regulations' In this way, only a limited number of products will qualify
ffihclrtificatron: (BNA.1992) In addition, standards of quality and packaging requirements
are also considered during the development of the criteria.

        Stichting Milieukeur does not create product 'standards on its own initiative, but rather
accepts requests  from manufacturers, consumer groups, trade associations  • ^  oAer
 interested party  Once the requirements for a product category have been set and published, any
 narSnuer o'r hnporter Si  submit their product for evaluation by one of the recogmzed
 Ce^ation  Authorities.   The  cost of processing  an application vanes, depending  on  the
 complexity of the certification  process.
   1                                        •  '
 Stage I: Requesting a New Product Category

        A req ult "rbr developSg criteria "for a new" product catego^ mustbemade. Anyonecan
 submit a request to the Stichting MUieukeur Board, which may approve or reject an appUca  on
   or a new product category.  "The main priority in deciding whether the ™»^^*£
 system should be applied  to a particular group  of products is  to establish  whether the
 environment will benefit." (The Dutch Ecolabel, 1992)
Si" ,. ,    „],       I I III                   i ,. Jij"" ! ..... |. !' •" "„ ;|i'|n " ' ! ...... /' ; , ^'li ' ,', ' , " 'f I]'"',' '•",'•
 Stage U: Developing Award  Criteria

        •If the request for the inclusion of a- product category  is granted by the Board  the Panel
       perts hef^nducts a first screening investigation. The Panel charges a Specialist Research
         eferivate  or public) to  conduct a study, looking at all aspects  of the product, from
   "£o>ave",  in order to  draft award criteria for the product category. Special^ Research.
   Ins^efconduct studies for proposed standards because the Stichting does not have the capacity
                                             105

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or the  knowledge to research  product criteria.  Research  Institutes are  chosen based on its
expertise of the product, research experience, staff, and price.
Stage IE: Public Review

       The proposed standards are then discussed at a meeting of the Panel of Experts which
is open to all interested parties.  Participants include the applicant,.selected manufacturers, and
representatives  of consumer,  environmental, and professional associations.  (SNA,  1992)   A
report on the proceedings of this public meeting is made available to the Panel of Experts, which
then delivers its recommendations to the Stichting Milieukeur Board.  The Board makes the final
decision on whether the standards should be made official.  At this time, the College of Appeals
hears complaints about decisions made by the program.

Stage IV: Applying for Certification

       Once the requirements for the product category are approved and published, individual
manufacturers and importers may submit a product for individual certification to the Certification
Authority.  The applicant must persuade one of the Certification Authorities that its  product
meets the standards.

Stage V:  Awarding the Ecolabel

       Certification Authorities,  recognized by the Dutch Council for Certification, assess
whether or  not a product meets the defined standards.  If a  product meets  specifications, the
Certification Authority awards the applicant the  use of the logo.  Manufacturers sign a  contract
with the Certification Authority, which  sets out the conditions for use of the ecolabel.  The
applicant  signs a contract with the Certification  Authority, which sets out the conditions under
which the logo may be used.  An annual fee will be required for the use of the certification.

References                                •

       Bolger, Annette,  1992.  Personal communication with Abt Associates, October 15.

       Bolger, Annette,  1993.  Personal communication with Abt Associates, May 17.

       HartweU/Ray  V., m and Lucas Bergkamp,  1992.   "Eco-labelltng in  Europe:  New
       Market-Related Risks?" in BNA International Environment Daily, October 20,  1992.

       Stichting Milieukeur, 1992. "The Dutch Ecolabel: Added Value for Your Product".
                                           106

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FRANCE'S NF-ENVIRONNEMENT

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FRANCE'S NF-HN'VIRQNNEMENT

Introduction                           .    -

   Tlie  NF-Environnement  certification  program  is  a national, voluntary seal-of-approval
ecolabel developed  for  the  French market  by the Association  Francaise  de Normalisation
(AFNOR).  According to AFNOR, the program is intended "to certify products that have a less
adverse  impact on the environment...'when  compared with other...products available on the
market" (General Rules, 1992).  The program's operation is based on the following principles!

      (1)  Certificates must be issued on  the  strength of finding actual  compliance with
       "meaningful  certification criteria," defined  in technical rules developed jointly by the
      economic parties concerned and approved in accordance with the law.
                                                         _:__ „ .      • r         -
       (2) Arrangements for evaluation and surveillance must be established to ensure that the
       firms to which the ecolabel is  granted offer for sale products that actually conform to
      these criteria.-     '                                                    .    •

       (3) Consumers must  have access to information about the certificate that is not subject
       to any ambiguity of interpretation (General Rules,  Appendix I,  1992).

       NF-Environnement plans to coordinate its efforts with other European programs, "both
through the process of  harmonization of standards and through  its participation in  European
reciprocal recognition agreements." (General Rules, 1992)  In light of this, product criteria for
paints and varnishes were approved on June 3, 1992, based on a study originally conducted for
the EC ecolabel.  To date, however, this  is the  only product  category, for which the NF-
Environnement has certified products.      .

       On  June  24,  1992,  work on NF-Environnement was  suspended  by  the  Labeling
Committee of AFNOR,  pending a re-evaluation of its methodology.  Having originally planned
to use a" multi-criteria  matrix similar to Blue  Angel and the EC ecolabel, AFNOR is now
proposing to use a complete life cycle analysis (LCA).

       NF-Environnement  plans  to  issue  its first  product  standards  based  on  .this new
methodology, for trash  bags, in March 1993.  To finance the cost of testing products  in this
manner, companies desiring a  new product category  must pay  fifty percent of the cost of an
LCA. Once the LCA is completed and product criteria have been set, applicants for certification
are required to pay a registration fee, a repayment of costs incurred to verify a claim,  and an
annual royalty for use of the ecolabel: (Ventere, 1992)

Structure

       The French environmental certification program involves five functional roles (filled
 either by groups  or individuals):

                                           108                  '     .   ••-

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 The *Asson'aiion Francaise Je Normalisation (AFNbR),  which administers the
'pro^kin and issues awards, appoints members ;o the Label Committee, selects.
 the "Expert" to prepare a report on a product category's acceptability, and makes
 the final decision on  a product, category and its "Technical  Rules" (the criteria
 which products "must  meet to1 Veceive the award).

 The^Reporter, selecteci '"'by 'AFNOR  with the approval of the Label Committee,
 drafts the technical rules for a product category. One "Reporter" is selected for
 each proposal.  He/she may consult other groups in this process.
 ,	 US ' ', '••,   ' '  "; ,'.""';) ,  ••, •','. , '' -;"1:";:,: v;,.i '. ' \	,';•' ; ,,..•;[ .'.•.'' a t '.-'• i ,*, i[/.'.,  '    . , ,-   ,  ' ,
 T^e'Labe^Committee consis^of il  members appointed by the Director-General
 of AFNbR, in agreement with the  Minister of  Industry, the Minister of
 Environment, and the Minister of Consumer Affairs.  There are 6 representatives
 from industry, 3 representatives from  consumer organizations, 3 representatives
 from  environmentai-pfdtection  groups, and a representative each  from the
 Minister of Environment, the Minister of Consumer Affairs, and the Minister of
 InHustry  The" Chair of the Scientific Council and a representative of AFNOR are
 Standing  members of the  Committee.  There is also a Secretariat provided by
 AFNOR which oversees the technical and administrative issues of the program.
 Members hold  office for 3 years and may  be reappointed.  The Chair of the
 Committee is elected for  a one year term; with the industry representatives
 alternating with the environmental and consumer representatives in the chair.
    	''	     	 "     "	
        The Committee is  responsible  for the development and administration of
 the NF-Euvironment program. It gives opinions on the draft product criteria used
 to evaluate products within a category, approves AFNOR's choice of Reporters
 for the draft of  the Technical  Rules, monitors the work of the Experts  and
 Reporters, appoints  the Scientific Council, and set royalties.

 The Scientific Council advises the Label Committee. Its tasks include 1) proposing
  suitable" Experts and Reporters to be called upon for the technical administration
  and development of the program; 2) consulting on the methods used to evaluate
  product criteria and the harmonization with other programs; 3) intervening, at the
  request of the  Committee and/or AFNOR, on any point requiring technical and
  scientific expertise,  for example in matters  relating to the validation of technical
  rules; and 4) maintaining a permanent technological monitoring service.

  the Experts are 'individuals appointed by AFNOR; on the recommendation of the
  Council,  who evaluate  applications  for  certification  for existing  product
  categories, arid recommend to AFNOR that a product  be accepted or rejected.
  There is one Expert for each application and he/she is responsible for examining
  the application, visiting the applicant to validate that the product adheres to the
  technical  rules or to determine if  "further tests or inspections [are]  required to
                               109

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             demonstrate the conformity of the product to  all the .applicable 'certification
             criteria and then to assess the results." (General  Rules,. 1992)

Award Process                                                                    :

      The NF-Environhement award process consists of four stages. Any. interested group may
apply to AFNOR for the preparation of Technical Rules for a given product category.  Once
AFNOR. has  decided that Technical Rules  should be drafted,  it assigns a  Reporter  to draft
Technical  Rules that are reviewed by the Label Committee.  Once the draft is accepted by  the
Label Committee, it is sent to the Director-General of AFNOR and  the public authorities to
accept, reject, or send  back for revision.   Once the criteria have been approved, interested
parties may apply for certification.  The application is  reviewed by the Expert appointed by
AFNOR; the  final decision is  made by AFNOR. If the award is granted,.,the applicant pays an
annual royalty to use the logo.

Stage I:  Choosing Product Categories

       Product categories may be proposed to AFNOR by any interested party.  AFNOR,'on
the advice of  the Label Committee, decides whether the proposal is acceptable in principle. The
Committee bases its recommendation on  the assessment of (1) the scientific foundation, (2) the
acceptability  to consumers,  (3) the technical and economical feasibility and (4)  the proper
integration of the proposal in the context of the NF-Environnement program.  "When a proposal
is judged  acceptable, AFNOR, with the  approval of the Label Committee, nanies a Reporter,
whose task will.be to -draft  Technical  Rules  based  on the proposal submitted to AFNOR,
working closely with the parties concerned." (General Rules, 1992)

Stage H:  ^Drafting Technical Rules

       When drafting the Technical Rules, the Reporter must define specifically 1) the category
of  products  concerned, 2) the environmental-impact criteria,  and 3) "the  requirements  and
acceptable limit values adopted when the quantification of environmental criteria is  founded on
a scientific basis." (General Rules, ,1992)

       The Technical Rules for paints and varnishes used a life cycle matrix,,but not all criteria
w.ere selected (see table).  Certain criteria in the Technical Rules may be deferred "pending the
solving of the specific problems they raise."  (General Rules, 1992)  As of June 24, 1992,
however, AFNOR has  suspended all  work currently being done to establish Technical Rules
based on  a complete life cycle analysis.                                                 ;

Stage HI: Approval of Technical Rules

       Draft Technical Rules are submitted by the Reporter to the Label Committee for review
and a recommendation. "After advice from the Label Committee, it is the responsibility of the
 Director-General of AFNOR and the public authorities...to evaluate to what extent the criteria


                                           110

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TABLE OF CERTIFICATION CRITERIA ADOPTED FOR PAINTS AND VARNISHES





STAGE OF
PRODUCT
LIFECYCLE
Extraction of
raw materials
Production :

1) procurement
2) manufacture
Distribution:
1) conditioning
2) packaging
3) transport
Use and.'or
consumption
Disposal after
use:

1) product
treaiment/recyc
ling
2) packaging
treatment/
recycling
EVALUATION CRITERIA
Use of
natural
resources,
raw
materials,
energy






















Pollution
and
deterioration
of physical
environment
, water, air,
earth



X






X





Noise






















;







Waste









X






X










Impact on
ecosystems









X





X



X







Other
damage







--.



















Impact
on
Man





!


X





X




X





      	• •      '.::•  .,„       ••
  X = Criteria that were selected
adopted are significant enough to justify granting the LaGei."  (General Rules,  1992)  When
approval has been granted, AFNOR communicates the Technical Rules to firms who may be
interested in obtaining certification.

Stage IV:  Awarding Ecolabels to Manufacturers
        ''   ' . "    I1!"!1 |!! ,  ' ",'  "'  ', • '"."i. "' "j"', i,"!1' .' " : "'«'!' I  " V'j ' !,.'' '' ' !' ': 1.1 . i, •'•'   '»"•]•' '" '•„,!' j ::: ' i   !'''''' ,'v1 ,,/; ',     '  " '"
       For each application for NF-Environnement certification, AFNOR appoints an Expert to
prepare a report proposing that the application be accepted or rejected.  The appointment of a
particular Expert can  be challenged once by the applicant.-
                                           ill

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     '  The manufacturer must pay a flat-rate'registration fee (~ 12,500 Francs) to cover the-
 costs of processing- the application and repay the costs of verifying that the product conforms to
.the Technical Rules,  as  well as make an annual royalty  payment (0.1% of the product sales,
 minimum 7,500 Francs)  for the right to use the NE-Enviroruiement logo.

 Stage V:  Monitoring

    Tests  and inspections will be performed once  a year in the  first two years following
 certification.  After the first two years of operation, the  periodic tests  and inspections will be
 performed every two years if no infraction of the use of'the logo has occurred.  "On the other
 hand, the frequency of tests and inspections may be increased from the first year onwards, upon
 the Committee advising  that this is warranted by the standard of organization reached by the
 applicant for product quality control purposes." (General Rules', 1992)

 Public Review Process

       While there is representation  from industry,  environmental and consumer groups,  and
 government on the Label Committee, there is no official public review.

 References

       Associatiqn Francaise De Normalisation, 1.992.  "General Rules Applicable to the NF-
       Environnement Label".

       Ventere, Jean-Paul, Ministere de  1'Environnement, 1992. Personal communication with
       Abt Associates, August  17.    '                    .                          ,
                                            112

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FLIPPER SEAL-OF-APPROVAL
  iliii; i. ;•.',[. ,,.;	;	> 1 ;* iiiiaSi, A. •»' <^i J'^

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FLIPPER SEAL OF APPROVAL

Introduction            "                                 •

       The  Flipper  Seal of  Approval  is a  international seal-of-approval program run  by
Earthtrust, a nonprofit wildlife conservation group.  The Flipper program is solely interested in
protecting dolphins from fishing practices that maim and kill dolphins.  The program is designed
to encourage tuna companies  to purchase tuna caught by dolphin-safe fishing practices and to
take proactive effort  to protect dolphins  and promote their welfare.

       The Flipper program examines all facets of a company's corporate policy that may affect
dolphins, including the fishing techniques of .tuna suppliers, activities of subsidiaries and parent
companies,  and involvement in dolphin protection efforts. Tuna firms that apply for and meet
the program's standards for "dolphin-saving"  can license and display the Flipper Seal on their
tuna products.   Flipper standards are  more  stringent than-those established by the Dolphin
Protection, Consumer Information Act (DPCIA), a Federal law that-took effect in September
1991.  One  of Flipper's goals is to help the tuna consuming public distinguish between  those
companies  that  are  actively  dolphin-saving,  as opposed to those  which merely meet  the
requirements of DPCIA.                           ,

       The Flipper Seal of Approval is endorsed by 23 environmental organizations from around
the world.  There are currently seven tuna companies  in the  U.S. and other countries that are
licensed with the Flipper Seal of Approval.                          .     •

Structure

       Earthtrust, a  nonprofit tax-exempt wildlife preservation organization based in Kailuna,
Hawaii,  is  the sole  licensor  for the Flipper  Seal of Approval.  Other Earthtrust campaigns
include the  Driftnet Campaign, -the Save the Whales Campaign, Project Delphis (researchin the
mental abilities of dolphins),  and the Asian Wildlife Initiative.

       The  Earth Island Institute (FJI) of San Francisco, the leading conservation organization
monitoring  the tuna  industry, established the  licensing standards  which  Flipper uses.  FJI also
runs the tuna company monitoring program,  in cooperation with  other dolphin conservation
groups.                                                                               .

Award Process.

       The Flipper program uses the same standards for dolphin safety as Earth Island Institute
(EH).  The  monitoring program is run by EH  and other conservation organizations,  which have
access to the factories, loading docks, and purchasing/sales records of certified tuna firms.

       According to program literature,  "the Flipper program contracts  include the  right to
examine records of  licensed  tuna companies, and to place observers in company facilities. If
     /••••..                           .                 .
                                           114

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found to be in  violation of the agreement! the company is first warned;,  its licensing  of  ihe
Flipper Seal is revoked if problems are not corrected."  (Earthlrust, 1992)

      To receive the Flipper Seal of Approval, a tuna company must agree to:

1)    Maintain a corporate policy to kill no dolphins;

2)    Enforce this policy in aU of its operations worldwide, including its subsidiaries and their
      parent companies;                                •

3)    Not purchase, process, or sell any tuna that was caught by driftnets or gillnets, or by the
       intentional setting of purse-seine nets on dolphins;

4)     Allow independent monitoring personnel to examine records and operations at the tuna
       firm's factories and docks, in order to certify compliance;

5)     Require its suppliers to provide credible guarantees that dolphins were not harmed in the
       capture  of tuna;

6)     Provide the Flipper program with any information on dolphin-unsafe practices of which
       it becomes aware;

7)     Pay  an annual licensing  fee to the Flipper program,  which helps fund  the  global
       monitoring program;

8)     Work internationally to support the concept and practice of dolphin-safe seafood as an
       example of corporate environmental responsibility; and

9)     Engage in pro-active dolphin-protection activities, such as  educational programs, to
       further  promote the welfare of  dolphins.  (Earthtrust,  1992)

References

       Harthtrust, 1992.  Flipper Seal of  Approval Information Kit.

        Madison, KT, Media Coordinator, Flipper Seal of Approval program, 1992. Personal
        communication with Abt  Associates.

        San Diego Union-Tribune,  1992.   "Flipper's Face on Tuna Saving Dolphins,  Group
        Says,"  June 8.
                                           115

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SCIENTIFIC CERTIFICATION SYSTEM'S

 FOREST CONSERVATION PROGRAM
                    This wood wos horvesfed
                    from a Sfate-of-f he-Art
                    Well-Managed Forest*

-------
{'if
       SCIENTIFIC CERTIFICATION SYSTEM'S

         FOREST CONSERVATION PROGRAM
                            This wood was harvested
                            from a State-of-the-Art
                            Well-Managed Forest*
             SCIENTIFIC CERTIFICATI0H SYSTEMS

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SCS FOREST CONSERVATION PROGRAM.

       SCS's Forest Conservation Program (FCP)-is designed to evaluate forest management and
timber harvesting practices. According to SCS, the program's goal is to "provide independent
feedback to timber operation managers regarding the relative sustainability of their practices, and
to assist retailers, product manufacturers and...consumers in their efforts to make sensible wood
purchasing decisions." (SCS, 1993a)     .

       SCS uses a  100  point index to evaluate  the management of forestland tracts (called
"management units") by timber operations with respect to the following three program elements,
or evaluation categories:                                •.'•'••                •

       •     sustainability of timber resources

       •     forest ecosystem maintenance

       •     socio-economic benefits to the surrounding community.

A set of site-specific evaluation, criteria are selected for each category by an  "interdisciplinary
Evaluation Team."  For example, relative sustainability of timber resources may be measured
through the rate of harvest as compared to growth, the age of the trees harvested, long term
productivity of the  harvest sites, and harvesting  efficiency.  For each category,  a score on a
normalized, 100 point scale is assessed after the examination of these criteria. (SCS, 1993b)
These scores reflect the extent to which the timber operation under review meets the ideal
management practices (as defined by the Evaluation Team) for its own management units.   A
timber operation under review is not directly compared against other timber operations.

       SCS gathers data for its analysis from information supplied by the landowner  and field
data collected by the Evaluation Team.  If necessary,  SCS  will verify the landowner supplied
information through observation and field sampling. A periodic monitoring program is installed
by SCS to ensure that participating timber operations continue to meet standards.

       Timber operations that have been thoroughly evaluated may communicate SCS's findings
 via marketing, claims  to the public through a special label developed by SCS.

 Structure                    ,

        For each evaluation, SCS  organizes an Evaluation Team composed of SCS  staff and
 "contract/consultant field-level personnel with expertise in relevant disciplines (e.g., forestry,
 wildlife ecology, hydrology, sociology and natural resource economics)." (SCS, 1993a) A field
 team made up of members of the Evaluation Team makes on-site visits of the management units
 to gather data.                                                      ,'".'-.
                                           118

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   FCP Ojwutional Process
   Stage I: Contractual Agreement
                    I, "t	II
                    i-sii i i,.'
          A contractual agreement between SCS and the timber company under review establishes
 ;  the scope of the study, and delineates rights and  responsibilities for each party.  The timber
:   operation may use the results of the study in marketplace claims only if the scope of the study
   includes all evaluation categories for all of its management units. (SCS, 1993a)
   Stage U:  Assembling the Evaluation Team

          After the contract has been drawn up, SCS assembles an Evaluation Team, composed of
   SCS staff and "contract/consultant field-leyel personnel with expertise in relevant disciplines."
   The, Evaluation Te^m designates a field team to gather field data, and is itself responsible for
   compiling and analyzing  "all  pertinent,  available information on  the  property's resource
   conditions and management plans in order to arrive at criterion-specific scoring for each of the
   three program! elements." (SCS, 1993a)                                  '      ,    '
   Stage Eft:  Data Collection and Analysis
   • !  ',;*', ;   , .,    " '  Pill; ;:..••..'  . ' ' I!1". • !• , "   •:•. ..... ! •'. ,:.'?rp .......... • ': ..... . "(I • " "i  • :' ,,: .. ,# "i;'i " , ••

          The Evaluation Team collects quantitative and observational information about resource
   conditions on  the property and the landowner's management plans for the area.  Information
   sources include:

          *      plans and data submitted by the landowner;

          •      empirical data and observations gathered by the field team;

          •      published data on habitat occurrence and wildlife population statistics;
                                                                                   ,
                       s*fte,  or fed?1^ fo^stry agencies that  monitor forest practices or are
                 familiar with the subject property;

                 interviews with  non-governmental organizations,  employees, and community
                 members  who are familiar with the subject property.
          SCS notes that the management plans  of the landowner weigh  very  heavily in the
   evaluation, and are scrutinized for their "technical veracity and overall Lmplementability." (SCS,
   1993a)

   Stage IV:  Criterion Selection and Weighting

          From a pre-established set of potential criteria, the most relevant criteria, as defined by
   the Evaluation Team, are used for the data evaluation.  If field data indicates a need, the

-------
          criteria '-may  be modified" to. "better "focus, on  key' ground-level parameters and'
                          -te. tSCS,  I993a)  Criteria are then  we,ghtcd  by the*, relattve
Importance,  also as determined by the Evaluation Team.
Stage V:  Performance Ranking
 ui a luuwi' operation is"i	                            .
 for those management units under review,  A timber operation-under review Mr
 against other timber operations, although in practice various evaluation .criteria
 Sober operations may be very similar.  Timber operations are scored on a normalized 100 point
 scale. (SCS, 1993a)                    v                "

 Stage VI:  Chain-of-Cusfody Review

        In order  to  make  marketing  claims based  on SCS's  evaluation   mamifacfurersaiid
 retailers using-raw timber or finished products that are derived from evaluated sources must
 undergo  a  4ha?n of-aSody" review.  A  chain-of-custody review uses vanous tracking and
' Egging techniques to verify that all the participants along the distribution chain are handling the
 product that was originally evaluated by SCS. (SCS, 1993a)

 Stage VH:  Awarding Certification

        SCS has  developed a "labeling system to convey evaluation results for those companies


  •n nrrW to make a oublic claim  These operations are designated as "Well-Managed.   Timber
  operations which  place in the top 10 percent  of  the "Well-Managed"-.category are further
  identified as "State-of-the-Art."  (SCS, 1993a)

  References

         SCS, 1993a. Fact sheet: "The SCS Forest  Conservation Program."

       '  r,™'   j ,u  r-«ii5«B wi«»' rnmnanv  1993b   Joint  press  release: "New, Scientific
         SCS and tne c.oiixns jrinc vumponjr, ^ss^**-        r            _,,., ti-e -n  ^:i^^i
         ^^                           .-.  protection of Jobs Ti~ees, and Wildlire Unveiiea -
         ProgSm Uunched ^h Study of Model U.S. Timber Operation."
                                             120

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WAL-MART
           "in

-------
\VAL-MART-

      The nation's third largest retailer  announced in August  1989  that it .would promote
products "that have been improved to prevent lasting environmental problems".by means of a
shelf labeling program.  (Fisher,  1989)  "The Wal-Mart tag does not say the product is safe.
What  it does say is an improvement has  been made," said Paul Highara,  vice president of
marketing.  "If you .try to have something that is a shortcut, like a symbol, people might assume
it is safe or not.  You  might not be as definitive as you ought to be."  (Fisher,  1991)

      In October of that year, products began  appearing on its shelves accompanied by shelf
tags  commending the manufacturers and noting  the  specific  environmental  improvement.
Manufacturers requested labeling from Wal-Mart and provided documentation, and Wal-Mart
made the  final decision on the  shelf tag. (Fisher,  1989)  Wal-Mart also set  up recycling
collection centers in the parking lots  of its 1,500 stores across the. country.

       Wal-Mart ended its shelf labeling program in 1992, for a.-humber of reasons.  The main
problem was that varying state laws made it difficult  and expensive  to make environmental
claims, and the risk of breaking a law in one of their numerous stores outweighed the benefits.
Jan Maulden, Environmental Marketing Manager, cited  New York's law on recycling claims as
well as slate laws in Florida, South Carolina and California as limiting environmental marketing
activity in those areas.  Since.the shelf labeling programs were run by the corporate office but
implemented by each individual store there was a concern that some mislabeling would occur.
Wal-Mart has  a shelf label promoting products  made in. America; problems  with this program
were the subject of an  ABC "Nightline" expose that generated a great deal of negative publicity.

       Another significant worry for the legal department at Wal-Mart was that consumers may
be  misperceiving  the  shelf tags as a  general  approval of the product's  "environmental
friendliness" and that Wal-Mart would be  liable for making misleading claims. A further legal
complication was that Wal-Mart  was relying on information provided by the-suppliers; thus, it
was necessary to develop a "paper trail" to track the claim back to its original source. . A final
concern was that suppliers may complain that a shelf label would make an  unfair  comparison
between two brands, although this had not yet become  a problem. •   -
   \
       Currently, Wal-Mart is trying different approaches to promoting environmental products,
 mostly by educating consumers about environmental issues and encouraging  marketers to make
 environmental  improvements.  In Lawrence, Kansas, an "environmental demonstration  store"
 is opening that will.serve as a test site for different marketing programs. Shelf labels will be
 used, but they will not promote  specific products;  instead, they will "tell corporate stories" —
 acknowledging companies for general improvements made to products or packaging.  There will
 also be a number of "generic" signs with information on environmental issues.
                                          122

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fisher, Christy, 1989.  "'Sealof Green1 Planned," Advertising Age,, November 20.
Fisher. Christy, 1991. "fending ''Wal-Mart's Green Policy," Advertising Age, January
29.    "                      i     ,         '     • •

Maulden,  Jan,  Environmental  Marketing Manager, Wal-Mart,   1993.    Personal
communication with Abt Associates, March 31.
       ', '!, liiI
       i ',4i
                                   123

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WHOLE EARTH ACCESS

-------
 \VUOI>:KAR!ni ACCESS

       Whole Earth Access is a chain of six retail stores in the San Francisco Bay area operated
 by Basic Living Products, Inc., of Emeryville, California. It was originally associated with the
 Whole Earth Catalog, a long-time source of environmental and socially conscious products, but
."itic stores are n:o:t direct retail outlets for products offered in the Whole Earth Catalog.

 	    Whole  Earth Access  does  some  shelf labeling  "to  highlight products that are an
 alternative  to  mainstream  America,"  according to  buyer Brenda Tong.   The labeling  is
 determined by each merchandise'buyer based on manufacturer claims, combined with whatever
 additional information each buyer deems necessary to verify the claim. Ms. Tong often requests
 additional information "from 'manufacturersand "personally tests" products. In addition, she will
 give a product a shelf label if it has already  been,certified by SCS or approved by People for
 the Ethiral Treatment of Animals (PETA).
"»,'•     ''      ' " ii,tii Illilll  ., •   ,i   ' :• ': „,:' • ,» i1 ,,•!'„!, /"'J. 'mi!"1!11' '.' •' |, ./ ,,i '"M i',•'"'' .»j" I:1"!'1;!' :'!:, i: ' . • .'!''i 	" ,,11 ,,'•  "'' '        , .    ,      •
I;      ': Although Whole Earth stores have promoted ''environmentally friendly" products for the
 15 years of their existence, there does not  seem to be a cohesive program.  Shari Rigdon,
 Advertising Manager for the company, says that Whole Earth does not "do that corporate stuff."
 (Rigdon  1992) Since each store and buyer marks products as they see fit, the corporation does
 not keep track of  the number or  types of products that are promoted as "environmentally
 friendly."  Some products marked include unbleached bed sheets and greeting cards made with
 recycled paper.

 References

        Tong, Brenda, 1992. Whole Earth  Access, personal communication with Abt Associates,
        September 25, 1992.
        ,  ii      i i                                        i          , •          ,
        Rigdon, Shari, 1992. Whole Earth Access, personal communication with Abt Associates,
        October 16, 1992.
                                             126

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    SCIENTIFIC CERTIFICATION  SYSTEM'S
ENVIRONMENTAL CLAIMS CERTIFICATION
                   Biodegradable Product
                    .Breaks down into carbon dioxide,
                       basic minerals and water.
                      Claim independently v«riSbd by
                           SCIENTIFIC
                            CERTIFICATION
                   100% RECYCLED PRODUCT
                                    #
                    • 20% post-consumer
                    • 80% pre-consumer recovered
                     industrial material
                   Claim verified by
                   Scientific Certification Systems "^H!

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              	(I
SCS LNVfRONMENTAL CLAIMS CERTIFICATION
              l| I I                    I              !        I              i ' , ''•      i    ',''"'
       According to Scientific Certification Systems (SCS), single claim certification is designed
"to provide "independent assurance that specific environmental claims made by manufacturers"
are accurate and represent "significant environmental accomplishments." (SCS, 1992a) To date,
|hore than 5^^                                  	

•      Recycled Content (state-of-the-art)
•      Recycling Rates by Material
*      Biodegradability
•      Energy Efficiency
•      Water Efficiency
•      No Smog Producing Ingredients (VOCs)

       After a product has been certified,  its packaging may display an " authorised certification
emblem" accompanied by an exact description of the verified claim.  SCS emphasizes consumer
education by  providing product shelf signs,  information printed on the products, and special
educational material prepared by manufacturers and retailers.

       In 1991™  scs announced joint efforts to establish  an environmental  claims review
 program for Home Depot, a nationwide  retailer.   Under this program, SCS is working with
 Home Depot to verify the accuracy and  significance of claims made for products  that Home
 Depot stocks.  SCS  also started similar programs in 1992  with the Home Center Institute and
 {he National Retail Hardware Association, which are two  trade associations that represent the
 entire retail hardware and home improvement industry. (SCS,  1992b)

 Certification Process

 Stage I:      The manufacturer signs  a  contract with SCS, agreeing to  disclose information
               relevant to the claim.  All sensitive product information will remain confidential.
•i.'""  '   ". .'  ',". ',  I III  II          *                                   ' ., '":'.' :,".'   '..,,'.
 Stage 6:     The manufacturer releases the information  to SCS,  which is reviewed by SCS
               faff.  If necessary,  additional product testing may  be  required to confirm the
               Siformation.

 Stage 'ill:    SCS performs on-siteinspections to verify information.

 Stage IV:    SCS performs an audit of detailed  plant records.
i",' '     ' !   , ' '	  I1',,,,1,"ill'  ' I" , ,  , '.' n ' ,' I '« i'! " 'El ,„ ' , " ' ,l ' , ,»'•,!'' •'!! " I"'!1, " 'I"  i' •'!, !" •!• i ,r' '!:•!	"';"  !' |n -  i11!1"'' '"I1 "j, '!     !     , '
 Stage V:     SCS consults independent databases to compare the product's attributes with the
               mdustry norm.

 Stage VI:    Certification is issued or denied.
                                           128

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Stage \n:   Monitoring: Once certification is awarded, SCS reviews and updates certification
             records on. an annual basis to make sure that the certified product continues to
             perform to required specifications. Quarterly monitoring is required for recycled
             content and recycling rate certifications.
References
      Brown Linda, Vice President of Communications, SCS, 1992.  Personal Communication
      with Abt Associates,  November 12.
              t                   .                          . ,
      Green Cross Certification Company,  1991.  "Review of the Green Cross  Certification
      Program:  Prepared in Response to the Environmental Defense Fund Report," October


      Home pepot Press Release, 1991.  "The Home Depot Teams  Up With Green Cross to
      Assess Suppliers' Claims Concerning Environmental Effect of Products and Packaeine "
      Julv 11.           .                                                       5 5)
July 11.
      Scientific Certification Systems, 1992a.  "Scientific Certification System's Environmental
      Certification Programs:  Frequently Asked Questions."

      Scientific Certifications Systems Press Release, 1992b. "Home Center Institute, National
      Retail Hardware Association Join with Scientific  Certification Systems to Establish
      Program,to Screen 'Green' Claims," April 23.

      Smith, R. Justin and Richard A. Denison,  1991.   At  Cross Purposes?-   A Critical
      Examination of Green Cross's Environmental Record, Environmental  Defense Fund
      Washington  F> r  <:<=ntomKQ^ -an                    •                           '
Washington, D.C., September 30.
                                       129

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MS"
    ENVIRONMENTAL CHbiCE AUSTRALIA
               o
•|g"M V I R O NM E
                         L
                           T A L


                    T R- A

-------
ENVIRONMENTAL CHOICE AUSTRALIA

       The stated goals of the Environmental Choice Australia (ECA) Program are to ensure that.
"environmental claims made about products and services are both meaningful and truthful" and
that "consumers and the providers of products and services are educated and informed on the
environmental impacts of products and services." (EGA, 1992) To these ends, in .October 1991,
Australia  initiated  an environmental  claim verification program, education and• information
programs,  environmental legislation, and programs that encourage  manufacturers to lessen
.environmental impacts throughout their design and production processes.

       The EGA program is currently undergoing a review  as part of the original agreement
made between EGA and the Australian and New  Zealand Environment Conservation  Council
(ANZECC).   Some.of the  proposed changes include:   1) a  requirement that all'products
participating in EGA must-meet all relevant Australian regulations .and State and Commonwealth
environmental legislation; and 2) a classification of environmental claims into broad categories
such as' "reduced resource usage"  and "reduced energy use". (Doyle, 1992)

       'According  to sources at the EGA, the program has encountered significant resistance
from industry.  Industry groups hold the view that  government involvement in environmental
advertising "should be confined to ... education" and that "industry should be self-regulating/
To this, end,  some industry groups have developed their own "codes of ethics and charters."
 (Doyle,  1993)                                  ;

       EGA also relates that they are having some problems with consumer understanding of
 the logo.  Even though  all-of ECA's  educational materials emphasize that EGA only verifies a
 manufacturer's environmental claims, consumers continue to interpret the presence of the logo
 on a product  as.an endorsement of that product by the program.

 Structure

        Environmental Choice Australia is run under the auspices of ANZECC, the Australian
 and New Zealand  Environment  Conservation Council.   The Commonwealth Environment
 Minister oversees  the program on behalf of. ANZECC.  Environmental Ghoice Australia is
 expected to harmonize closely with Environmental Choice New Zealand.

     -   In addition to ANZECC,"a Scientific Committee has been proposed to provide advice on
 eriviipnmental,claim verification, definition of terms, and testing processes to be used to validate
 claims.  Also, a broadly-based Advisory Committee including representatives from government,
 industry, consumer, and environmental groups consults on all aspects of Environmental Choice.

        "The  Commonwealth has advised it will provide the running costs for administration of
 the scheme,  covering the secretariat, random testing,  Committee costs, office accommodation
 and equipment." (EGA, 1992)
                                           132

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Envu unmental Claim Verification Process

    I;/ 'Environmental Choice Australia is a voluntary program that gives government approval
to those product environmental claims that can be tested and quantified.  If a manufacturer and
its product pass the required tests, the product may display the Environmental Choice logo.  Fhe
texton  the logo reads "Environmental Claims Checked  by Environmental Choice Australia.
Environmental Choice has categorized possible claims as follows:

       1) claims that can be quantified;
       2) claims dependent upon common understanding of terms used;
       3) meaningless claims;
       4) misleading claims.

       Manufacturers applying for verification are  not  allowed to- use claims that fall under
categories (3) or W-  For example, a verified product, cannot claim that it is free of a specific
chemical which is not usually contained in that type  of product anyway.  Products can claim to
be free of an ingredient only  if they present an "analytical report from a recognised laboratory
that supports that claim.  According to the program, "[a]ll products submitted for verification
of their claims wiH have to be formulated to do what they are supposed to do," although their
effectiveness is not measured as part of the verification.
 " '   I .1'!   ' ' '   i,                                                            , '
Manufacturers who participate in the program must agree  to:
  '  l"  ;'  • ' ;;'   :    I'  '    i                                           .'',''
 1.      Ensure that the interests of consumers are maintained by the development of product
        te&tLng "procedures designed to ensure the integrity  of product environmental claims.

 2      Verify or establish,  claims concerning  environmental benefits by appropriate  testing
  "procedures" using  where necessary approved laboratories, and  advise  Environmental
        Choice of the way in which claims have been verified.
 3      Ensure that all product  claims  use words  in accordance with  standard definitions
        developed by Environmental Choice in conjunction with interested parties, for example,
        "biodegradable" or "recyclable."
   -""i,:" •    ''i1 \   •/." • ijajij;;., ; • .,  . • ;,;. _,'! ,ji,;:,;  j ! J-	!" ?" "L;'ijj,11;!., ' ",.,'!,	...I-' i1;111'-'!1"11'!1.'1'' !.>!,!  *-$•.'!,'; !.i  ';'•.•,."
 4 !:"i "' ^vpid'thef s^^                     or illusionary statements including pictures and
        graphics implying the product is  "environmentally safe," "environmentally beneficial,"
        "harmonious with the environment"  or the like in product  claims, advertising, or
        promotional material.

 5.     Relate aU environmental claims to the manufacture,  composition, or use of the product
        including disposal of packaging and subsequent decomposition.
   .•••' 	   ijl •,'  "      in                                 '         11      ,,  '     /
 6.     Participate with Environmental  Choice in promoting  manufacturing, packaging and
        distribution processes that have minimal impact on the environment, as well as seek to
                                            133

-------
   •    remove processes that have a detrimental impact on the environment in 'the production.
       use and/or disposal of products and/or services.

7.      Collaborate with Environmental Choice  in  the development of and participation  in
       consumer education  Programs, and prepare and distribute  information to consumers
       which will enhance the community's awareness of environmental issues relevant to the
       participant's products and services,  and the lesser impacts of the participant's product on
       the environment.               .

8.      Ensure that they and.their staff are  familiar .with, and comply with, the provisions of the
       Environmental Choice Code of Ethics."

9.      Refrain from promoting or marketing  products with harmful environmental impacts on
       the  basis of a minor environmental benefit, such as-a toxic product marketed  in  a
       reusable container.                   -

 10.    Refrain from  words  that would not generally be understood by the "average shopper"
       when making environmental claims.           -

 Enforcement

       Environmental Choice Australia states  that it will perform random testing of products and
 services to ensure that providers of products and services, regardless of whether they participate
 in. the Environmental  Choice program,  remain  honest.   Because  they  are a  governmental
 organization, they have the  authority to prosecute manufacturers who make false claims.  Fines
 up to $100,000 (companies) and $20,000 (individuals) may be levied on those parties who are
 caught making false  product claims.

 References

       Doyle, Kevin, 1993.  Personal Communication with Abt Associates,  May 14.

       Doyle, Kevin, 1992.  Personal Communication with Abt Associates,  September.

       Environmental Choice Australia,  1992. Information package.

        Salzman, James, OECD,  1991.   Environmental Labelling in  OECD  Countries,
        Organization for Economic Cooperation and Development, Technology and Environment
        Programme,  Paris.
                                           134

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EPA ENERGY STAR COMPUTERS PROGRAM
       EPA POLLUTION PREVENTER
  I;;!1!

-------
 EPA KNFRGY STAR COMPUTERS PROGRAM

       In June 1992,  the EPA launched the Energy Star Computers program to promote the
 introduction and use of energy efficient personal computers, printers, and peripherals. Designed
 as  a voluntary partnership effort between EPA and the computer industry, each participating
 company has agreed to introduce computers, monitors, or printers that switch to a low power
 state when left idle. In the low power state, a computer component drops its power draw to 30
 watts or less, a 50-75 percent reduction compared to normal power draw.   Companies that
 market qualifying products may use the EPA Energy Star logo to identify those products. EPA
• emphasizes that the purpose of the Energy Star logo is to promote energy efficiency only,  and
 that EPA does not endorse any particular product. Participants in the program are required to
 note this wherever and whenever the logo is used.  The first logos are scheduled to appear on
 June 17,  1993.

        As of June 1993, 70.companies had signed on as "partners,"  accounting- for 60 percent
 of U.S. computer sales, and  80  percent  of laser printer sales.  Included in this list of 70
 companies are large,  high  profile manufacturers such as IBM, Apple, Hewlett Packard,  and
 Compaq.  In, his Earth Day 1993  address, President Clinton released an Executive Order  that
 directs the various agencies of the federal government, the largest purchaser of computer
 equipment in the world, to purchase only desktop computer equipment that meets Energy  Star
 specifications, provided that they are available commercially and meet performance needs. EPA
 is  also encouraging consumers to buy. computers with the Energy Star logo through a corporate
 purchasing program modeled after EPA's Green Lights program. (Johnson, 1993)

        Computer systems  currently  account  for 5  percent  of  the electricity  used by  the
 commercial sector, and this figure  may increase to as much as 10  percent by the year 2000.
 EPA estimates that by the year 2000, the Energy Star program will reduce annual carbon dioxide
 emissions by 20 million tons, or the equivalent of the emissions of five million cars.  Significant
 reductions of sulfur dioxide (140,000 tons/year) and nitrogen oxides  (75,000 tons/year) are also
 expected. ,(Hansen,  1993)  Since much of the technology used to make computers energy
 efficient has been readily available in laptop and portable systems for some time, manufacturers
 expect to convert many of their product lines with virtually no increase in cost or decrease in
 performance.  (Johnson, 1993)                                      ,

 References

        Hansen, Ellen, 1993. "EPA Effort aimed  at power-guzzling PCs"  Boston Business
        Journal, March 26-April 1, 1993.

         Johnson, Brian J.,  1993. EPA Energy  Star Computers program information packet.

         Nadel, Brian. 1993. "The Green Machine." PC Magazine, May 25, 1993.

         U.S. EPA, 1992. "EPA Energy Star Logo Premieres." EPA  Journal, July/August 1992.


                                           136

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                                EPA
                       ENERGY STAR
                        COMPUTERS
                                                      EPA  POLLUTION PREVENTER
       SUMMARY OF COMPUTER AND MONITOR AGREEMENT

      Voluntary partnership agreement between EPA and Computer Manufacturers

ENERGY STAR COMPUTERS PARTNER COMMITMENTS:

      Introduce personal computer(s) and/or monitor(s) capable of entering a low-power
      state when" the unit is inactive

      A low power state is defined as < 30 Watts for either the computer or the monitor

      Educate customers about the energy savings and pollution prevention potential of
      turning off existing computers

THE fpA ENERGY If AR™ LOGO:	'' "'"';":	' '"" "": '	'""''"'' '. ''. '""""' •

      The EPA ENERGY STAR™ logo may be used to identify products that qualify

•    ;The ENERGY STAR™ logo makes its debut: one yearfrorri the launching of the
      program, on June 17, 1993
     i,!"!!1  '"',  i1  ' ,!„ ,"  il'flli'i'lili ' l1,,'"	• ",' :  I,1,,1! Win"*,, 	"im'iii , I'' M'11 a "i i1!,!1* i, »  f "!iii,'! l!,i "'' • : !• '.' i,"I!', ,•'" '	.'i'1	•"" iiiinU «, (,!! '•»'!:'*'' „„    ' '   • • ,'!>  ;   •
*     EPA seeks only to promote energy-efficiency and does not endorse any particular
      company or its products; this will be noted by Partners wherever the logo is used

EPA COMMITMENTS:

.     Recognize Partner for its public  service in protecting the ehvi ronment

*     Promote public awareness of energy-efficient computers

*     Encourage companies  to buy products bearing the ENERGY STAR™ logo through its
      voluntary purlhasing programs

•     Work with U.S. agencies to encourage Federal procurement of products bearing the
      ENERGY STAR™ logo, when evaluating approximately equivalent products
                                      137
                                    '•,	.,"•, : I'll'' •!':!'; l"'" ", "ii! ' ', ; ",

-------
 .•^'
;?
3
o
v-
          •f*
            TJ
            .0*
         EPA
ENERGY STAR
 COMPUTERS
I^M^:
EPA PQLLUTIQM PREVENTER
                SUMMARY  OF PRINTER AGREEMENT

     Voluntary partnership agreement between EPA and Printer Manufacturers

ENERGY STAR.PRINTERS PARTNER COMMITMENTS:

•    Introduce printers capable of entering a low-power idle state:
Printer Speed
(Pages Per Minute)
1 -7
8 - 14
1 5 and above,
& color laser printers.
Default Time to
Low-Power State
(Minutes)
""•15'
30
60
Max Power ;in s
. ...Idle State
(Watts)
30
30
45
      Educate customers about the energy savings and pollution prevention potential of energy
      efficient printers

THE EPA ENERGY STAR™ LOGOr                    .

      The EPA ENERGY STAR™ logo used to identify .products that qualify

      The ENERGY STAR™ logo makes its debut June 17, 1993

      EPA seeks only to promote energy-efficiency and does not endorse any particular
      company or its products; this fact will be noted by Partners wherever the logo is used

EPA COMMITMENTS:                            .                    .
                                                           i       •
      Recognize Partner for its public service in protecting the environment

      Promote public awareness of energy-efficient computer equipment

      Encourage companies to buy products bearing the ENERGY STAR™ logo through its
      voluntary purchasing programs

      Work with U S agencies to encourage Federal procurement of printers bearing the
      ENERGY STAR™ logo when evaluating approximately equivalent products
                                     138

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•COUNCIL FOR ECONOMIC PRIORITIES'
 V  SHOPPING FOR A BETTER WORLD

-------
COUNCIL FOR ECONOMIC PRIORITIES' SHOPPING FOR A BETTER  WORLD
        • •          *               '    "            i
Introduction

       •In 1988 the Council for Economic Priorities (CEP) published the first edition of a book
tilled Shopping for a Better World,  in which producers of consumer goods  and services are
ranked on the basis of a wide  variety of criteria.  In addition to environmental  issues (such as
the amount of toxic substances that the company releases), companies are judged based on such
social issues as, the advancement of minorities and women to top level management, the  level
of investments in South Africa, and donations to charity.

       The 1989 edition of the book rates 138 manufacturers of 1,600 consumer products.  The
book resembles a collection of report cards, rating companies with a three-tiered check (v/),
check plus (v/+), or check minus C/-) for each category.              „.

  •     A new edition-of Shopping for a Better World for teenagers, .called Student'Shopping for
a Better World, was published in 1992.  In this book, CEP uses a different rating system (A =
excellent,  C '=  average,  F  =  failed)  and  new  criteria  (listed  below)  to  update  their
environmental ratings.  If a company has become "greener"  since the last publication, it will be
recognized for improvements  in its overall environmental performance.

Structure

   ' The.review process at CEP  is relatively informal.  CEP staff decide on which criteria they
feel capable of assessing, which generally  includes non-scientific data.  With the criteria  in
place, the Environmental Ratings Researcher examines the  companies and awards the ratings.

Process

    The Environmental Ratings Researcher uses the list of criteria created by  the CEP staff and
.compares companies within an industry against  one another, taking into consideration the size
 and financial stature of a'company.  The environmentally oriented criteria that CEP will use for
 the next edition are as follows:  '

        •     toxic release inventory:  the amount  and nature  of pollutants  released to the
              environment
        •     toxic reductions
        •     disposal techniques:  how they dispose of chemicals and waste
        •     superfund sites
        •  •   hazardous products
        •     formal environmental policy of the company
        •     where  responsibility lies in the company
        •     compliance with regulations
        •     recycled content, of packaging

                                           140

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              :     •      amount of packaging
                   •      office recycling: what they recycle and how much
 =             "...    •      sustainable use of raw  materials and waste reduction: what they do to conserve
              ::..:          resources
                   •      enetgy conservation
                   •      donations to environmental organizations
                   •      purchasing practices
                   •      cdmniunity health issues
                   •      accident record (Jonathan Rose, CEP, 1992)

            If a company is on the borderline between ratings once the above criteria are assessed, CEP will
            look at a company's litigation record and technological improvements.
              ii!1'1 ''  _ * "I  '' 	• '•:. Ijjijiii!1!!!! , •   " •>	; ' .( "' ,,;, f :/'•;,; ji ;'i.', VtfJ' .•''.;•' ';' '< I1.1'.' >"'''!''I .'v	 ;"," v,'!*''1;  ' '                   '",
              !: i   tlieteselrcheygathersinfomiatiOT                                 ^questionnaires
            rilled out By companies; 2) printed material and interviews with company officials; 3) specialized
            ijtitutions sucK  as  EPA,  Greenpeace  and the  Natural  Resources Defense Council; and  4)
            libraries  and government agencies.

            Public Review Process     ':     "   ...,',,'	  '„	'„''„';	', '	\	.,',

i|    '    '  '; ^oMq;'puDiicatfon:'!CEl?''s^                                	that they used to assess  !ts
            f ting and the rating that the company will be given.  The company is allowed to respond to its
            rating, offering more information if  it chooses.

             Effectiveness
                     In a 1289 poll of 1, 000 buyers of Shopping 'for a Better World, CEP found that 78
             percent had switched brands because of ratings in the book, that 64 percent referred to the book
             Whenever .'"they shopped11 and that 97 percent considered the environment "their top or near top
             priority' >"' Ben 
-------
SCIENTIFIC  CERTIFICATION SYSTEM'S
    ENVIRONMENTAL REPORT CARD
       PRODUCT & PACKAGING:

       TYPE OF BURDEN  -   AMI.*
       WATER     .     35kg
       WOOD          230 g
       COAL, OIL, GAS (non-fuel) • 0,4 g
       MINERALS        120 g
      Ml
   31!
TOTAL ENERGY USED

                    23 MJ
 CARBON DIOXIDE
 CARBON MONOXIDE
 SULFUR OXIDES
 NITROGEN OXIDES
 HYDROCARBONS
 PARTICULATES
 UNCLASSIFIED
 HAZARDOUS
 OZONE LAYER DEPLETERS

"TOTAL SOLIDS
 OXYGEN DEPLETERS
 TOXIC
                     19 g

                     79
                    240 g
                     3g
                    0.008 g
                    500 mg
                    Oi
       UNCLASSIFIED
       HAZARDOUS
              260 g
            2,600 mg
            1-80Q-ECO-FACTS
       SCIENTIFIC CERTIFICATION SYSTEMS
                    [BETTER
                    ! LOWER BURDENS
                             10*
                                   lOOx
   WORSE
HEAVIER BURDENS
                                           l,000x
                                                10,000
                      * PER 122 GRAMS OF PAINT SOLIDS

-------
 SCS ENVIRONMENTAL REPORT CARD

       The Environmental  Report Card  approach: to: environmental  labeling involves the
rcategdrfeafion and inventory of environmental burdens (such as carbon dioxide emissions or the
 amount of hazardous solid waste generated) associated with the life-cycle of an industrial system
 related to a specific consumer product:  The report card  lists these burdens directly  and also
 provides a bar graph representation of these burdens on an exponential scale.  This scale reflects
 the potential range of burdens  for  all  consumer products, enabling  the reader  to  compare
fproducts  not only within the same category, but across othercategories as well.  In theory, the
 report card is an impartial instrument with which to present multiple criteria, the idea being that
 consumers ban-Select products based on criteria of particular concern to them.  At this time, only
 Scientific Certification Systems (formerly Green Cross) is offering a version of this method _of
 environmental labeling, with its LCI-based Environmental Report Card   As of mid-1993, the
 SCS Report Card appeared."611 nine products, including trash bags, recycled-fabric clothing, and
 spray paint.

 SCS Certification Program
               |l                    i                      i"      , .!•   •  v' •'•  '•  •, '  , ;.'..•;
        Initiated  in 1989 by  Scientific Certification Systems, the Green  Cross  Environmental,
 Certification Program was an independent, no^for-profit certification program  with tte stated
 goal of "verifying the accuracy arid significance of environmental claims on products    SCb has
 recently  consolidated all of its certification programs (including Green Cross) under its own
 name and has  applied for 501(c)<3) non-profit tax exempt status, partly in response to criticism
 over possible  conflicts of interest due to the for-profit nature of the parent corporation.  SCS
 also recently announced its  alliance with the Good Housekeeping Institute, which will  advise
 SCS on  various product issues.

        The sled long term program  goals for SCS are to 1) support  consumers'  efforts  to'
  optimize their product choices with "coherent,  comprehensive  environmentalinformation ;  2)
  provide companies with independent feedback  about the environmental  ramifications of their.
  products; 3) encourage manufacturers' efforts to meet the highest environmental standards  m
  broduct  design  and production;  4)  build a  consensus  on  what constitutes  a  significant
  environmental claim; and 5) help policy makers to set down effective environmental policy.

         SCS'slabeling program has evolved into three  distinct areas: 1).environmental claim
  certification (e.g., recycled content, biodegradable) (see Section ™*2\*^l^J^:
  attribute clainis
-------
emissions,  and  solid wastes) • associated  with the  raw  material extraction,  manufacture,
transportation, use, and disposal of a product.  Under SCS's LCI, inputs and outputs under the
following categories are quantified for each stage of material extraction, manufacturing, use, and
disposal:

       •     resource depletion
       •  ' .  energy use.        •                     • .    '      .       .
       •     air emissions
      ,•     water emissions
       •     solid waste generation

For  each  labeled product,  the SCS  Environmental Report  Card lists  approximately  twenty  -
categories of environmental burdens.  According to SCS, these categories have been'selected to
be consistent with Clean Air Act, Clean Water Act,  and Resource, Conservation and Recovery
Act  (RCRA) regulations.   A numerical value is provided for each burden; these values are
derived by studying the life-cycle of the industrial system associated with, the product (e.g., kg
of carbon dioxide released during manufacture).                    ,

       The LCI analysis is based on  the philosophy  that while the ultimate fate or effect of an
environmental emission is not clear,  it is reasonable .to  assume that the less emission released,
or the less resource used,  the better for the environment.  Once the LCI has been completed,
the results are presented on the Report Card label, which consists of a bar graph, with an entry
for each category-of environmental burden.  Displayed in an exponential scale, the bar graph
documents the  "environmental burden" of the  labeled product by  displaying a bar for  each of
20-odd different environmental impacts that are measured.  The bars run horizontally across the
page,  with smaller bars indicating  "less"  environmental burden  and  longer bars indicating
 "more" environmental burden. Also included on the label are the numerical values for an impact
category,' which may range anywhere from zero (e.g., 0 kg of carbon dioxide released)  to some
 highest value as determined by the  product  which is the  most offensive in that particular
 category..

        The Report Card has been referred to  as the environmental equivalent of a nutritional
 label, and is designed to "provide a full disclosure to the public of the known/calculated input
 and output burdens.. .associated with a particular product."  This provision of information by the
 Report Card confers  upon it an advantage  over a standard  seal-of-approval  environmental
 certification program, which only considers "a subset of [all] input and output categories" in its
 evaluation process. (SCS 1992b) SCS selected the report card approach  over the seal approach
 in order to "ensure that environmental trade-offs were not overlooked.. .and to find a mechanism
 capable of representing the full spectrum of environmental performance in products." (SCS,
 1993)  SCS. emphasizes that the Report Card simply provides information to the consumer, and
 neither advocates nor condemns a particular product.

        However,  the Report Card has been criticized as being overly complex for the average
 shopper, and its presence may  be construed as an endorsement  by SCS despite its claims of


                                           145

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                           "!	It,, ' .j1!	I!',"" I'
  	'  ,'.   ,'•'•,' ••  ' iiisi  ,!•;,'  .  '• :  i   I;,1".1 ;'! ,.,. ;',!.;! :i 'v">: M,,!,!1 :v..., •ii*:;Ji*a ',""'' .'i t&.t'l-'i.  •'   ''.  -     •'
 neutrality.  In addition, many products Within one product category must carry the Report Card
 in order for the consumer to make comparisons among them.

        SCS Report Card Certification is a multi-step  process,  involving identification  and
 quantification of  inputs and outputs  for every stage of a product's life cycle, site inspections,
 record audits, emissions sampling and testing, and quarterly monitoring (if certified).

 Structure

        Approximately a dozen people are  working on  the Environmental Report Card staff,
 although SCS is  planning to increase this number in the near future;   Typically three or  four
 people are involved in a certification evaluation.

 . &  .!'.• ,"X i'4-me^i»r''$cien^                                               from various
 sBentiflc and economic disciplines,  advises the SCS stiff during the evaluation procedure.

 Certification Process

        As presented by SCS in a  1992 document, the 'certification process has nine stages, and
 takes place over the course of a year's  production (SCS 1992b) The process is outlined as
 follows:  ^     ^  	          t"     [  / ,'',...    t  '.  ,   	'  ' ,'„„ '.'.,'
•  ,:        ,  	 suft.  '.    "••  ;•   •>::.   '• ':..  ,:' •';  ""•  .  "  	•'•   ,.,,;:  ; •:." .•: ...'.'•'     :
 Phase I.

 Stage I: Define  Project

 a.     Identify product(s) to be evaluated.
 b.     Define system(s) of inputs and outputs.
 c.     Define project objectives.
  d.     Write proposal.
 eV    Identify project manager and client'technical teams.

  Stage II: Prepare Flow Diagrams
  a.     Collect existing flow diagrams/schematics from client.
  b.     Prepare flow diagrams for each component of system, including all potential inputs and
         outputs (see flow diagram).

  Stage HI: Prepare Inventory Data Sheets

  a.     Generate inventory data sheets for each component identified in flow diagrams.
  "b.     Determine required documentation for initial documentation review (e.g. invoices for
  t* ;     :,  "(.!•(•. f	'	'i	• '	v"	"li" 	'	'	•
         material purchases).
  c.     Determine which site(s) should be physicaUy inspected.
  :',.,.    in •    "  • ii	nun'  "   	   ""in  	      	i1        ......             i            ,  ,
                i	in	   ""in
                                              146

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Stage IV: Site Inspections (2-3 visits/site) -   ,                      '

a:      Review inventory sheets.        •       .                       .     ;  •    •'  .
b.    '  Assist in completion of inventory sheets where additional data are'needed.
c.      Examine technical processes to ensure full consideration of factors.     .
d.      Confirm flow diagrams and make necessary changes.
e.      Conduct preliminary review of relevant documentation, including discussions with client
       technical team.
           L               ..ft                     '

Stage V: Data Management

a.      Prepare data input sheets and input data - Reduction of Raw Data.
b.      Conduct data quality review.           :
c.      Perform necessary calculations and revisions.

Stage VI: Presentation of Findings to Client

a.      Submit detailed LCI report.                         ,
b..     Review report with client.

Phase  H.

Stage VII: Final  Auditing and Testing
a.     Full audit of records, invoices, and support documentation.
b.     Sampling and testing,to confirm emissions data.
c.     Final inspection:
d.     Development of Quarterly Update Certification Plan.

Stage VEtt: Peer Review

Stage EX: Certification                                     •  "..

a.     Issuance of  full  report,  with executive  summary describing data  quality,  and
       corresponding Environmental,Report Card. Before the report or the Report Card may
       be released to the public, the applicant must  satisfy all federal and state environmental
       regulations.  Companies are free to publish their Report Cards, provided that the more
       in-depth study reports are made available upon request to  the public.

Stage X: Monitoring

a.     Once a Report Card has been published, SCS  monitors company performance on  an
       annual basis, with recycled content monitored quarterly.  The monitoring plan includes


     ':                              '  •  .    147  -  '

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                                         148

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       such components as review of emissions  report's,  reverification  of  material  sourcing,,
       random resampling and testing, examination of plant records, etc. (SCS 1992b, 1993)

The client pays fortesting fees but does not pay any  licensing or royalty fees.

References       ,

       Brown, Linda, Vice  President of Communications,  Scientific Certification  Systems,
       1992.  Personal Communication with.Abt Associates, November  12.

       Scientific Certification Systems, 1992a.  Information Packet.         ,

       Scientific Certification  Systems,  1992b. Life Cycle Inventory  and the Environmental
       Report Card, May 5.      '       .      „            .        ; ....         -

       Scientific Certification Systems, 1993.;  Personal communication with Abt Associates
      .Inc., May 9, 1993.
                                          149

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	„;;,
i1' „'
  PESTICIDE LABELING UNDER THE

 FEDERAL INSECTICIDE,"FUNGICIDE,

      AND RODENTICIDE ACT

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PESTICIDE LABELING UNDER THE FEDERAL INSECTICIDE, FUNGICIDE, AND
•RODENTICDDE ACT

       The Federal Insecticide,'Fungicide, and Rodenticide Act ' (FIFRA)  first enact   n 1947
and subsequently amended, requires the registration of pesticides and pestle P
the-U.S.  Environmental Protection Agency.  Pesticides, as defined by .FIFRA  are
designed  to prevent, destroy,  repel, or mitigate any pests, or to regulate, defoliate, or
plants.          . '      ,'

       Each of the 600-odd pesticide active ingredients in use today must pass a set of health'


                      tzssrzzs. ??<^3
 registration,  the labelling of each product is  reviewed and approved by the Agency.

 Pesticide Labeling

       FIFRA requires labels to appear on the containers of every pesticide product sold in the
 US   and imposes  standards and  restrictions regarding the wording and format (40  CFR
 §156'. 10) As outlined in the Code of Federal .Regulations (CFR), a pesticide label must clearly -
 and prominently display the  following information:

       a) The name, brand,  or trademark under which the product is sold;   ~     .   .   .
       b) The name and address of the producer, registrant, or person for .whom produced,
       c) The net contents (weight or measure);                     .       ,
       d) The product registration number;
       e) The producing establishment number;
       f) An ingredient statement;                '
       g) Warnings and precautionary statements;
        h) The directions for use; and          ,
        i) The use classification(s) (restricted use).


  Ail  required label text must be set in 6 point type or larger, and must appearJj ^g^The
  Agency, however,  may require "additional text in other languages if it is considered necessary
  in protecting the public health.

         The Office of Pesticides Programs (OPP) at EPA reviews eachpesticide label ^^y
  to ensure appropriateness and accuracy, (Frane, 1993) The particular e™ro™fi°'^
  effects  of a rLFcide may prompt EPA to require additional warnings or messages to be included
  on  its label (e.g., groundwater advisory statements, chronic hazard warnings).

         The various components  of the label are discussed in more detail  below.  Label
              as described below are taken from the 40 CFR §156.10. The regulations set only
                 n label content. In practice, the Agency has wide latitude to require, oraccept,
                                          152

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^ateirstiiSs "ihut 'deviate from the	regulations','	and ""many	statements"	that are accepted  .reflect
variations baied on product type and use.

A.     Name, brand', or trademark: the name that appears oh the label must be registered with
       the EPA, and not be false or misleading.

B.     Name and address  of the producer,  registrant, or person for whom produced:   If the
registrant's name that appears on the label  is not the producer of the pesticide, it must be
qualified by appropriate wording such as "Packed for ***,"  "Distributed by ***," etc.

C.     Net contents (weight or measure):  The net weight or'measure, exclusive of wrapping
materials, must be stated as an average content unless explicitly  stated as a  minimum quantity.

D.     Product  registration number:  The EPA registration number (often abbreviated to "EPA ,
Reg! No.") assigned to the pesticide; productat the time of registration must appear on the label.

E.     Producing establishment number: The producing-establishment  number, preceded by the
phrase "EPA Est.,s must appear on the  label or on the immediate container.


F. 	   Ingredients statement:  The ingredients statement "Is '"normally required on the front panel
of the label. If there Is an outside container or wrapper through which the label cannot be read,
theni the ingredient statement must also appear on that container or  wrapper.

   :"   The label of each pesticide product must bear a statement that contains  the name and
percentage by weight of  each active ingredient, the total  percentage by  weight of all inert
ingredients. Each ingredient must be referred to by its accepted  common name, if there is one.
If no common name has been established, then the chemical  name must be used.  Trademarked
names not accepted as common'names are not allowed.

        Pesticide products that contain one or more chemical components that change significantly
over time must also include a statement that reads: "Not for sale after [date]."

G.     Warning and precautionary statements

   E  :  Required warning and precautionary statements regarding lexicological hazards to  humans
fall into two groups: those required on the  front panel and those that may appear elsewhere.
Tlie  chUd hazard w                                 hazard  signal word (see below) must
appear on the  front panel of a pesticide label.  Other warnings and  messages, including the
 statement of practical treatment (except in the cases of extremely  toxic products), health and
environmental  precautionary statements, and physical and chemical  hazard statements,  may
appear elsewhere on the label.

                                           153

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    1.      Child hazard warning  .

           Except for those products deemed safe for use on children or infants, or  where
    the possibilityof contact with children is exceedingly small, all pesticide product labels
    must bear on the front panel  the warning "Keep  Out of Reach of Children.

    2.     Toxicity Categories

           The text required on  the front panel of the label is determined by the Toxicity
    Category of the pesticide product.  A pesticide is assigned a Toxicity Category  based on
    its highest hazard potential in any of the following indicators listed  in Table 1:   .
                          Table 1: Toxicity Category Definition
                                                 Toxicity Categories
                     up to and
                     including
                     mg/kg
                     up to and
                     including 0.2
                     mg/liter	

                     up to and
                     including 200
                     mg/kg
                      corrosive; coraeal
                      opacity not rever-
                      sible . within 7 days
from 200 thru
2000 mg/kg
corrosive
corneal opacity
reversible within 7
days; irritation for
7 days
                                        severe irritation at
                                        72 hours
                  from 500 thru 5000
                  mg/kg
                  from 2 thru 20
                  mg/liter
                                    from 2000 thru
                                    20,000 mg/kg
no corneal opacity,
irritation reversible
within 7 days
                   moderate irritation
                   at 72 hours
                   greater than 5000
                   mg/kg
                   greater than 20
                   mg/liter


                   greater than 20,000
                   mg/kg   ..
                                                                             no irritation
                    mild or slight
                    irritation at 72
                    hours
NOTES-  LD. is the lethal dose at which 50% of the animals in lab testing die.  LDX is measured in mg
p °Sde pef kg bodyweight. LC* is the lethal concentration at which.50% of the anunals m lab testmg d,e.
LCso is measured in mg pesticide per liter of air.
SOURCE: Consumers' Research, July 1992; 40 CFR §156.10
       3.      Human Hazard Signal Words

              Pesticide labels must  bear specific signal words,  depending-on the pesticide's
       assigned Toxicity  Category.
                                               154

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             A pesticide that meets the criteria of Toxicity Category I must bear the signal
      word "Danger" "on the front panel of its label.  In' addition',' if the product was assigned
      to Tpxicity Category I based on its oral,  inhalation, or dermal toxicity, the label  must
      also bear the word "Poison"  in  red .on a background of distinctly contrasting color and
      the skull and crossbpnes symboi must appear in close proximity to the word "Poison."

             A pesticide meeting the criteria of Toxicity Category H must bear the signal  word
               *1 "oh" the front panel of its label.
             A Pf sticide meeting the criteria of either Toxicity Category m or IV must bear
      the signal word "Caution'' on the front panel of its label.
      4.     Statements of Practical Treatment (First Aid or btner)

             For pesticides in Toxicity Category I, a statement of practical treatment (i.e. first
      aid) is normally required on the front panel, although in practice reasonable variations
      are permitted by EPA.  For other pesticides,  statements of practical treatment are not
      required on the front panel, but must appear elsewhere on the label.

      5.     Other Required Warnings and Precautionary Statements
        , ,.                             i                              ,,,,',
             Other appropriate warnings and precautionary statements must appear on the label
      under thegeneral heading" of'"Precautionary Statements," and under the subheadings of
      "Hazard '_to; Humans' ''and Domestic AnirnalsJ1 ''Environmental Hazard," and "Physical or
      Chemical Hazard."    :  ,    i	 ..  ,. 	,  ,_„	

             Typical precautionary statements  indicating  hazard to  humans and domestic
      animals  are  listed in  the table below, and are arranged by Toxicity Category.   Other
      statements are also used — there is considerable variability in hazard statements.
               PI n H
       If a pesticide is found to be'potentially hazardous to non-target organisms (excluding
humans and  domestic animals), the  text on its  label must include precautionary statements
describing the nature of the hazards  and the appropriate precautions to avoid problems.  For
example, for a pesticide.'intended" for outdoor iise, which contains an agent with an acute oral
Ljpi0 of 100 or less, the label must read,  ''This Pesticide is Toxic to Wildlife." Other statements
address toxicity to birds, fish, and aquatic  organisms.

       Finally, for chemical or physical hazards, the required precautionary statements are listed
below in Table 3

H.     Directions for use

       Exceptingjpesticides that are not destined for consumer use, all pesticide labels must have
printed on them detailed use instructions or references to accompanying instruction leaflets.

               d  •  ..•.''  ;••'  ••:,.,: ;>••:":J.V05 ',   ''    ":   ,:";:          '  •.

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         Table. 2.  Hazard'to  Human and Domestic Animal Precautionary Statoment-s
   Toxic ity
   Category
      II
                                       Precautionary -statement by Toxicity Category.
                       Oral, inhalation, or dermal toxicity
                 Fatal (poisonous) if swallowed (inhaled or
                 absorbed thru skm'l. Do not breathe vapor [dust
                 or spray mist). Do not get,in eyes, on skin, or
                 on closing [Front  panel statement of practical
                 treatment required].
May be fatal if swallowed [inhaled or absorbed
thru the skin]. Do not breathe vapor [dust or
spray mist]. Do not get in eyes, on skin, or on
clothing [Appropriate first aid statements
required].            •	'  	•
                                                      Skin and eye local effects
                                              Corrosive, causes eye and skin damage [or
                                              skin irritation]. Do not get in eyes, or skin,
                                              or on clothing. Wear goggles or face shield
                                              and rubber gloves when handling. Harmful
                                              or fatal if swallowed. [Appropriate first aid
                                              statement required].    	 _   	
Causes >eye [and skin] irritation. Do not get
in eyes, on skin, or on clothing. Harmful if
swallowed. [Appropriate first aid statement
required].
      ra
Harmful if swallowed [inhaled or absorbed thru
the skin].  Avoid breathing vapor [dust .or spray
mist). Avoid contact with skin [eyes or
clothing].  [Appropriate first aid statements
required].	
Avoid contact with skin, eyes, or clothing.
In case of contact imnrediately flush eyes or
skin with plenty of water. Get medical
attention if irritation persists.
       IV
 [No precautionary statements required].
                                                               [No precautionary statements required].
SOURCE: 40 CFR §156.10.
                 Table 3. Physical or chemical hazard precautionary  statements
                     Flash Point
                                                                        Required Text
                                    (A) PRESSURIZED CONTAINERS.
Flash point at or below 20°F; if there is a flashback at
any valve opening.
                                    Extremely flammable. Contents under pressure. Keep
                                    away from fire, sparks, and heated surfaces. Do not
                                    puncture or incinerate container. Exposure to
                                    temperatures above 130°F may cause bursting.	
 Flash point above 20°F and not over 80°F or if the
 flame extension is more than 18 in long at a distance of
 6 in from the flame.
                                    Flammable. Contents under pressure. Keep away from
                                    heat, sparks, and open flame. Do not puncture or
                                    incinerate container. Exposure to temperatures above
                                    130°F may cause bursting. ^^	
 All other pressurized containers
                                     Contents under pressure. Do not use or store near heat
                                     or open flame. Do not-puncture or incinerate container.
                                     Exposure to temperatures above  130°F may cause
                                     bursting.	
                                  (B) NONPRESSURIZED CONTAINERS
 At or below 20° F
                                     Extremely flammable. Keep away from fire, sparks, and
                                     heated surfaces.	
 Above 20 °F and not over 80 °F
                                                      Flammable. Keep away from heat and open flame.
  Above 80 °F and not over 150°F
                                                      Do not use or store near heat or open flame.
  SOURCE: 40 CFR §156.10.
                                                    156

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 "   i       i       	Ill  i        'I  ' i    i    I    ' I          1,1 l|l| 1      .••',,•.,  •  -  • "  :'  .

    |h   The directions must  appear under the heading  "Directions for use," and include the
 following:
                  l|l||l|          '    I        I                     I I      .'.'••'.'•'•• I
 a)     the statement of use classification (sec section I, below);
 b)     the statement  "It is a  violation of Federal law  to  use this  product in  a manner
        inconsistent \vith its labeling; "
 c)     the sites of application (e.g., crops, lawns, etc.), or objects to be treated;
 d)	   the target pests;	'   	'	 	_
 e)     the dosage rate;
 f)     the method of application;
 g)     the proper frequency and timing of application;
 h)     the reentry statement (if needed), which specifies the length of time that must pass before
      •  people can reenter a treated area;
 1)     the disposal directions; and
 j)     any use limitations or restrictions required to prevent unreasonable adverse effects.
   1 •	in ,1	"';',, »:';
-I.  	Use classification  	          i  _	      '^            ,             •

        Every registered pesticide has one or more RPA-designated uses.  Each of these uses is
 evaluated for hazard potential and  may be classified for restricted use if necessary  to  protect
 human health or the, environment,

        1.     General Use Classification
   /I'll ,                                                                '' .',''.,"

               Products designated  for general use must be labeled  with  the  words "General
        Classification," which must appear directly below the heading "Directions for Use."
   :ivi ... ' •''  ii        ii i 111  i      ii     mi       i      ii     i   ii     ii     ,'',  .  , •  ,  ,,''''    , '
               Restricted Use Classification
               Products designated for restricted use only must include the words "Restricted Use
        Pesticide" on the front panels of their labels.  A statement describing the nature of the
        restrictions and  the  reason for the restriction  must appear directly  below the above
        statement.  If the product is to be sold to Certified Appb'cators only,  the following
        statement must also  appear  "For retail sale and use only by Certified Applicators or
        persons under their direct supervision and only  for those uses  covered by the-Certified.
        Applicator's certification."   For each specific pesticide, other  additional restriction
        statements may be required by EPA.

 Enforcement

        According to FIFRA Sec. 2(q) and 12 (Federal  Environmental Laws,  1988), failure on
 the part of the pesticide producer or registrant to comply with labeling  requirements  may be
 considered  "niisbranding" of the  pesticide.   Sales or  distribution of a  misbranded pesticide

                   	  ;  .'	is?'                 '      '•

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constitutes  an  unlawful  act.  'The Environmental Protection  Agency may then cancel the
registration, or bring criminal  and/or civil charges against the registrant or producer of the  .
pesticide.   -                                .              .

References                            >

  •     Code of Federal Regulations, 40: PARTS 150 to 189.  Revised as of July 1,  1992.

       Committee on Scientific and Regulatory Issues  Underlying Pesticide Use Patterns and
       Agricultural Innovation, Board on Agriculture, and the National Research Council (US),
       1987.  Regulating Pesticides in Food: The Delaney Paradox.  National Academy Press,
       Washington D.C.      .                             '       .
                                                                                      •
       Consumers' Research,  1992.  "How to Read Pesticide Labels," July.r  pp 34-36.

       Federal Environmental  Lam, 1988 Edition, 1988. West'Publishing Co., St. Paul, MN.

       Frane  Jean,  U.S. EPA, OPP,  1993.  -Personal  Communication with Abt Associates.

       Hurst,  Peter, Alastair Hay, and Nigel  Dudley,  1991.   The  Pesticide  Handbook,
       Journeyman Press, London, Concord MA.                 '      .

     ~ Tweedy,' E.G.,  et al.  eds.,  1991. Pesticide Residues and Food Safety: A Harvest of
        Viewpoints, American  Chemical Society, Washington D.C. pp 324-332.

        U.S. EPA, undated. Simazine Reregistration Guidance Document.
                                            158

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PRODUCT LABELING UNDER
 THE TOXIC SUBSTANCES
  CONTROL ACT (TSCA)

-------
PRODL'CT LABELING UNDER THE TOXIC SUBSTANCES CONTROL ACT (TSCA)

       The Toxic Substances Control Act (TSCA) was enacted by Congress in the fall of 1976
to identify and control toxic  chemical  hazards  to human health and the  environment.   "To
prevent unreasonable risks," the Act gives EPA  the authority to  "select from a broad range of
control actions under TSCA, from  requiring hazard-warning labels to outright bans.on  the
manufacture or use of especially hazardous chemicals.1" (EPA, 1987)

       Section 6(a)3 of TSCA allows the Administrator to apply:

       a requirement that  such substance or mixture or any article containing'such
       substance or mixture be marked with or accompanied by clear and adequate
       warnings and instructions  with respect to its use, distribution in commerce, or
       disposal  or with respect to any combination of such activities.  The form and
       'content  of such  warnings  and  instructions  shall be  prescribed  by  the
       Administrator. (PL 94-469)

       The law does not specify the form or content of the warnings,  nor has EPA promulgated
~any regulations  establishing a single consistent method of labeling.' To date, labels have been
 required or proposed for chemicals and products on a case  by case basis.  To date, regulated
 chemicals and products subject to TSCA labeling include PCBs, asbestos, hexavalent chromium
 and acrylamide  grout.                                                           ,

 Examples of TSCA Labels

        Polychlorinated biphenyls (PCBs) were  regulated under  TSCA in  1978.   The labeling
 section of this rule required one of two labels to  be used, a "Large PCB Mark" or a "Small PCB
 Mark."  The large label states, "Caution:  Contains PCBs,  a toxic environmental contaminant
 requiring special handling and disposal in accordance with-U.S. EPA regulations 40 CFR  761.
 For disposal information contact the nearest EPA office.  In case of accident or spill, call toll
 free the  U.S. Coast Guard  National Response Center. "   The small label states,  "Caution:
 Contains PCBs. For proper disposal contact U.S. EPA. "

        The  labeling of  asbestos was  required in 1989 as part of regulatory  actions which
 included a ban on "almost all products" containing asbestos.  Consumer products containing
 asbestos include  clutch  parts and brake shoes for cars and trucks, pipeline Wrap and vinyl
 asbestos floor title.  The labeling aspect of the rule is intended "to facilitate compliance with and
 enforcement of the rule."  The required label stated,  "Notice:  This product contains asbestos.
  The-EPA has banned the distribution in U.S. commerce of this product under section 6 of TSCA
  (15 U.S. C.  2605) as of [date, ranging from August 1990 to August 1995]. Distribution of this
 product in commerce after this date and intentionally removing or tampering with this label are
  violations of Federal law. " (54 FR 29460)
                                           160

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 ';V •   HexavaJent chromium-based water treatment chemicals used in HVAC and refrigeration
 systems, v, ere regulated under TSCA in 1990. (55 FR 221) The warning label reads, "Warning:
 Py*. Pro^ltct con,yifls hexavalent^ chromium.  Inhalation of hexavalem chromium air emissions
           *. ri& 9fllinS cancer. Federal law prohibits use of Ms substance in comfon cooling
           ch are towers that' are open water recirculation devices and that are dedicated
      i.Ypfy co'  <*™i,. ore  an  integral part of,  heating,  ventilation  and air conditioning or
 refrigeration systems. "
               proposed a ban on acrylamide and N-methylolacrylamide ,(NMA) grouts, which
    used to make repairs to  leaking cement structures such as sewers and manholes, but also
dams and basins,  and to stop water flow in mines, reservoirs and hazardous waste sites. The
b|n, WOU:F prohibit all use of acrylamide grout and would allow NMA to be used only for sewer
     r ror three years> subsequently banning it.  EPA proposed labeling of containers of such
      15. days after the effective date of the rule.  "JEPA belieyes there is a strong need for
     ing to ensure  compliance with the prohibitions on the manufacture, importation, distribution
and use of acrylamide and NMA grouts.   Labeling is a necessary mechanism to  direct  users
tftward compliance with the prohibitions  on uses of acrylamide  and NMA grouts." (56 FR
49871)  No wording  for the label warning  has been suggested.


References

      Axelrad, Dan, Office of Pollution ^Prevention and Toxics, Exposure, Economics and
      Technology  Division,  Regulatory  Impact  Branch,  U.S.  EPA,  1993.    Personal
      communication with Abt Associates, February 26
      y.S.. EPA,  Office of Toxic Substances,  1987.  The  Layman[s  Guide to the  Toxic
      Substances, Control Act, EPA 560/1-87:011, June.

      U.S. .EPA, Office of', Toxic ^Substances,,, 19.89.  "Asbestos; Manufacture, Importation,
      Processing and Distribution in Commerce Prohibitions," Federal Register, 54 FR 29460
      July 12.
      U.S. PA, Office of Toxic Substances, 1990.  Prohibition of Hexavalent Chromium
      Chemicals in Comfort Cooling Towers," Federal Register, 55 FR 221, January 3.

      U.S. EPA, Office of Toxic Substances,  1991.  "Proposed Ban  on Acrylamide and N-
      Methylolacrylamide Grouts," Federal Register, 56 FR 49863, October 2.
                                         161

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CALIFORNIA PROPOSITION 65
        WARNING:THIS PRODUCT CONTAINS
        DETECTABLE AMOUNTS OF CHEMICALS KNOWN TO
        THE STATE OF CALIFORNIA TO CAUSE CANCER
        •AND/OR-REPRODUCTIVE TOXICITY.

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 ^AJJFORNTA PROPOSITION 65

 w ' "'!'::i'ealifbnMaS!"P^^	as'the Safe Drinking Water and Toxic
 Enforcement Act of 1986. is an initiative statute that was placed on the ballot by citizen petition
 lue"to'concern over inadequate	governmental public health regulations.  Although the law was
 Sposea  By industry  and  agriculture groups as well  as  almost every major newspaper  in
 California, Proposition 65 was approved by the California electorate by nearly  a two  to one
 margin.  The purpose of the law Is to enhance community right-to-know, protect drinking water
 Supplies, and reduce toxics release.  (KLzer,  1988)

 •-      proposition 65  mandates  that chemicals found to  cause cancer, or developmental  or
 reproductive toxicity, be listed by the governor.  Warnings must be provided by businesses that
 knowingly and intentionally expose individuals to these chemicals  at significant levels.   In
 addition, discharge of these chemicals into drinking water supplies must stop within  twenty
 months of being  listed, except  in those cases where the discharger can demonstrate that the
 discharge is insignificant,  the'governor's list currently  includes over 500 chemicals; (391
 carcinogens and  150 reproductive  toxins)  (Cal/EPA  1993).   The  Act ,is  not  applicable to
 government agencies, drinking water utilities, and businesses employing fewer than 10 persons.
  (Cay EPA, 1992)

        Implementation of the Act for many products and industries has been subject to extensive
  industry attention.  The food, drug, and cosmetic industries lobbied to receive a temporary
  exemption from the law on the grounds that they are already regulated by the federal Food and
  Drug Administration (FDA).  In addition, these same industry groups tried to avoid the warning
  labels by  instead setting  up a toll free number for  product  information, which was ruled
  unacceptable by  the courts.  Proposition 65 warning labels have been implemented in other
.industries with less  opposition,  and  has  added significantly to the scope  of warnings on
  hazardous products.

         Proposition 65 has had some measure of success. It has resulted/for instance, in greater
  public awareness about the hazards of alcoholic beverage consumption daring pregnancy, and
  of tobacco smoke  exposure.  While data are not currently available on  actions taken by the
  regulated community to  remove  themselves from the purview  of Proposition 65, there is
  evidence that manufacturers have  reformulated products to eliminate or reduce exposures to
  listed chemicals to avoid having to provide warnings.  Proposition 65's effectiveness as a market
  based incentive for the reformulation of products has led to the removal of certain solvents from
  correction fluids, as  well as the removal of lead from certain ceramic products and from toil
 ""wrapsllbri"wm!bottles. (Cal/EPA, 1993)  In addition, Proposition 65  has resulted in process
   modification, chemical substitution or use of pollution control devices to eliminate or reduce
   emissions of listed chemicals that would have required community warnings.
                                             164

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 Structure

       California  EPA's  Office of Environmental Health Hazard Assessment  (OEHHA)  is
 designated as the lead  agency'for Proposition 65 implementation.  OEHHA'is "directed to
 implement the Act in a manner that,is fair, predictable, and based oh  a  firm  foundation of
 science." (Cal/EPA 1992)  OEHHA compiles the  list of carcinogens and reproductive toxins,
 prepares dose-response assessments on listed chemicals, promulgates regulations and provides
Assistance to the regulated community in complying with the law.  The authority to enforce
 Proposition 65  is vested in  the Attorney  General,  local district  attorneys,  and certain  city
 attorneys.  Private citizens may also take action to enforce Proposition  65, following certain
 conditions (see "Enforcement"). (Cal/EPA, 1993)  .  •

       The Governor's Scientific Advisory Panel, composed of 12-State Scientists from the Dept.
 •of Health Services, the Dept. of Pesticide Regulation, the Dept. of Toxic Substances Control,
.and the OEHHA, represent the state's qualified experts and perform a limited role in addressing
 the listing of chemicals. (Cal/EPA, 1993b)                                  ""
 Chemical Listing

       The lead agency compiles and publishes the list of chemicals known to the state to cause
 cancer or developmental/reproductive toxicity, and updates it at least annually.  A chemical  is
 listed:                         _            •

 1)     if, in  the opinion of the "state's qualified experts," the chemical has been clearly shown
       to cause cancer or reproductive toxicity;

 2)     if an  "authoritative" body  designated by  the "state's qualified experts"  has formally
       identified the_ chemical as a carcinogen or  a developmental/reproductive toxicant; or

 3)     if any state and/or federal agency has formally required the chemical to be  labeled or
       identified as a carcinogen or a developmental/reproductive toxicant.'      .

       A panel of state scientists  (the Proposition 65 Scientific Advisory Panel)  currently
 represents the "state's qualified experts,"  Authoritative bodies include the U.S. EPA, the FDA,
 the International Agency for Research on Cancer,  the National Institute for Occupational Safety
 and Health (NIOSH), and the National Toxicology Program (Cal/EPA, 1992).

 Business Requirements

 1.     Twelve months after a chemical is listed, businesses must not knowingly and intentionally
       expose any individual to  a significant risk  level of the chemical without first providing
       a "clear and reasonable warning,"  unless the business can demonstrate that the exposure:
                                          165

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 ;:;;  ;,  .'; •  >  iSoes not  exceed 1/1000  of the  "no observable effect  level"  (NOEL) for
'»-.    '	,'.,  ',:'.  i: reproductive toxins;

 	:        •      poses "no significant risk" of cancer — i.e., results in a cancer risk of less than
                one excess case of cancer per 100,000 individuals exposed over a 70-year lifetime
                for carcinogens.

         Examples of warnings that have been issued as a result of Proposition 65 include: labels
  on cigars, pipe tobacco, and other tobacco products not covered by the federal cigarette labeling
  requirements,  pomt:of:purchase sighs warning about risks of alcoholic beverage consumptions
  during pregnancy, signs warning  about the presence of environmental  tobacco  smoke, and
  newspaper•notices about emissions from facilities in the community. (Cal/EPA, 1993)

  2.     Twenty months after the chemical is listed, businesses must not knowingly discharge the
         chemical in "significant amounts" to the drinking water supply.   "Significant amount"
         refers to any detectable amount, unless the resulting exposure meets the same criteria for
         exemptions from the warning requirement.
 Ill            *T       ,,.„!„.„,,, 	,,	- ',,  ,;, „,„,. „, •	 !„,,„, • ,,l' , n, "i, ,' ,,; 	,	 V  ;•, • ,  ,«	   • , , • ,.    ,         .      '

  Enforcement

  :       Proposition 65 utilizes  an  unusual  means of  enforcement called the  "bounty  hunter"
  incentive, which allows private citizens to initiate proceedings against potential violators and reap
  monetary benefits from successful actions. Sixty days after notifying public authorities (i.e., the
  Attorney General, the appropriate district attorney or city attorney) of a potential violation, any
  individual or  group  may  sue  the offending  business  if the authorities are not  "diligently
  prosecuting" the matter (Kizer, 1988).  If successful,  the  individual  or group bringing suit
  receives 25 percent of the penalty fines, which may amount to a maximum of $2,500/day for
  e^ch violation;  Tlie  plaintiff filing suit "must first show that the alleged violator generated  a
  knowing discharge or exposure. It is then the responsibility of the defendant to prove that the
  exposures and discharges were within legal limits (Cal/EPA, 1992).
  '  ' •  i       ii mi
   References
          California EPA, Office of Environmental Health Hazard Assessment (OEHHA), 1992.
        •  The Implementation of'Proposition 65': A Progress Report,  July 1992.

          California EPA, Office of Environmental Health Hazard Assessment (OEHHA), 1993.
          Dr  Carol J. Henry Personal Communication with Abt Associates, May 13,  1993.
           •' .• i	IB  'i	  Ji'-, ", 	f	 ,	-  ,.	,	  . ,  ,

          California EPA, Office of Environmental Health Hazard Assessment (OEHHA). 1993b.
          T^!jipiemenmtionoff^                             January 1993.

          Kizerf Kenneth W.'f et' 'al-V 1988'.'''  "Sound  Science in the Implementation of Public
          Policy: A Case feport ori Calfornia's Proposition 65", The Journal of the American
          Medical Association, August 19, 260 (7): 951-955.

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THE VERMONT HOUSEHOLD HAZARDOUS
 PRODUCTS SHELF LABELING  PROGRAM

        CONSUMERS: MANY ITEMS IN THIS SECTION ARE
        HOUSEHOLD  HAZARDOUS PRODUCTS
      Free information
      about hazardous
      products and
      toxics use
      reduction is
      available at the
      register or service
      desk area.
   These products contain    \
HAZARDOUS INGREDIENTS j
      Consider
 alternatives; buy
   only what you
  need; read the
   use directions
carefully; store or
     dispose of
.residues properly.
      CALL THE VERMONT RECYCLING HOTLINE FOR MORE INFORMATION
                         1-800-932-7100

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VERMONT HOUSEHOLD HAZARDOUS PRODUCT' SHELF LABELING PROGRAM

Introduction

       The Vermont Household Hazardous Product Shelf Labeling Program was implemented
in April 1991by the Solid Waste Division of the Agency of Natural Resources.  The program
mimose is to promote toxic use reduction and pollution prevention by educating consumers^about
fffigers6f household hazardous products,  and encouraging them to consider altenwtives
The mandatory shelf labeling  program was set up by a 1990,state law requiring all retails s
sitldnThousehold products containing hazardous constituents to identify the produc s with shelf
 a£h   By Prompting consumers to avoid purchasing such products, the program's goal is to
1$ a siff^anlfacturersto produce less hazardous products.  This in turn would result
IVdelir environment and less costly waste disposal bills for the state.  ^* '^J*
Se programare organized under the following four categories: cleaning  products, auto and
maS maintenance products,  hobby and ^.V^^^J^^^
includes shoe polish, non-personal care aerosols, butane lighters, etc.). Personal care products
and food are excluded.
        Retailers were initially concerned that the program would result in a
 Deception of their stores because they sell hazardous products.  Instead, consumers have been
 ^  eCpportive of the participating" stores,  and have  expressed their  appreciauon^ or ±e
 3dditionalPproduct information. Retailers also worried about possible loss o f sate-of^he tabeted
 nroducts'' %e State responded by modifying the program to label products deemed ess toxic
 or nontoxic with an "exempt" label, so that retailers could offer officially-sanctioned alternatives
 § Sailed products. To date;  "approximately 58 percent of Vermont retailers have attempted
 JO comply with the program intent."  (Vermont 1992)

        After nine months of implementation; the progra^
 and implementation was good, But'that"consui.V« education needed more work. Suice that time,
 the sndf^Sas been'augmented with a I  ger (3"x5") "shelf talker"  card which increases
 label visibility and decreases the implementation burden on  the retailer.
                I1          I   i "                        I '                 «    '..••'.••  :.,
 Structure

         Vermont's program was set up in a public process with, input  from the broad-based
  Governor's  Technical Advisory  Committee on Solid Waste and other  interested parties.  The
  Te^hS AdS Committee included representatives from retailers as well as environmental
  organizations. The program was implemented and is maintained by the & lid Waste: Drn^on ot
  the Agency  of  Natural Resources,  The Commissioner  of Agriculture  has established  a
  companion program for pesticides and commercial fertilizers.
         Categories of products are  added or removed from the list through ^m^bj
         ^slators: It the time of this writing, program staff anticipated the addition of many
   new products in the near future.
                                             168

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 Program Elements

 Labeling:

       The labeling program is mandatory.  All retailers of products specified in the law were
 required.to have the labels or "shelf talker" cards on shelves or in the immediate vicinity of the
 identified products within 9 months of the establishment of the program.  Approximately 3,500
 Vermont .stores are subject to the law.   There is one state-approved label for retail use with
 respect to,the  hazardous products, a yellow sticker with the text "REDUCE TOXICS USE.
 These products contain HAZARDOUS INGREDIENTS." printed on it.

       In addition, there is a green exemption label which may be affixed to shelves displaying
 products that are. covered by the program  but have been  exempt from the yellow hazardous
 ingredients sticker.  To qualify for an exemption label, a product covered by the program must
 be  free of 24 ingredients listed in the  Vermont Community Right-to-Know list of hazardous
 chemicals.  The Agency reviews individual product applications for the exemption sticker, and
 makes decisions based on data on the product's Material Safety Data Sheet (MSDS).

 Retailer Information:

       Retailers are  provided  with information  about household  hazardous products  and
 alternatives arid logistical information  on how to label shelves in the "Retailer Information
 Guide."  Also, a full time "retailer educator"  was hired for nine months to assist retailers in
 implementing the program.

 Consumer Education:

       In addition to the labels and "shelf talker" cards,  the Agency has developed informational,
posters to be displayed close to shelves  where hazardous products are sold, and brochures that
contain background information on products, potential hazards,  'safe  disposal,  and use of
alternative nontoxic products.  The Agency also has plans to launch a media campaign and to
advertise offsite at recycling depots, schools, and businesses.

References

       Cohen,  Andrea, State  of .Vermont, Household Hazardous Products  Shelf Labeling
       Program, 1992.  Personal communication with Abt Associates.

       Vermont, State of, 1992.  The Vermont Household Hazardous Products Shelf Labeling
       Program - Retailer Information Guide.
                                          169

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 f' '
EPA'S OZONE DEPLETING SUBSTANCE
       	WAKNINCT

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EPA'S OZONE DEPLETING SUBSTANCE (ODS) WARNING LABEL

       Section 611 of Title VI of the Clean Air Act, as amended in 1990, requires "labeling of
products that contain or were manufactured with class I or H [ozone depleting] substances" by
May 15 1993  Class I .substances are chlorofluorocarbons (CFCs), halons, carbon tetrachlonde
and .   I'.l.l-trichloroethane    (methyl   chloroform),   while   class   n    chemicals   are,
hydrochlorofluorocarbons  (HCFCs).  The text of the label  reads: "Warning:  Contains (or,
"Manufactured with")  name  of  substance,  a  substance ^ which  .harms  public health and
environment by destroying ozone in the upper atmosphere."    .

       The final rule implementing section 611 was promulgated by EPA on February 11,  1993.
The rule prohibits the sale of "any container containing class I and class E substances,  product
containing class I substances and product manufactured with class I substances,  unless it bears
a warning statement indicating that the product contains or is manufactured with ozone-depleting
substances."  "Any  products  containing, or  manufactured with class n substances"  will be
required to  be labeled "if the Administrator determines that safe alternatives are available."
After January I, 2015,  all products containing or manufactured with class I or class H substances
-must be labeled. (58 FR 8136)                                     .

        "Products manufactured with Class I  substances can be temporarily exempted from the
labeling requirements if EPA determines  that there are no substitute products or manufacturing
processes that  (a) do not rely on the use of the Class I substance,  (b) reduce the overall risk to
human health and the environment,  and (c) are currently or potentially unavailable.  However,
all products must be labeled by 2015." (Labeling Subcommittee,  1991b)

        Although a symbol featuring a globe within an octagon (a stop sign), was considered in
 the rule proposal,  the final rule requires only the text of the warning above. EPA believed that
 "this  symbol  would substantially  increase  consumer understanding and  recognition of the
 required warning  and  thus heighten the effectiveness of the label." (proposed rule)  However,
 they were also concerned  that the cost of changing product labels, "would outweigh the benefits
 of using the label."  (58 FR 8136)         .

        Section 611 required that the warning be "clearly legible and conspicuous," while EPA
 proposed that it should appear on the "principle display panel" (PDF), the place on a product
 or package "where  the consumer is likely to look for product information."  After receiving
 comments  on the proposal,  EPA  decided  that "In  view  of the  broad diversity of products
 potentially affected by the labeling requirements... manufacturers,will need some latitude as to
 where to place the labels." (58 FR  8136) Therefore,  the final regulation reverts to the language
 of the CAA  requiring the  warning to  be  "clearly  legible  and conspicuous" wherever  it is
' presented.  Other labeling options such as hang tags> stickers and supplemental printed materials
 are also acceptable.                                   ,            ..•,.'.
                                            172

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  Affects of Phaseout

        At  the time of the Clean  Air Act amendments  in 1990, the U.S. was committed to a
  phaseout of class  I substances by the  year 2000 (two  years later for methyl chloroform), in
  concordance with  the  Montreal Protocol on Substances, that Deplete the Ozone Layer.  In a
;' ^PV^niber ^ 19.9,2	nieetipg _in _ Copenhagen,	the	phaseout	schedule for class I, substances was,
  aljfeler^le^ to January  1996 (two years sooner for'halon's)"  Thus, the ODS warning label will
  be in effect for fewet than three years before the phaseout is completed.  "As a result, EPA has
  streamlined some of the proposed requirements"  for labeling.
•• :fr;": •'Jp,:;^ ||;:fi;i:;*v;i^;{^j^lfjf^^	SS^^^ifllP^	-t:!i?^-;••'• .^.:  :    '" .  •	•
        "The recent decision  oj the Protocol Partie
  listed ozone-depleting substances  reduces the importance of the labeling program."  When the
  phaseout was  scheduled for  2000, "the labeling  requirements provided an  incentive  for
  manufacturers to move away from their use of such substances before 2000 in order to avoid the
  negative market reaction.  With  the acceleration  of" the phaseout,...  requiring products to  be
  labeled  is  unlikely to  significantly add to manufacturers'  incentive to  switch to alternative
  substances.""(58	FR 8136)   	'"_'"'	' "'\""'.'"'_"'.''	,'"  I	 ,"'"""" J .'"''  "",	,„"' '

_  Previous ODS Labeling	''""" \	'	  ",'".'..,	  ,'.. '".'.	','.	,
        In 1977, "The FDA and the CPSC required marketers and importers of self-pressurized
 medical and consumer products that use a CFC propellant to label their products with a warning
 that such products may harm public health and the environment by reducing ozone in the upper
 atmosphere."20   Soon afterwards,  CFC was banned  as an  aerosol propellant for all  but
 "essential applications," thus making the warning label irrelevant.
 References
        BNA Daily Environment Report, 1992. "Some'Nonessential' Products;Containing Ozone
        P"epleters to be Banned, EPA Rules," January 9, p. A-12.

        Labeling Subcommittee of the Stratospheric Ozone Protection Advisory Council, 1991a.
        Labeling Products Containing or Manufactured with Class lor II Substances, March 11.

        Labeling Subcommittee of the Stratospheric Ozone Protection Advisory Council, 1991b.
        "Meeting Summary," Washington, D.C., March 11.

        Labeling Subcommittee of the Stratospheric Ozone Protection Advisory Council, 199Ic.
        "Meeting Summary: Second Meeting," Washington, D.C., August 30.
    20 See the Federal Register April 29, 1977, 42 FR 22018, and August 24, 1977, 42 FR 42780.
   ,/'-'"                  I          II             I

            ' • '  	"173""

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U.S. EPA,  1991a.  Federal Register,  "Protection of Stratospheric Ozone: Notice of
proposed rule making," regarding the  ban on nonessential products  releasing class I
ozone depleting substances, 57 FR 1992, January 16.

U.S. EPA, 1991b. Federal Register, "Protection of Stratospheric Ozone," regarding the
ozone depleting potential of Class I and n  substances, January 22.

U.S. EPA,  1991c.  Federal Register, "Protection of Stratospheric Ozone: Temporary
final rule,"  regarding production limits on ozone depleting chemicals,  56 FR 9518,
March 6.

U.S. EPA,  1992.  Federal Register,  "Protection of Stratospheric Ozone: Notice of
proposed rule making," regarding warning latels on products made with or containing
ozone depleting substances, 57 FR 19167, May 4.

U.S. EPA,  1993a.  Federal Register, "Protection of Stratospheric Ozone:  Final rule,"
regarding the ban on  nonessential products releasing class I and H ozone depleting
substances,  58 FR 4768, January J5.

U.S. EPA,  1993b. Federal Register,"Protection of Stratospheric Ozone; labeling: Final
rule,"  regarding warning  labels  on products made with or containing ozone depleting
substances,  58 FR 8136, February 11.
                                     174

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         	THE ENERGY  GUIDE:
   HOUSEHOLD  APPLIANCE ENERGY
            , EFFICIENCY  LABELING
111!"!  V	
              Model! with the mo«t efficient
              energy rating number ui« leu
              energy and coil leu to operate.
              Least efficient
              model
               5.7
                     Models with 7 800 to
                      8.299 BTU'S cool
                    about the same apace.
                      Most efficient
                           model
                             9.8
                  THIS MODEL
                   ratify « tim»t on U 3 Oo*»niiw«rt tundArt t«M>.
               How much will this model co»t you to run yearly?
               Ytarly hours
               of ut«
   250   750   1000   2000   3000
               Co*t ptr
               kilowatt
               hour
4C
                          «e
                          8«
                          12C
         $13
      $17
      $33
                          $50
   $8
$25
$33
$67
                          $100
                             $13
         $38
                                         $50
            $100
                                                     $150
                             $17
         $50
      $67
                                               $134
            $200
                             $21
         $63
      $84
      $167
                                                     $251
                             $25
         $75
      $100
                                               $200
            $301
               Ask your salesperson or local utility for the energy rate (cost per
               kilowatt hour) in your area. Your cost will vary depending on your local
               energy rate and how you use the product.
                        Removal ol this label before contumer purchaM i* a violation ol
               federal law (42 U.S.C. 8302).                .     Pirt H0 ^^.^

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THE ENERGY GUIDE: HOUSEHOLD APPLIANCE ENERGY EFFICIENCY LABELING

       In December 1975, Congress "passed the Energy Policy and Conservation Act (EPCA),
which requires that Energy Guide labels be placed on certain new home appliances.  These home
appliances include: refrigerators,.refrigerator-freezers, freezers, water heaters, clothes washers,
dishwashers, furnaces, room air conditioners, central air conditioners and heat pumps.  These
appliances are  covered under EPCA because their energy costs can vary greatly, depending on
their construction and design.  EPA also  requested standards and labeling for humidifiers and
dehumidifiers,  clothes dryers, direct heating equipment, kitchen ranges and ovens, and television
sets, but FTC  did not include them  in the labeling program because there  were insufficient
differences in energy efficiency.

       The National Appliance Energy Conservation Act'(NAECA) of 1987 amended EPCA'by,
among other things, establishing minimum efficiency standards for all EPCA products. National
Appliance Energy Conservation amendments of 1988 added "fluorescent  lamp ballasts.  The
Energy Policy Act of 1992 added general service fluorescent lamps and incandescent reflector
lamps, showerheads, faucets,  water closets, 'and urinals.

       Under  the EPCA,  the Federal Trade Commission (FTC) was given  responsibility for
establishing the format of appliance labels, while the Department of Energy  (then the Federal
Energy Administration) was given responsibility for promulgating standardized test procedures,
setting minimum energy efficiency standards and conducting  a consumer education program to
complement the labeling program. (McNeill & Wilkie, 1979; U.S. DOE, 1980)  For most of
the:appliance categories, FTC required that the energy labels should disclose the average annual
energy use for the appliance in dollars and a comparison with similar models.  For heat pumps,
air conditioners and furnaces, where variations in climate make a national average  meaningless,.
an energy rating figure is  used instead.  The design of the labels'was announced in 1979.

       Although the labels vary somewhat for different types of appliances, they  all contain
specific information on energy efficiency and costs (see title page for figure).  The text of each
label includes:                                                     '

•      the manufacturer, model number,  type of appliance, and capacity, all listed at the top of
       the label;

•      a large number in the center of the label  which is either the estimated yearly cost to
       operate the appliance, or an energy efficiency rating (EER). The annual operating cost
        is based on the national average electric rate ($/kwh).  Because this  average rate may
       change over time, labels printed  at different times may use different standard energy
       prices.  For room air conditioners, furnaces, central air conditioners and heat pumps, the
        large number refers to the Energy Efficiency  Rating (EER).  This number tells the
       consumer the amount  of cooling or heating the appliance provides  for the amount of
        electricity that it consumes. The higher the EER, the more efficient the appliance;
                                           176

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      ::;  the estimated yearly cost to operate or the efficiency rating of the most and least efficient
         mode's ,w"hin a category.  The label displays how the appliance compares with other
         Similarly sLzed models in energy efficiency by placing it on a line scale between the most
         and least efficient models a| the endpoints;

         a table shpwjng the- estimated yearly cost to operate the appliance for varying electric
         rates IS/kwh), and varying usage habits.  This allows  the consumer to calculate likely
        costs of rm^ing the appliance in different parts of the country, where energy rates may
        differ, substan|ialjy from tjie national average. (Consumers' Research, 1988; EPA, 1989)
         '   '"'    "         "   '  ''   : ' " '  '''•    '        ' '   '    ''  ''' '•'''''''•     '
            ,                        ,  „                     ,                     .
            re hayeJranji.nHropei.Qfj5tudjes to measure the impact that the Energy Guide labels
 have had on consumers and energy efficiency. (EPA, 1989)  While the results of these studies
 vary, the  most typical conclusion was that of  a study performed for the Bonneville Power
 p^H^tration. .(Bonneville Power '.Administration, 1985)   It concluded that the Energy Guide
 label*  may helj> Braise consumer awareness of energy  efficiency  issues,  but they do not
 necessarily change consumer purchase behavior. Respondents also complained that the labels
 ™QiQ !Hd  to read, atf jntejpret, a problem borne out by other studies. (California Energy
 f°/n™s*on» 1988)  FTC is currently  conducting a review of the content and format of the
 labels;  which is expected to be completed by October 1993. (GAO, 1993)

 _      Other criticisms of the appliance labeling program  have been made since its inception
 *°r e?amPle. operating costs for an appliance  are  computed based on the  current national
 average cost of electricity at the time of toting.  Since that model may be on  the market for a
 number of years with the same label, and the price of energy may fluctuate, the label becomes
 less accurate. And since operating costs of new models are also computed for their own year
 of testing,  they may be computed at  different rates than mpjej| already on the market
                   • IRI1IHI " ,..|". ,,J •!,„,.",." >'	„;'''vi:,ii!" ' N;,	'\*i ' ' "Mil". 1'!«'• f'fll'Wilii!-1!!,1!"!''t
       FTC has proposed a number of changes to overcome shortcomings in the program  One
      sal is to change the visual format of the label to a bar chart or a vertical line instead of a
 nonzqntal line.  Another is to change the large central number on the label from a dollar amount
 0 e't«er an   energy factor" (similar to  the EER) or a specific unit of energy use,  such  as
 kljowa!tjhou.rs *** y^ of tricky or therms of natural gas.  Dollar amounts could  be
 fWtejusuig a "cost grid" that gives operating costs for different energy rates and amounts
 of .use'  ^ would avoid *e problems presented by changes in the cost of electricity by region
 f"d Ov5r time;  The FTC also proposes to modify the explanatory  language on the labels and
 to conduct a public education program,  the  first such program since one conducted  by the
 Department of Energy in 1980.


References

      Bonneville Power;Administration,  1985.   Report on Market Research and Program
      Recommendations:  Bonneville Power Administration Regionwide Promotion of Energy-
                                          1771...

-------
Efficient Appliances, prepared by-Brian Gard William Lesh, Inc., November.  Cited in
U.S. EPA,  1989.                       ,    .   .-

California Energy Commission,, 1988.  Conservation Report, publication 400-88-004,
October.  Cited in U.S. EPA, 1989.

Consumers' Research, 1988. "How Much Do Appliances Cost to Run?" September 1988,
pp 16-19.

Government Accounting Office, 1993.  Energy Conservation:  Appliance Standards and
Labeling Programs Can Be Improved, RCED-93-102, March.

McNeill, D.L., and W.L.  Wilkie, 1979. "Public Policy and Consumer Information:
Impact of the New Energy Labels," Journal of Consumer Research, vol. 6, June 1979,
PP Ml.

Mills, James, Federal Trade  Commission, 1993.  Personal Communication with Abt
Associates,  June  14.

U.S. Department of Energy,  1980.  An Analysis of the Potential Impact of Consumer
Education  and Labeling on Energy  Efficiency, prepared by Policy Planning and
Evaluation, Inc., January.

U.S. EPA,  1989. Environmental Labeling in the United States: Background Research,
Issues, and Recommendations - Draft Report, prepared by Lori K. Carswell, Julia J.
Langel, and Adam B! Borison, Applied Decision Analysis, Inc., December 5.

U.S. Federal Trade Commission,  1993a.  "Notice of Proposed  Rulemaking:  Rules for
Using Energy "Costs and Consumption Information Used in Labeling and Advertising of
Consumer Appliances Under the Energy Policy and Conservation Act," Federal Register,
58 FR 7852, February 9.

U.S. Federal Trade Commission,  1993b.  "Notice of Proposed  Rulemaking: Rules for
Using Energy Costs and Consumption Information Used in Labeling and Advertising of
Consumer Appliances Under the Energy Policy and Conservation Act," Federal Register,
58 FR 12818,  March 5,
                                   178

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 ...... EPA FUEL ECONOMY
  n III
  nil
INFORMATION  PROGRAM
        Sample Fuel Economy Label
                New Vehicle Window)
                                        This a th« lvw»g«
                                        a«tim«t« fw highway drivwg
              1993 CANARY 2.8 LITER
              V6 ENGINE 2 BBL CARS
              MAN 4 SPO TRANS CATALYST,
              FEEDBACK FUEL
                Eiinattd Amutl Fuel Cote
                    *942
                  15,000 mi/yr al $1,20

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 FUEL ECONOMY INFORMATION PROGRAM

       In 1975, Congress passed the Energy Policy and "Conservation Act  (EPCA)  which
 established Corporate Average Fuel Efficiency (CAFE) standards as well-as a testing, labeling
 and information program to assist consumers in purchasing new  cars.  One aspect  of the
 information program was the Gas Mileage Guide, a publication listing the fuel economy of cars
 manufactured at a  given  time.  Car  dealers were required  to  have the Guide available for
 customers.              .                             .        • .

       The  law also required an label to appear in the windows of new cars that lists the miles-
 per-gallon (MPG)  of the car for city and  highway driving, the estimated annual fuel cost
 associated with its operation, and.the fuel economy of comparably-sized models.  Such labeling
 began in 1974 with a voluntary  program administered  by the  EPA' and the Federal  Energy
 Administration (FEA), a precursor of the Department of Energy.- The EPCA made the program
 mandatory as of March, 1976. Although EPA is responsible for  testing cars,  and preparing the
 Gas Mileage Guide and the MPG labels,  responsibility for other aspects of the fuel economy
 program is  shared with three other federal agencies:  DOE, Department of Transportation and
 the Federal Trade Commission. (U.S. House, 1980)

       The labeling program had a number of problems initially with the measurement of vehicle
 mileage.  A Congressional Committee hearing noted, "As the public quickly discerned, the EPA
 mileage figures were not an'accurate measure of on-road performance." (U.S.  House,  1980)
 According  to Elder Bontekoe of EPA's  Office of Mobile  Sources, the tests  were  not run
 according to "real world" conditions and' considerably overestimated the actual  mileage
 automobiles could  be expected to achieve. In response,  in 1985 a formula was worked out to
 adjust the mileage  for actual city and highway driving conditions.  This new system has been
 found to be fairly reliable. (Bontekoe, 1993)                                  .      '

        A few changes have been  made to the format of the label since the program's inception.
 Initially showing both highway and city ..ratings for MPG, 1979 EPA regulations removed the
 higher (and less accurate) highway rating, and changed the wording to "Estimated MPG." Car
 makers  were still  allowed to use both ratings  in  advertising,  so there was  a concern that
, consumers were-"being misled by nightly television advertisements and auto showroom displays
 featuring extravagant  gasoline  mileage  claims based  on  their government's own  testing
 program."  (U.S. House,  1980)  After changes were made in 1985 to improve the accuracy  of
 the tests, labels again bear estimated MPG ratings for city and highway use.

        A study performed in  1976 found  that 72 percent of new car buyers  were aware of the
 Fuel Economy Information Program and  more than half had seen the mileage label on the car
 they bought (while only 7 percent were aware of the Gas Mileage  Guide).  Also, buyers who
 were aware of the label  bought cars with higher mileage than did unaware buyers, with the
 mileage of their new car more than 20 percent higher than their old vehicle., Unaware buyers
 achieved almost no increase in mileage. On the other hand, 64 percent of buyers did not believe
 the MPG estimates. (Abt, 1976)  Two important considerations for interpreting this study are


                                           180

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   that the OPEC oil embargo, in the winter or  1973-74, was fresh in" car buyers' minds at that
   time, and that the program was still quite new.

         The effectiveness of the EPA gas mileage labeling program is largely dependent on public
   opinions toward gasoline use and conservation.  Due to the low price of gasoline in recent years,
   mileage has become a less important consideration for many car buyers.  "We perceive that the
   nuritbers are well accepted and the program has a fair degree of recognition in the marketplace,"
   said Mr. Bontekoe.  "A lot of people don't care, but they do seem to be paying attention."

   References
 	     ;n,'.', •• :•; \-,\ >•*,     i                        i    i               i         '.•' ,;•••'.,•
         Abt Associates  1976.   Impact  of the FEA/EPA  Fuel Economy Information  Program,
         prepared for the Federal Energy Administration  by Vince Scardino, James Birch and
;:  .,     Kathy  Vitale, June.	  ••	•	•"   '    •'"
    IN,  f'!!i|!'",l| „, i	|||""|! |. ,  j| " , jWlliinill 	 |	i| ,  ;|,.|",  ,, J,, | ,„,;;,	I,,!, M I,,,,,, ,h, , , ,	, |, ,|,, ,	I, , , ,|ifi,,i , || §  | „ |r,,|||;|l| I,,, n, j ,	, , ,,1,1	„ i,, i ,„ ,   -,  ,

         Bontekoe, Elder, U.S. EPA, Office of Mobile Sources, 1993.  Personal communication
         with Abt Associates, April 1.
 ;	:   in            i ii n  i          i           i          i    i i     i      '••"'..•':.         ' '
         Tyree,  C. D., U.S. EPA Certification Policy and Support Branch, 1982. 'History and
       !  Description of the EPA ^n^ronjnen^iprot^cffQ^ Agency) Motor Vehicle Fuel Economy
         Program, NTIS# PB 84-212091, EPA# AA-CPSB-82-02.

         U.S.  House  of  Representatives,  Committee  on  Government Operations,   1980.
         Automotive  Fuel Economy: EPA's Performance,  May  13, report no. 96-948.
                                             181

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NONTOXIC, NATURAL & EARTHWISE

-------
NONTOXIC, NATURAL & EARTHWISE

^^^^^^


=ss±.  i ':±!?*ra  2: ;± rt^t= sr££
descriptions." (Dadd, 1990)
      For each criterion she gives an award to products that are  notable   Under product
         , for example, she awards three different levels, nontoxic  natural, and the hughes
                            products are truly good for the Earth and for us; they are not
 merely the least harmful that happen to be available." Such products include organically grown
 |S, unbleached  recycled paper and  skin-care  products  made from  organically grown

 ingredients.

 '*• - '-fetfuctfkre ^^$Siffi£	W^^fv^ products, "so you'll know that an
 SMhwise product will meet the same standards whether it is apple juice or a sweater.   The
 following list describes the requirements of an ideal product:

 *     be practical and durable, well-made,  with a timeless design;
 V     satisfy;a.functional and/or aesthetic need, and not be superfluous clutter;
 •     be made from either:                                          .  ,,       ,
             Ihewable plants grown  arid harvested in an  organic  sustainable way (or
             recycled) and processed in a manner that is  environmentally benign;
       o     ^ia]s raisedli a way that is environmentally benign and in a place where they
             are treated humanely; or
             recycled,  nonrenewable petrochemicals and metals (as opposed to mining new
             npnrenewables);
       be healthful for humans to use; and be biodegradable or recyclable;
       .'fee; "made ; with ^renewable energy and be energy-efficient in manufacture and use;
      ' ..... be ..... ^^p0!ni:s^|y'Jpackage3 ...... or" not ..... packaged at all;
       not be tested on animals; and                              .
       be provided by businesses with socially responsible business practices.
        Dadd criticizes seal-of-approval programs like Blue Angel for "Pthe
  existing products", since they "do not set new standards that take a creative leap into the realm
  Sr£5? hSSfol a^d environmentaUy responsible products." She abo adrmts that the s^ndards
  shelas set "are more stringent than any I've seen, but I believe it is vitally important to move
  in this direction." (Dadd,  1990)
                                        184

-------
Reference
      Dadd Debra Lynn, 1990. Nontoxic, Natural & Eanhwise, Jeremy P. Tarcher, Inc. , Los
      •*»J l&CtCo .                     '         -                '
                                      185

-------
.I.1;; sir!1' " "',
ill-'i'"'' v»:  i      I I
Siifl!.'!1" . ',:• !•• i '       I l»l
             THE GREEN CONSUMER
                 GREEN, CONSUMER
                           GUIDE

-------
THE GREEN CONSUMER and THE GREEN CONSUMER SUPERMARKET GUIDE

      The Green Consumer was first published in England in 1988, written by John Elkington
and Julia Hailes. In 1990, the book was published in the United States, with additional writing
by Joel  Makower.  Its primary  goal is  not to rate  specific products but to give an overall
approach to being an "environmental shopper." The Green Consumer has been very  popular,
appearing on  bestseller lists, selling more than 100,000 copies in the U.S. and over 250,000
copies in the U.K. A second edition of the book was published in the U.S. in 1993.

      The Green Consumer Supermarket Guide, published in the U.S. in 1991, was written as
a companion to The Green Consumer to include "brand-specific information on hundreds of the
best and worst products."  It contains much of the same information,, but where Green Consumer
covers a wider range  of consumer goods, such as automobiles,  appliances and furniture,  the
Supermarket Guide is  shorter and geared more toward supermarket goods.  The book attempts
"to give an environmental tour of the supermarket aisles, offering information and insight into
how to view your purchases through a 'green' lens."

      The book also gives more information about specific brands, and includes a rating system
for products.  "We have  provided names of hundreds of products we think you should either
seek out or avoid, based on the product's packaging, contents, and on the environmental records
of their manufacturers."

       The book does not rate all categories of supermarket products,  nor all products within
a category.  Its standards vary according to  "the state of the  art" rather than  "seeking an
unattainable perfection."  The "state of the art" ..is determined using '"examinations of packaging
types, research into ingredients, interviews with experts, label information, product data sheets,
databases  about  companies'  environmental  records,  and other  journalistic and  research
techniques."  Information on the environmental performance of companies was provided by the
Council on Economic Priorities, authors ,of Shopping for a Better World.

       Products are rated from ten food categories (such as beverages, snacks, and  breakfast
cereals) and eight non-food,categories (e.g., batteries, paper products, pet foods).  Those rated
highly are awarded one or more of three logos: a beaker indicating a product is "rated highly
for its contents," a bow (such as on a birthday present) indicating a "product rated highly for
its packaging," and a factory  building for a highly rated manufacturer.  If a product is rated
poorly, it receives the same logos with an X superimposed.
            f                  •                                 '              •
        The rating criteria are presented as brief discussions of the relevant environmental
 impacts of each product  category,  in sections titled "What's the Problem?"  Although these
 discussions may touch upon  many  environmental impacts, awards are often given  for only
 certain reasons.  In the discussion of coffee, for example, it is noted that decaffeinated coffee
 is processed with chemicals "similar to  those used in dry cleaning." However, since "there  is
 no information available on the environmental impact of such chemicals" coffee products are
 rated for their packaging only.

                                          188

-------
       In addition^Supermarket Guide does not always disclose reasons for its ratings of specific
products or companies. With coffee "any brand packaged in a steel can or glass jar" is awarded
for recyclable packaging.  However, only Melitta coffee is rated highly for packaging, contents
and the manufacturer, although no reasons  are given.

References,   	  ni.	   	MI	^	,,	•	  	.., 	
       Elkington, John, Julia Hailes and Joel Makower,1990.  The Green Consumer, Penguin
       BOC..S, New York.

   4i,.: M^pwer, Joel,withi  John Elkjngton  and Julia Hailes,  1991.  The  Green Consumer
       Supermarket Guide, Penguin, New York, 1991.
       Pearce, Fred, 1990. "The Consumers are not so Green," New Scientist, June 16, p. 13.

   21i  See also:  	_ '"'          •

       The Green Consumer Letter, monthly newsletter, Tilton Press, Washington, D.C.
   i'JMLi M :i  i,'.»,„',:'  .'!.,„• ;- » '•Bill1 V'i.i"1 " I .|,l,:,, "i,!, ii.i",!1!'1!,!'r,1,!, J :,'!'!!"	•,  » k .',. lih.'li! "' '' ,!", ,l/	,, „ '	 '	',„„„,,     V ,',,,,
       Makower, Joel, with John  Elkington and Julia Hailes, 1993.   The Green  Consumer,
       Revised Edition, Penguin Books, NY.
                 *!'!	t
                                          189

-------
 OTHER ENVIRONMENTAL
CERTIFICATION PROGRAMS

-------
              OTHER ENVIRONMENTAL CERTIFICATION PROGRAMS

                     In addition to the labeling programs described above, a number of others are in planning,
              Ijave tHMp dropped after plans were made, are peripheral or obscure, or did not have information
              available at the time this report was prepared.  Such programs are included here in  an attempt
              © be conipj-ehensive.  Also, some  of the proposed programs, such as  the United Kingdom's,
              tlioiign riot enacted, offer interesting approaches to environmental labeling.
Siili;' ;	i  •  "  '  I  I      i      1 ill  lii        111      i  ii I      i                   "  : '  ,  ' ••, •      i   '•'.''.''
              Organized Labeling Programs, but Not Yet Active

                     Some of the following countries have  organized certification  programs, and may be
              actively awarding labels, although we have not been able to confirm this.
                     AUSTRIA
                     Legislation implementing Austria's Ecolabel program went into effect on April 26, 1991.
              'Sfiinistry"of^Environment, Youth and Family, 1993) To date, standards have been set for 13
              product categories and the program is reported to have awarded its  first labels in September
              1992, to tissue paper, refrigerators,  and paper bags. (Wanner Bulletin,  1992)
                                                                 i  '.         •      '           (
                     As of mid-1993, there are award guidelines for the following  product categories:
                     *      refrigerators and appliances for cooling
              •";I ,:,  ';:"•	"„"'.',"'famishes	
                     •      Sanitary paper
                     •      fine paper
              ;:;;::,:, •  „•   „   exercise books                  •           .                '
                     •      washing machines
                     •      wood                                                    ..',',
                     •      wooden furniture
                     •      riling systems
                     •      sealing varnishes
                            water-saving WC-cisterns made of chlorineless plastics
'!*!';''•  -|  '"!'|*  .' '.  fit '!i'. ^V'; I:,1; "'"electronic	control systems for sanitary"	mstaflations
                            reprocessing of toner-modules, ribbon cassettes and ink-cartidges (Ministry of
                            Environment, Youth and Family,  1993)

                     According to the OECD, the program is jointly administered by the non-governmental
               Association for Consumer Information, the "certification association" ARGE QuaJitywork, the
               Ministry of Environment, Youth and Family, and a Council "thatserves as an advisory body to
               the Minister.  This'Counciliscomposedof environmental science experts and representatives
              'IpI'lM'V''"'!!!,! i,' : i i Kli 'in, . "'i..!,!. :,' '	CH^	'if'IP"!! B1,1:, ii'li'lliiJ'!!'''.'!'!'!!!!'!,!"'!)"!::';!]!™!! I, «L''Sv,ii	HIM,	"	,'.im.,	»>	.n-,,,'	:;	y	•%	 .  .        \ , i          a.n4-
               of consumer arid^environmental groups, standards and mdustry associations, and the government
               departments for trade and environment.  (Salzman, 1991)
                                                         192

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        Product  categories  are  proposed to the  Ministry of Environment;  which prepares  a
 background report for the Council.   The Council make's a recommendation to the Ministry,
 which has final say on which product categories will be-pursued.  An expert group, selected by
 the Association for Consumer Information,'establishes criteria for each product category based
 on an assessment of environmental impacts throughout the life cycle of the product  The <>roup
 uses the life cycle matrix prepared by the German Blue Angel program to measure "raw material
 usage and energy consumption,, waste production am<  emissions, and disposal "  Proposed
 criteria are submitted to the. Council, which comments a, .1 passes them  on to the Ministry.

       When criteria  are finalized, ARGE Quality work oversees  product applications  testing
 and contracts for the  use of the award.  Fees for use of the label depend on the sales-of the
 product, ranging from $500 to 54,500  for the two years the award is valid.'

       In addition to an label, Austria  has a law regulating the labeling of tropical timber.  Pan
 of the law requires all products containing tropical timber to bear the phrase,  "Made of tropical
 timber," or, "Contains tropical timber." The law also provides for a voluntary seal-of-approval
 for products made of wood provided  "from sustainable forest management."  This program
 would be  run by the Minisitry of Environment, Youth and Family, with consultation from an
 Advisory  Committee for Tropical Wood.   (Gatt,  1992), The law was introduced in September
 1992, apparently underpressure from environmental groups seeking a boycott of timber logged
 from rainforests.  (New Scientist, 1993) Recently, however, the Association of Southeast Asian
 Nations (ASEAN), including Malaysia and Indonesia, have complained to the council of the
 General Agreement on Tariffs and Trade (GATT) that the law constitutes a.technical barrier to
 trade, blocking exports from their countries.  They argued that the law  unfairly discriminates
 against tropical timber, since it does not address all types of wood products, and that the action
 was taken unilaterally by  Austria, without the participation of the international community.
 (GATT, 1992)   Malaysia  arid Indonesia  have reportedly .threatened an economic  boycott of
 Austria. It is possible that the labeling law could  be repealed as a  result. (New Scientist, 1993)

.References

      .New Scientist,  1993.  "This Week: Timber Labels," March 13.

      Ministry of Environment, Youth and Family, 1993. Personal communication with Julie
      Lynch, U.S. EPA, May 5.

      Salzman,  James,  OECD,  1991.    Environmental Labelling in  OECD Countries,
      Organization for Economic Cooperation and Development, Technology and Environment
      Programme, Paris.                 ~;

      Warmer Bulletin, 1992.  "Feature: Austria," p. 8, no. 34,  August,
                                         193

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•      CHILE
       Plans have been made in dhile for a private sector environmental labeling



on the Environment.21
 Administrative Structure
                currently promoted by Casa de la Paz, the program will be administered by the
           >uuue for Environmental Recognition (ICRA), also a non-profit private ^datuDn-
           bring together a Board, which will be assisted by an Executive Secretary and a Jury.
                 'Iff 'els!^^iffi*^i^6en^S	by'"representatives of the
                    universities  the business sector, the scientific world," and environmental
            consumer' groups. '  The Board will be in charge of planning,  managing  and
        controlling the program.
        p                adequatacbucal preparation and linked ,o industry  commerce,
        Sonmental organizations, consumer and workers' orgamzations and the media.
  Process
             e time of the Seminar, the process of setting criteria and certifying products had not
            Jneff."General Criteria," which  all awarded products must meet, regardless ot
         tor ^pe^ific categories are as follows:
         •     It must not put consumers' health at risk.
               It  must  not  significantly  damage  the  environment  via  its  production,
               transportation, use or disposal process.
         .     itmustnot consume a disproportionate ^ount of energy in those prcx^sses.
        It is unknown whether this group is governmental or private.
         ""-•'',    i              ,         i     194

-------
               It must not produce unnecessary waste (via excessive packaging in relation to its
               manipulation needs,  useful life, etc.)

        •      It must not utilize materials derived from endangered species or environments.

               The label  of the certified product must indicate  the  specific  reasons  which
               justified its certification, as well as the environmental characteristics which are
               the bases for this distinction.

               As the logo will be granted to products only, the producer will not be able to use
               this fact to promote his company or to highlight other products of the same line
               1991  US productl°n) which *re not authorized to use the logo.  (Casa de la Paz,


        The award will be given for a period. of 2 to  3  years, with standards raised to require
 contrnued improvement.  The program plans to be self-financed through fees charged for
 nrttif ^n  f^PP T'n *!? ^ Pay fOr M*™* 6Xpenses  for testing products   The
 program will start gradually, determining environmental impacts for products that "will not cause
 major difficulties, "and work up to  more complex cases.

 Reference                                                       '

        Casa de la Paz, 1991.   "Eco-labelling in  Chile", presented  at Global Environmental
        Labelling Seminar, United Nations Environment Programme, Industry and Environment
        Urtice,  working group on Policies,  Strategies  and  Instruments to Promote  Cleaner
        Production, September 24-25.

 Planned, Cancelled or Unconfirmed Labeling Programs

        Other environmental certification  programs are rumored,  unconfirmed,  have  been
 cancelled,  or  have been  approved/planned  but have  not  been organized yet   The best
 documented of these  is the United Kingdom's environmental labeling program which wa
 planned extensively before being set aside in favor of the EC ecolabel.


       CZECH REPUBLIC (CZECHOSLOVAKIA)

 PT^  Pi6 government of the Czech Republic began preparing an "Environment Friendly
 Product  labeling program  in 1991, which is expected to be operational in 1993. Proposals have
a™™?? £ r   Pr°gram's organization,  financing,  logo and legal authority, and await
approval by the Czech government.
th M  ?6 Pr0gram « based on the "experience of already estabUshed programs" in Austria,
the Nordic countries, Germany and Canada.  It is "in compliance with" the EC regulation settin
                             regulation setting
        /                           *

195

-------
,up the EC ecolabeling program.  HarmonJka'tTon is an important issue for the Czech program,
 "to enable the mutual acceptance of this award" in other countries.
  li! ..... lii'l ,     ,,    ;! ..... ' IILIiHilr1!!1!   :  ' „ ...... ''"' sy,'1:,!'1 i ";',;, I!1 11!":,1 i, !,!! nil!1 il ' » I1, "I1 . in'1 I.";, M,J| ........ ..... I1 ',ii ; ', ..... ,l n'lli'l. ,ll, » ','11 ..... ! ",! ....... i  IllilX . V'f „ i.      ' •  '•      ,           ''
"  i! ..... I'!' '"   -'i  •  ',  liSiiilliri -I1"' ! ' '.'.i.." r'SIH !. iii V'liii i.-1. "If ...... ,:'fltf ..... '.'jtu:;-1! ..... , Jj'l'f1   II .M'ii1!1'" 1:1 !'; i ) •.•,: >,;  'IS"!,, i;   i
 CJeneral Principles

       To qualify for an award, products must first meet health;  safety, and hygiene standards
 Priority wUi be liven in  setting product  categories  to those products that  "cause substantial
 damage" to the environment.  A life cycle approach will be taken to assessing products  defined
 as Including use of "raw materials, energy consumption, production, function, regeneration [and]
 dls^sal."   Products already regulated, such as food, beverages and pharmaceutical will be
 excluded from the program.
1  i  i             in              i          i    .      i          ii     '• . • •    •             ,  ,
 Administrative Structure

        The Ministry of the Environment is the "director and coordinator" of the program.  The
 Ministry  will appoint the Council, approve criteria  set for product categories  and enforce
 ploVisions of the contract for use of the award.

        The  Council is  the "control body"  of the  program, and  includes representatives of
 environmental aTH Son'suTne^^^ion groups; ............... scientific and ^olo^/°^orari2^d
 industry and trade groups. It will "consider and recommend" criteria for product categories and
                           that meet the criteria.  The program will hire accredited laboratories
  for testing products that have been submitted to the program.

         The Agency acts as the executive body, or secretariat, of the program.  It will receive
  applications for awards, make contracts with companies whose products are given awards and
  cha ge fees.  There will be an application fee and,  for those companies that receive jan award
  an annual licensing fee based on the volume of manufacture.  The award will be valid  for at
  roost three yeafs aid awarded products will be audited to ensure that they continue to mee  d»
  Xia^tne  award.  The program is hoped to be self-financing  "in its final  stage at least
  partiaily."
  References
         KopeckyJ Alois,  Director, Czech Ecological Institute, B93.  Personal correspondence
         with Ab"t Associates, May 11.

         Kunc, iakar,'Czech Institute for;S^clards,  1993.  Personal correspondence with Abt
         Associates, January 19.
                                              196

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        DENMARK
        The Danish Ministry of Environment was  given legal authority in 1989 to  create  an
  environmental .labeling program. Although Denmark is a member of the Nordic Council it is
  waiting  to  assess  the European Community ecolabeling program  before joining  in  either
  program. (Salzman, 1991) Denmark is participating in setting standards for EC, preparL^ft
  standards for paper products. (Bethge, 1991)                                  .
  References
        Bethge, PerOlof, 1991. Eco-labelling of Paper Products, written for the Ministry of the
        Environment, Danish Environmental Protection Agency, Denmark.

        Salzman,  James,  .OECD,   1991,   Environmental Labelling 'in  OECD  Countries
        Organization for Economic Cooperation and Development, Technology and 'Environment
        Programme,  Pans.
       IRELAND
       According to a representative of the Irish Department of Environment,  "In light of the
       T" ^th^QQ^0' 5? EC SCheme' ^  »*>*«*»•<* - -parate Irish scheme is
       y.   (Linehan,  1992)  The recent Environmental Protection Agency Act provided for
 development of an environmental labeling program "having regard to any act of an institution
 of the European Communities' relating to a Community labelling scheme." The Act allows the
 Environment Agency to determine product categories.and services, set standards and procedures
 carry out testing, publicize the program, and monitor the use of a "special symbol" awarded to
 products and services.  The Act also determines that it shall be an "offence''to use the symbol
 without approval of the program: arish Congress, 1992)          ,                  Y

 References

       Irish Congress,  Environmental Protection Agency Act of 1992, section 78.

       Linehan, Brendan, Environment Policy Section,  Dept. of Environment,  1992  Personal
       communication with Abt Associates, May 12. ,              '•'....


 •      PORTUGAL

      .According to the OECD report, a legislative proposal was discussed within the Portugese
government^ and was expected to be approved in early 1991. This legislation would create an
environmental labeling program to promote "ecoprodutos," or eco-products.  The program would
be entirely governmental, with representatives from the ministries of environment, consumer and
                                         197

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industry;.  Portugal is a member of the EC and is expected to participate in the EC environmental
labeling program? '	'_"	" '"

Reference

       Salzman,  James, OECD,   1991.   Environmental Labelling in OECD  Countries,
       Organization for Economic Cooperation and Development, Technology and Environment
       Programme, Paris.
t      SWITZERLAND
                                                      I  , ,,
       According to the Federal Office of Envkonment, Forests and Landscape, "Switzerland
iill not introduce  its own national environmental label [in order] to participate in the EC
scheme	"	SwitzTrffia'not';	However?a	memBer	of the"fiu1ropean"1Community.. Action on their
fnvolvement was not expected before the  end of 1992.  In 1991, the Swiss government
Commissioned a study on the feasibility of a national environmental labeling program.  (Salzman
1991")   Switzerland  has  also  passed a  specific law  regulating misleading  environmental
advertising (Scammon and Mayer,  1991).
 References
       Back, Eduard, Federal Office of Environment, Forests and Landscape, 1992.  Personal
       ;cpmmuru^tion with Abt-Associates, May 13.

       Salzman;  James,  OECD,  1991.   Environmental Labelling  in  OECD Countries,
       Organization for Economic Cooperation and Development, Technology and Environment
       Programme, Paris.

       Scammon, Debra L., and Rob Mayer,  University  of Utah,  1992.   Environmental,
       ecolabeling and Advertising Claims: International Action and Policy Issues, Submitted
       to Summer ACR Conference, Amsterdam, the Netherlands, June 11-14, p. 8.
 •      UNITED KINGDOM

        The British Government has held the position for several years that  a European
 Community Labeling program would be preferable to multiple independent national programs
 for both consumers and manufacturers. On the other hand, it has also said that they are strongly
 ilo'm' fitted" "to .'naving'M OTvlroMential certiruation program, and if the EC program failed to
 *bSx>mQVcSve; itwouia set up S separate UK program. Since the EC ecolabeling regulation was
 adopted by the Comm₯sT6n  on March' "25; 1992, and was expected to come into operation later
 in  1992, the UK Department of the Environment stated that the  UK will  not have a national
 program. (Watkinson, 1992)
                                          198

-------
         The United Kingdom  has  been  actively involved  in developing  the
                                       ra
  .
  up a Competent Body to administer the program in that country^  TO
  S-«L";J2^^
  Industry.  (Department of the Environment, 1992)     -
              ^ ** *"   *
                     ^ ** *"?. J* °™ nati°nal envi™ental certification program, the
            Wh  h  Enviro™entu dld set UP the National Advisory Group on ^Labeling
          , which researched other environmental certification programs. They published f

     hvK^l^   ^^l0^ G™» C*™»™>- -Progress on an EcolabeU^lc^e



  information for its Eighth report: Eco-Labelling.  Published in September 1991 this report made

  ™         '   "
        o,     V      -                                              mg
 a view to being in a position-to introduce" a program "which would be able to operate under a
 national or a European scheme. " (Environment Committee,  1991)            ?

 General Principles
                                                    for an environmental certification
nPTV-de C°nsu"lersuwith accura'e information on the environmental acceptability of
products ui order that they can exercise, an effective and informed choice;

                   ^

                          *" 6nvirOnment'       Pro^e the competitive po^itl
       of
            S^r?gement\?r,enVir0nmental labeUing «» consistent with the development
         the Single European Market." (Nagel, 1991)
      inhoud     * n ^ 6nvironmental unification program should be voluntary and self-

      and should hi,    C°nSUrr PIDdUCtS 6XCept foOd ^ drink' should award pass/fail
                      "       SyStem ^ W" transParent ^ crediWe to consumers and
                                 ^ harmfti1 to the envi™' ii^ ^!^^
that are from industries that would be cooperative, and that are widely known and used.  Since
                                       199

-------
'IK   I •>'	'».
t; It ill


W>  ! •'•'
•'SI. if!;...  '
''f
jl is Important for a program to build
                                                                      n
                                                                      .ore
                                                                                                   certify
             pap-; paint, or television sets rather than snowmobiles
 •IB'1,' :..•!',"  ,!-.,.
 '£.  !• 1."  . '!"
lifc"!;!!1'
!i|'i 'W  I!''1!!
                                                                                 isa
                                                                                                       of
             next stages of the exercise may always be open to challenge.
                                                                                              -
              performance."


              Administrative Structure

                pier year for 3 years.
                                                             200

-------
         The functions of  this Advisory Body would  be to  propose product cateeories-  to
  de ermine, on the bas,s of life cycle analysis, appropriate criteria' for c'emf.cationMo review
                                 n
  Award Process
        The operation of the program would be similar to that of other environmental labelin
  programs, such as Canada's Environmental Choice or Germany's Blue Angel TorSr tc
  the trust and involvement of industry, environmentalists and consumers, U mu"t have cl
  drawn pass/fed criteria, draft criteria should be open for public review 'beforeThey aTadomel
  and  applications  for certification  should be  secret  to  protect  compan eff^m  pEc
  hteTT/h   '     °i ^ teS-S/ ***>' the 10g° ^ould -be legally protS^aga °sT rniste
  nd »      H   an aPP6a S Pr°CedUre' °ng°ing monitoHng of companies who r^eive awards'
  and a hmited time penod for the award, with subsequent reapplication.
 suggesttehbei                                       SChemes in other countries
 suggests that the label is.a real competitive advantage" for products.  Thus  consideration must

  n %      tsi s°'trSe°^C " "^ aPPliCamS feirly'  "S° that a11 applic^rS
 on an eual basis.   Like other programs, the UK program  would  charge an aoolication fee

            ""
       One difference from other environmental certification programs is that NAGEL believ^
.independent product testing may not be necessary, and that maLLurer? dTtl± btsufficiem
       e  rCtS         W°Uld rdy °n ma^tplace competition to reveal T
       The paper states that communication to the public and to industry is vital to the success
of a program. Germany's Blue Angel took a long time to make an impact b^ause   too litt e
effort was put into promoting it in the early years," while Canada deUrJntLy^id not promote

 TshoT °™ sit6 P^§ram Until ^ a SUffldent number of cenm Jproduc
in shops. NAGEL spells out three main phases of promotion:  inform industry that the '
is being developed and involve them  in developing product categories "and criteria
consumer and environmental groups; and get the message across ?o the ^neS public

                                        201

-------
References

 :   -«»^
      House of Commons Paper 474-1, September.

      Environmental Pro^Mi^^                                    l992'
      Eco-labetling: Background Briefing, May 14.
       YUGOSLAVIA
                                                                              ,
  labeling prog™ "to motivate the public -, ^^J^Sicwi. used logos with
  1991)  Before this official government act, «£• » ™n*£m'^ organic foods, non-phosphate
  Sanies like "Grien Apple" and 'Power of Namr«  o ^^"^      ducts.  There had
 /References

                        nBrn  loo.   Environmental  Labelling  in  OECD Countries
        ^StionT kcS c^ratiofrDevelopment, Techno.ogy and Environment

        Programme, Paris.



 ........ .     OTHERS


         Israel, B^ and Slovenia ^^^l^S^^^^S
   own environmental label programs,  (K osm  ^ wMe Uv ^             ^     m Bfor

   "has been approached by a number of ... ^^.^.fcs A  1990)  Also, according to
   information about its work on ^™ni^^io^
   UNCT AD, Bail's program, the Selo Verde  Green Seal ) is oe g      P-

    with the BlurAngel Program:" (UNCTAD, 1993)
                                        202

-------
 References

       Canadian Standards Association, 1990.  The Ecologo Program,  December.

       Kostant, Amy, Green Seal, 1993. Personal communication with Julie'Lynch, EPA.

       United Nations Council on Trade and Development (UNCTAD), International Trade
       Division, Trade and Environment Section, 1993.  Eco-labelling and International Trade:
       Preliminary  Information from Seven Systems (Draft),  prepared by Veena Jha, Rene
       Vossenaar and Simonetta.Zarrilli, Geneva, Switzerland, May  19.



 Organic farming certification programs:

       Organic farming certification is perhaps the most widely spread  form of environmental
 labeling.  "Government labelling programmes for ecological agriculture [organic food products]
 have been introduced in ... Denmark, France,  Spain, the United Kingdom.  Private labelling
 programmes are in operation  in  ... Australia, Austria* Belgium, Brazil, Canada, Finland,
 Hungary, Ireland,  Israel,  Italy, Japan,  Luxembourg, Morocco, Netherlands,  New Zealand,
 Norway,  Poland,  Portugal, Senegal,  Sweden,  Switzerland  and the  U.S.A."   Also,  the
 International Federation of Organic Agriculture Movements (JJFOAM)  "is in the process of
 launching an international accreditation programme for such labels, with the aim of introducing
 an international label for products from ecological agriculture." (Pedersen, 1991)

       In the United States, a number of states have regulated  the use of organic food claims,
 as has  the Federal government, with the Organic Foods  Production Act of 1990.  In addition^
 several third party certification programs are active in the U.S., including California Certified
 Organic Farmers, Farm Verified Organic, Organic Crop Improvement Association, Northeast
 Organic Farming Association, Organic Growers and Buyers Association, Maine Organic Farmers
 and Gardeners, and NutriClean, run by Scientific Certification Systems. Most of these are local
 or regional programs.                                                    ,.

    ,   The Northeast Organic Farming Association  (NOFA) has certified organic farms and
 fields since 1986.  They consider if a "service" to their member farmers more than an labeling
program; they charge a sales-based fee of only $100 to $750 per year, which does not meet the
 cost of the certification.  On average, they certify between 25 and 40  farms or fields  per year,
 for a one year period:  The farms that seek certification usually do so  in order to  sell to
 wholesalers who require third party certification of organic claims.  Farms^that.sell directly to
the public, through farmers' markets for example, generally,find it unnecessary to be  certified,

    --  In  order to be certified  by NOFA, a farm  must meet standards  for "good organic
 management practices," including crop rotation,  natural pest control and  maintaining soil
                                         203

-------
 ,_..,v. tnlikelome certification programs that allow minimal or reduced use of chemicals.
 N'OFA does not allow any use of inorganic chemicals. (Rawson, 1993)

        NutriClean  is  a program  "which  certifies  farming practices,  such  as  organic  and
 intejirate^iMSt'rnanagernent  that reduce pesticide use and lead to food that is lab tested free of
 aiy detected pesticide residues." (SCS, 1991)  Introduced in 1984, the program tests fruits and
 vegetables mostly for the west coast market.  Unlike NOFA's certification, a product may be
 grown with the use of pesticides and still receive an label, as  long as no P6511^^5™ ^
 fSund on the product tested.  Fees  are charged for tests of fields and products  $1,000 to $2,000
 J|J'fiet^or e^'jproauKaftified. (SUver,  1990)  By  1991,  NutnClean  had certified over
 306,600 acres of fruits and vegetables.
   .v:!!1'1,,,. *  "	»' ' •  •  -I. IK hill  j'l'ii!:. in 	•',  "• 'T1:11 • !>,.'..,, v: •'.ij •	! '!:•",•:!,' i" ', '•	,"'' ".'.!iiii|! •", '	"ii'," ,,i,i','"[! ii1111;. „, i,,.",,i" ,,:i "»'i,i!	'	n •..,•,',,.        •
         One 'provision'of'the'Organic	Foods"'ProductiSn'Act'is'	an  accreditationprogram for
 private  labeling operations.   The National  Organic Standards Board  is  advising  the U.S.
  Department  of Agriculture (USDA) on regulations being promulgated to  implement the. aw_
 , One proposal would set up a two-tiered accreditation program: one for larger programs involved
  in export  would meet standards set up by the'European Community;  the other would be less
	  jftnsentfor smaller programs that deal directly with farms. The administration of the  programs
  *oiifdbe paid  for  by the  USDA, while  user fees would cover the costs  of accreditation,
:,  equationsof certification programs and enforcement. (Henderson. 1993) Final regulations are
  expected in  the fall of 1993. 	'".	'"        "_    '    .
 i'  lii'1.;;!'' ,  I  „ ,„ '!",» , 'in  . ';•; I1'A " ,.' i ",	'" \f ," '  ' i	„' i" 'i*  •' "'i i, i'"" „' , '!;::»'!i:	I > V	YI l|1,,i,»1 . ,««-  • ,'', -'& '•„,, „ " ,JM,, i' ',',,',, .in ill. :•!'. • SI",;'.,'''"'.   ;    ,   '„          ,   :
  References                                     "

          Elkington. John. Julia Hailes and Jc^el Makower,'T99U'""fe Green  Consumer, Penguin.
          New York.	'	

          Henderson,  Elizabeth,  1993.   -"Update  on the Organic Foods Production Act," The
                                    >Y NOFA. vol. 2, no. 16, Spring.
          Pedersen, Bo, Technical University of Denmark,  1991.  Paper presented at the United
          Nations Environment Program, industry and Environment Office. Invitanonal Expert
         "'                                          held in Lesvos, Greece,  September .4-25.
                                                             ' 1993. Personal communication
      ."  :" " with'1 ABf Associates'^ ..... April 2.        ^

          Scientific Certification Systems (SCS), 199i;  "Leading Certification Company to Seek
          Non-Profit Status," Press release,  December 2.
  4 J.I '  i      "i  . •" •'  Mitt "'3 '	,!" .1	,.,,.'",",:	'PI , ,1: i> a"! . ": .H" i	' '!"11. 'in,'1': i: nl-> t Hi ! ». L1 '•» -n,1:, I'"':'"".' £	J - „!,! ».-' !• .111.J I '• B"* ' '•.: i	 .'
  VIr  i11  ' .""  v' V . .  I"*"
                       } 1990.  "Seals for the Times," U.S. News and World Report,  p. 81-85,
          November 12.
                                              204
                           '': , ' ,  " ' •'	 Ill, '

-------
 SELECT BIBLIOGRAPHY ON
ENVIRONMENTAL LABELING

-------
            in ii 11 iiiiiii i mi  111 in ii in  in nil i  i in i  in i in in i in in Mini 11 11 i 11 n
          SELECT BIBLIOGRAPHY ON ENVIRONMENTAL LABELING
  I i            MI I           1 1        i      i              h               •       .
•I              mi                                                               • •
Germany

1.    Duales S||m Deutschland GmbH, Der Grune Punkt [The Green DotJ:  Don't Let
      Packaging |o to Wastel Bonn.

2.    Environmental ^ti S^i^;''^:'^^^ Product Management in a Greener

      Europe, London.

3    Federal Minister for the Environment, Nature Conservation and Nuclear Safety  et al
3'i     wo  ^mentation - International Conference on Environmental Labelling: State of

      tf^
      the Reichstag, Berlin.
       halten hat].

 C.
       Umweltzeichen: The Environmental Label Introduces Itself.


       Cartridges, September.

  Canada
  !;:-:- ;^fcjsisiiS^ff^ss;Ks
        Labeling programV July 1992.
  8.     Canadian Standards Association, 1990.  77* Ecologo Program, December.

  9.     Consumer and Corporate Affairs Canada, 1991.  Guiding Principles for Environmental
        Labelling and Advertising.                            .
                     '"           ihe 'Envirovnen.* Choice
  10.
         Ottawa, Ontario, Canada.

  11     toirodSe^'rcato"P«i^V'" Comparison of Environmental Advertising
         [Consumer and Corporate Affairs vs. the Green Report}.

   12.    Environmental Reseaich Associates, 1990.  The Environmental Report, Vol. 1, Fall.
 1 "',;  ;    '* • '„ ' iuiii' "'.v , •", • ,'".,,„ ••., ;v!i"• .virflji;'•" '!i;, •• r^'v,	i'vi.SKilr'i,'1,,,' ''''"i »,:.'"'I"1,1, ' 'Hii/'1!: i.1.1:'!: "!;:»'  '•'i:;1: .i""*"1'' i .,,     • •  '     , ' '   • '( '
  '"i1,,1      , ,,'!  • ,:  " 'I,,;,!:!"!! . ••;, 	 < ,: ,,i .,,'„•', f "I |< ,;, „.,•.;, ', :'.;"', i ..isii'i'i*1,!:'!!!,,,.,,; , •", !•: ,,, .i,"1'1* •'/' 'lijt'j1; .',»!; i,1;, i ."a1!1 l1'  , i^yii.;,; '!• ' 'I,;,;,1 '•   ,     '!,'"'
                                   •	206  ' ":	'    •

-------
 13.    Environmental Choice Program, 1990. Annual Report.

 14.    Recycling Council of Ontario, 1991.  Recycling Symbols, Discussion Paper, March.

 Japan


 15.    Hashizume, Shigeyuki, 1992.  Environmental Labeling in Japan: the Eco Mark, Japan
        Environment Association, January.

 16.   Japan Environment Association,  1991. The Ecomark System, September.

 Nordic Council                    •.-',_'.-.


 17.   Bethge, Per Olof,  1991. Eco-labelling of Paper Products, written for the Ministry of the
       Environment, Danish Environmental Protection Agency, Denmark.

 18.   Danish Resource  Management  Centre  (RENDAN. A/S).   Resource Management-
       Environmental Quality in Perspective.

 19.    ENDS  Report, 1991.   "Nordic  Eco-labelling Scheme Well Under Way",  No. 203,
       December.


 20.    Foundation TEM and University  of Lund, 1989. Environmental Labelling in the EFTA
       Countries, Invitation Seminar at the TEM Centre, Sweden, August 29-29.

 21.    Nordic Council of Minsters, 1990. Nordic Action Programme on Cleaner Technologies,
       Waste and Recycling, Copenhagen.

 22.    Nordic Council of Ministers,  1991.  Environmental Labelling in the Nordic Countries:
       Position Report, Copenhagen, November.


 23.    Norwegian Foundation for Environmental Product Labelling,  1991.  Environmental
      Labelling  of Chain Oil for Chain Saws, September12.

24.    Swedish Standards Institution (SIS), 1991. Environmental Labelling in Sweden: Position
      Report, Stockholm, May.


25.   Swedish Standards  Institution (SIS).  Summary of Criteria Document About Button Cell
      Batteries,  Stockholm.                                                  "


26.   Swedish Standards  Institution  (SIS),  1992.   Nordic Framework Agreement for
      Environmental Labelling, Stockholm, January.
                                        207

-------
27~.'   Swedish Standards Institution (SIS), 1991.  Environmental Labelling of Dishwashers:
       Criteria Document, Stockholm, September 6.
':i   I             III III I                      II     I    f          II    ,,',:',,'"''      '   ,,
New Zealand and Australia

28    Ministry for the Environment, 1989,  Packaging and the New Zealand 'Environment v
       Critical Aspects of Resource Use and Waste Management, prepared by Tim Denne, Chns
       Livesy, and Jeff McNeill, Wellington, NZ, October.

29.    Ministry for the Environment, 1989.  Labelling of Environmentally Friendly Goods:  a
       Discussion Paper, Wellington, New Zealand.

 30.    New Zealand Minister for the Environment, 1992;  Media Statement, March 18.

 31    PoionskyJ  Michael  Jay,  1991.    Environmental Advertising Claims:  an Australian
       Perspective to  Contentious Issues and  Potential  Resolutions,  Draft,  University  ot
       Newcastle, Newcastle, Australia, July.

 32.   Telarc, 1992.  Environmental Choice New Zealand: Environmental Labelling in  New
       Zealand, Document EC 010, Issue No. 1, February.
                                      i                           " .1         " ,
 European Community
                                                                *
 33.   Advertising Age, 1992.  "Publishers Watch EC Move", April 27.

 34.    Background ^Notes, 'lM'  "European Community", ILS"; Dept.  of  State,  Bureau of
        Public Affairs,  May.
  'IJi'.ii .to,1 '  , i, ,' ,,;ii'i!"" "K "' .i'lii',1 .|| llliiiilliiHil, ' !,' ' '" i ' '. '':'", !' .ir,,"'!!1*, i JIMi'iiP'! .if " •|i|,:',,!"JI'1|,|:! ,,!' ',: Mll.inra .ifii'li1 ,,'iiil!'v,!i'".|i •": ', ..... '!• ''H" "'.Jiu'li'i"' fJi .inii",1,!,. 1|: I'1,,!*1!!!. ...... ii"*!11 ...... ...... * n. •   .'i •  •!" . ,.    ^-»     * I
 35     Commission of the European Communities,  1991.  Amended Proposal for a Council
        Regulation (EEC) Concerning a Community Award Scheme for an Eco- label, Com (91),
        544 final, Brussels, December 11.

  36    Commission of the European Communities, 1991.  Proposal for a Council Regulation
        (EEC) on a Community Award  Scheme for an Ecolabel, Com (91), 37 final, Brussels,
',. '  ;!;;;';,; ''. ..... "February  11.                     '              .      •                   ,,    '
  Jffi'1 '!• ' ' '':i ,,'i"!1 ! ft! , !,''!'':,!|ii :" ''„'.. mill1!' < .i| i ...... n 'i|i"i .•  'i '' HH1 ." ,,i,' ,ni'l i „ !' •' , 'i .|i».  ''."'i1 !' ?! ;f! I,'!" i11!1 ih! ..... !:,:,• ........ ,,i|' Hi .|"i!,""*!iii' i'1!1,1"' ....... i1 'i!,'1" '• .' IW" I, ii""1',,'1'!!! •' i , '   ' '  „  ,  •,' .
  37.    Commission of the European Communities.   Integrated Pollution Control Framework
   '•:.»' :•' ^Directive.
      '••       '.          .....     ..... ;.                            j.        ;._    .  ,
  38     Commission of the European Communities, 1992.  Proposal for a Council Regulation
        'Allowing Wiunimy^ariiapairdnby Companies in the Industrial Sector in a Community
         Eco-audit Scheme, Xl/83/91 - final, Brussels, January.

-------
39.    EM)S Report, 1991. "Ministers Agree Rules on Chemicals, Habitats and Eco-labelling".
       No.  203, December.

40.    ENDS Report, 1991. "EEC Eco-labelling Scheme Ready to Roll", No.  203, December.

41.    ENDS Report, 1992.  "First Product Groups for EC Eco-labelling Scheme", No.  205,
       February.       ,

42.    ENDS Report,  1991.   "EEC Eco-labelling  Scheme Stumbles  Forward", No.  200,
       September.

43.    ENDS Report,  1991.   "European Debate Starts on Eco-labels for Paints", No.  202,
       November.

44.    ENDS Report, 199.1. "Experts Wrestle with Complex Issues in Run-up to Eco-labelling
       Scheme", No. 196, May.

45.    ENDS Report, 1991. "Centralised Decision Procedure a Key Issue in EEC Eco-labelling
       Proposal", No. 193, February.

46.    ENDS Report, 1991. "Delay With EEC Eco-labelling Proposal Prompts UK Concern",
       No.  192, January.             •

47.    European Communities, the Council,  1991.  Draft Council Regulation  (EEC) on a
       Community Eco-label Award Scheme, document 10466/91, Brussels, December 18.

48.    European Bureau of the Environment (HKR) and the European Bureau  of the Union of
       Consumers (BEUC), 1991.  Eco-labelling: EEB-BEUC Position, Seminar Proceedings,
       June.                                               '  '

49.    Haddon, Matt, 1992.  "Making Green Labels Stick," New Scientist, June 20, p. 23-24.

50.    International Organization of Consumers Unions, 1991.  Comments on the Proposal for
       an Ordinance (EEC) of the Council Concerning a Common System for the Granting of
       an Environmental Logo, April 26.

51.    Poremski, H.J., P. Rudolph, K.  Lemme and E. Six, Federal  Environmental Agency,
       1991.   Detergents in  Western Europe: Environmental Labelling, prepared  for the
       Commission of the European Communities, General Directorate XI, Berlin, October.

52.    Super Marketing, 1991. "EC Agrees to Green Labels," June 28, p. 12.

53.    Trollope, Kate, 1991.  "European Community Exerting Pressure for 'Green' Labelling,"
       Supermarket News, April 1, p. 2.


                                       209

-------
           54.    Wentz, Laurel, 1991. "P&G Exec Raps Eco-labels", Advertising Age, July 1.



           United Kingdom


           55.    ENDS Report, 1991.  "Advisers Criticise Government for Delay on Eco-labelling", No.

                  199, August.


           56,    ENDS Report, 1991.  "Paper Group Sets up Own Eco-labelling Scheme", No. 197, June.


           57.    ENDS "'Report, 1991   ^ontroi'oS'iPnxiuS Claims Urged by Eco-labelling Report", No.

              	200, September.	


            58.    ENDS  Report, 1991.   "Green Consumerism Rides the Recession (Green Consumer

                  Survey in UK)," No. 195,  April.


            59.   ENDS Report,  1991.  "Preparations  Advance for Eco-labelling Scheme", No. 202,
                   November.
                       h l  in ill nil l
            60.    Financial Times (London), 1991. "Call for Full 'Green' Label," August'23, p.8.


            If.    louse of Commons Environment Committee, 1991.  Eighth Report.  Eco-labelling,

                   Volume I, House of Commons Paper 474-1.
J	i""' :'  :';:   •'  '  '"a '•' ';•'•• • ^::^ii''Mi^^^                         • VriQi
62.   National Advisory Group on Eco-Labeuing (isA(jrti-), iyyi.
                                                                                           A
                                    Progress on an Eco-labeUing Scheme for the UK, United Kingdom,


                   August 22. ....................... ..................... | ............................................. ........ _ ........ ................ -  ........ ....... ........... ,

              ii,  ..... ....... ,,i .......  ["Mi' i ',:i ..it »(." ; - ..... 'H*  •: ,"i ...... .."!'. ........ ini. ...... :'^ii!iBi!ii*i:,!,-ifj, F'l, ;,« • M'-VI •'.,» :.-!.,  "''"iii'i ...... .. •• ...... , ' • s. '••   . '        . .,

             63>   pearce, Fred, 1990.  "The Consumers are Not So Green", New Scientist, June 16.



             64.   Whitehead, Cathy, 1992.  Green Survey, Environmental Health and Trading Standards,

                   London Borough of Merton, March 3.

                                                                     I  • ' ' '

             International Groups (OECD, UNEP, ISO, GATT)
             65.    General   grMTsand Trade (GATT) ," Council, 1992.

                    Labeling of Tropical Tiomber and Timber Products and Creation of a Quality Mark for
                    Timber and Timber Products from Sustainable Forest Management, Communication from

                    the ASEAN Contracting P'arties," L/71 10, Ctotober 23.


             66    International  StandardLzation  Organization  (ISO),:  Strategic  Advisory  Group  on

                    Environment  (SAGE),  Environmental  Labeling Subgroup,  1992.   Environmental

                    Advertising, September 8.
')' IBS:; ! "  ,•: ',
i jiiimi1 : L'  : ••

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67.    International  Standardization  Organization  (BO),   Strat   ic  Adviso    G
       Environment (SAGE),  1991, Draft Recommendations to th e Secretary General ISO on
    .   Environmental Labelling, Novembers.     .   -           .   .   y ^TUirai- l*v , on

68.    International  Standardization  Organization  (ISO),   Strategic  Advisory  Group  on
       Environment  (SAGE),  Environmental Labeling Subgroup,  1991.    Report  on the
       Organizational Meeting, September 12.                                  Conine

69.    International  Standardization  Organization  (ISO),  Strategic Advisory  Group  oh
       Environment  (SAGE),  Environmental Labeling Subgroup,  1992.   Environmental
                                                              ,      .             na
                 Terms and Definitions, Environmental Labelling Sy.mbols, and Environmental
        Labelling Testing and Verification Methodologies, July 28.

 70.    International  Standardization  Organization  (ISO),  Strategic  Advisory  Group  on
        Environment (SAGE), Environmental Labeling Subgroup, 1993. Final Report (Draft)
        J 11116.  -    •

 71,    International Standardization Organization (ISO), 1991. "Consumers  Stress Need for
        International Standards of Eco-labelling" ,  ISO Bulletin, 22:8, August.     :

 72.    Salzman, James, 1991.  Environmental Labelling in OECD Countries, Organization for
        Economic Cooperation and Development,  Technology and  Environment Programme
        Fans.                                                                        '

 73.    United Nations Commission on  Trade and Development  (UNCTAD)   1993   ECO
        Welling and International Trade: Preliminary Information from Seven Systems, prepared
        by Veena  Jha, Rene Vossenaar and Simonetta Zarrilli, International Trade Division
       Trade and Environment Section, Geneva, May 19.

 74.    United Nations Environment Program, Industry and Environment Office  1991  Global
       Environmental Labelling: Invitational Expert Seminar,  Working  Group on Policies
       Strategies and Instruments, held in Lesvos, Greece, September 24-25,               '

United States

75.    Advertising Age, 1990. "Green Seal Unveils Plan:  Colgate, Kimberly-Clark, P&G Not
       Interested," June 18.

76.    California EPA, Office of Environmental Health Hazard Assessment (OEHHA)  1992
       The Implementation of Proposition 65: A Progress Report: July 1992.

77.    Council on Economic Priorities  (CEP), 1989.  Shopping for a Better World, Ballantine
       Books; New York.
                                        211

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         73.    Council on Plastics and Packaging in the Environment  (COPPE).   Perspectives on
                Environmental Labeling.

         79.    Dadd, beBraEynn, 10901 ^oriioxic, Natural & Earihwise,  Jeremy P. Tarcher, Inc., Los
Sil.,•: i .:.'!•"•..  ,   t" ?• '•.; ;«•?	« ''«"<"	«	- •-• >•  ••	• •	-•	 	>•	 	•• • • • •«•••'	• • •	• ••"	-	• • • >	-• • •	-	•   •  •             •
?!!i:;: • • ;;  •	•    •   Angeles.      ,                          _               ,

         80.    Fisher,  Christy,  1992.   "Green  Seal Product  Will be Revealed,*" Advertising Age,
                October 26, p. 18.

         81.    Fisherl Christy, 1989.  "'Seal of Green' Planned," Advertising Age, November 20.

         82.    Fisher, Christy, 1991.  "Seal of Confusion," Advertising Age,  June 24.
     ,.<<:'               ||    I• II• I I    I     I   I   II   I I I  I I I    I II       II I IrII II   1         '	 .    :
     V, i :ii>;,     |,l ||, I       | 11   |||||||||||l||||||| | I | |	||HJ |l | H | II II ||l I M III,  I II III I    II Ml  I HI   1 I  .    . ,   	 I.' '  T	
         83.    Freeman, Laurie,  1991. '^Ecology Seals Vie for Approval," Advertising Age, January
      "	i-.   	29.                                                .             .;:;   .;  .

         84.    Green Seal,  1991.  "Green Seal/UL Alliance: Questions and Answers,"  and additional
                promotional materials.

         85.    Green Cross  Certification^Cqrnrjany,'  1991.  Review of the Green Cross Certification
                Program:  Prepared in Response to the Environmental Defense Fund Report, October 17.

         86.    Grodsky, Jamie A., 1993.  "Certified Green: The  Law and Future of  Environmental
                Labeling," Yale Journal on Regualation, 10:1, Winter.

         87.    Johnson, Bradley, 1991. "Green Rivals See Red," Advertising Age, February 11,  p. 34.

         88.    Johnson, Bradley and Christy Fisher, 1992.  "Seals Slow to Sprout: Why Green  Logos
                Aren't on Products Yet", Advertising Age,  April 20.
          89,    Kizer, Kenneth W., et al.,  1988.   "Sound Science in the Implementation of Public
                Policy:  A Case Report on California's Proposition 65,"  The Journal of the American
                Medical Association, August 19, 260 (7): 951-955.

          90.    Makower, Joel, 1991.  "Greener Than Thou:  a New Round Begins in the Battle of the
                Eco-labels," Green Consumer Letter, September.
          91.    Sari Diego ' Union:fribune, 1992.  "gHpper's Face on Tuna Saving Dolphins,  Group
        :••':     ""..,» Says'," June II ..........          "                  ...... ' .....................       "  .   "

          92.    Smith,  R.  Justin and Richard A.  Denison,  1991.  At_ Cross Purposes?:  A  Critical
               ^Examination of Green Cross's Environmental Record, Environmental Defense Fund,
                Washington, D.C., September 30.
                                                   212

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^3.   Task Force of'State Attorneys General,  1991.  The Green Repon II: Recommendations
      for Responsible Environmental Advertising, May.     -       •   ,

94.   Task Force of State  Attorneys  General,  1990.   Tlie  Green Repon: Findings and
      Preliminary Recommendations for Responsible Environmental Advertising,  November.

95.   Underwriters'   Laboratories,   Information   Kit,    including   "Annual   Report,"
      "Backgrounder," "Standards for Safety," and  "Yesterday, Today, Tomorrow."

96.   U.S. EPA, 1989.  Environmental Labeling in the United States: Background Research, ,
      Issues, and Recommendations - Draft Repon, prepared  by Lori  K. Carswell, Julia J.
      Langel, and Adam B.  Borison,  Applied Decision Analysis. Inc., December 5.

97.   U.S'. EPA, 1993.   Evaluation of Environmental Marketing Terms in the .United States.
      prepared by Andrew Stoeckle,  Julie Wormser,  Bentharn Paulos.  Steve Hochman, and
      Herbert Han-pu Wang, Abt Associates .'Inc.,  Febraury, EPA 741-R-92-003.
                               ' '.                   -         '
98.   U.S. 'EPA,  Risk  Reduction   Engineering  Laboratory,   Office  of  Pvesearch and
      Development,   1990.    Background  Document on  -Clean  Products Research and
      Implementation, prepared by Franklin Associates for EPA. Cincinnati, Ohio, June.

99.   Vermont. State of. 1992.  The  Vermont Household Hazardous Products Shelf Labeling
      Program - Retailer Information Guide.                                .      •      .

100.  Wynne.  Roger D., 1991.  "Defining 'Green': Toward Regulation of  Environmental
      Marketing Claims," Universityof Michigan Journal of Law Reform, 24:3 and 4, Spring
      . and Summer.                      .   '  .                      .
                                     *           -             -.''.-•
Other countries

101.  Chile, Casa  de la Paz,  1991.   Eco-labelling  in  Chile,  presented  at  the  Global
      Environmental  Labelling  Seminar,  sponsored  by the  United Nations Environment
      Programme, Industry  and Environment Office,  Working Group on Policies, Strategies
      and Instruments to Promote Cleaner Production, September 24-25.

102.  France-, Association Francaise De Normalisation, 1992.'  General Rules Applicable to the
      NF-Environnement Label, Paris.

103.  India,  Ministry of Environment and Forests,  Department of Environment,  Forests^ and
      Wildlife, 1991. Resolution, published in The Gazette of India,  No, 71, Part n, Section
      3, Sub-section i, New Delhi, Thursday, February  21.

104.  Netherlands, Stichting Milieukeur,  1992.  The Dutch Ecolabel: Added  Value for Your
      Product, the Netherlands.

                                         213                                     .

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                             ..' "I,;!	IB	In:,,,. 'I1 ,'i,!"v hii'1 Mu
Europe in General
   >,',!,.:   -,'- 	' '• ;; ' , ill IV 1 ' 	 !'I

,105;	 Economist ^1991. ,„",]

106;   E2VDS Report, 199_  "Eco-labelling:  a New Environmental Challenge for Business."
    p';; :i	i^Q^	g'g'^'^'g'gj" ''''Green	'(j'd/wwmemm	fl/uf Environmental Labeling in Europe,
       Danish Resource Management Centre, Soeborg, Denmark.

 108,  Rose,  Julian,  1991.   "Euro-confusion  for  the Green  Consumer?  (Eco-labelling),"
       Chemistry "and Industry, February 4, p.72.

 109.  Smith, Turner  T.,  199sl   Understanding European Environmental Regulation, The
       Conference Board, New York, Report Number 1026.

;,110:!'TrSope,Iate,'''':'l991.:	"^'ChS?	iXdTpfiM	BleWin'Europe," Supermarket
       News, May 6, p. 66.

 ;,,G|neral.

  111.   Engineer,  1991.  "'Green' Labels Plan Slammed."  June 6, p.15.

  112.   Frankel, Carl, 1992.  "Do Seals Sell?   The Market Impact of Product Certification,"
        Green bfdrket Alert, February.
  IB.  Holmes, Hannah, 1991.  "The Green Police: in the Environmental Holy War, Who Can
 ; '^

  114.  International Chamber of Commerce, 1991;  Environmental Labelling Schemes  (ELS),
   If! •  ICC Position ...... Paper, Paris, June! .......................... : ............. '   ....... .  ................. .

  ijfi.'  Itiepacici; ...... ' ..... LKW.''' ...... »ConSslon^                           Supermarket
  .      News, January 28, p.25

  116.   Salzhauer, Amy Lynn, 1991. "Obstacles and Opportunities for a Consumer Ecolabel,"
         Environment,  November, p. 10.
   ri ,,,,':i! l!l"    ' ........ Hl  "' '! ' ' , iliwii' ,,iL ..... » ",". "'inJ!,'/,,'!.1,,,1 '.'..Jl'l.!111 'ilf1 ..... :ii' '« ' , ''iiii \/t iiil''1! ,,,""i «:„' i k'\ ...... i'l'vb: 'ixiij "i'™'1'.'"1 i ..ifW'.1,1,1"1 ,.'?. ''' ;i': ', ' • '• hlliilrift .'"".,', \ ?_'•  " •   •"' '  •  ., y/^ A'o" TA '
  117.   Salzman; James, 1991.'  "Green Labels for Consumers," OECD Observer 169:28-30,
         April/May.
   118.   Scammon, Debra L. and Robert N. Mayer, University of Utah, 1992.
         Labeling and Advertising  Claims: International Action and Policy Issues, submitted to
         tne Summer ACR Conference, Amsterdam, the Netherlands, June 11-14.
                                            214

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119.  Schorsch, Jonathan, Council on Economic Priorities,  1990.  It's Not Easy Being Green:
      Can Our Economy Come Clean?, CEP Research Report,  April.

120.  Stillwell, E. Joseph, R.  Claire Canty,  Peter W. Kopf, Anthony M. Montrone, 1991.
      Packaging for the Environment,  Arthur  D. Little, Inc.,  American Management
      Association, New York.                                    .

121.  U.S.  Congress,  Office  of Technology  Assessment  (OTA),  1992.   Trade  and
      Environment:  Conflicts and Opportunities, OTA-BP-ITE-94, Washington, B.C., U.S.
      Government Printing Office, May.

122.  Watson, Tom, 1989. "Product Labeling Efforts are on the March Worldwide", Resource
      Recycling, October.

123.  Weber, Peter, 1990.  "Green Seals of Approval Heading to Market," World Watch,  July
      8, vol. 3, no. 4:7-8.

Life Cycle Analysis

124.  Cooney,  Catherine, 1991.  "Experts Say Life Cycle Analyses Key to Green Labeling";
      Environment  Week, 4:15, April 11.

125.  ENDS Report, 1992. "Bridge-building Forum Proposed for LCAs", No. 205, February.

126.  ENDS Report, 1991. "Analysing the Environmental Impacts of Packaging: Progress and
      Pitfalls", No. 192, January.

127:  ENDS Report, 1991.  "Spillers Misuses Life-cycle Data in  New Can Promo'tion",  No.
      201, October.

128.  ENDS Report, 1991.  "Problems with Life-cycle Analysis Highlighted by Conflict  over
      Nappies", No. 198, July.

129.  ENDS Report, 1991.  "New Group to Develop Standards  for Life-cycle Analyses", No.
      195, April.

130.  ENDS Report, 1991.   "Curbs  Urged on  Use of Life-cycle  Analysis in Product
      Marketing"-, No. 198, July.

131.  Environment  Reporter, 1991.  "Life-cycle  Analysis Imperfect  but Useful, Corporate
      Executives Conclude at Conference," Obtover 25.

132.  Inside EPA, 1991.  "Scientists Warn 'Cradle to Grave' Product Analysis not yet Strong
      Policy Tool," October 18.

                                        215

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