Washington, DC 20460
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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.
-------
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
-------
-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
-------
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
-------
)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.
-------
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 ' '
-------
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
-------
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
-------
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
-------
- 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.
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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.
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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.
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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.
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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." .
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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.
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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
-------
&" 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
-------
GERMANY'S BLUE ANGEL
-------
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
-------
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
-------
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
-------
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.
-------
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
-------
-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, .,|
-------
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
-------
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
-------
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
-------
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
-------
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
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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.
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GREEN SEAL
-------
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.
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SWEDEN'S GOOD
ENVIRONMENTAL CHOICE
-------
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.
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ENVIRONMENTAL CHOICE NEW ZEALAND
-------
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.
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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"
-------
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
-------
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
-------
SINGAPORE'S
GREEN LABELLING SCHEME
-------
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' * " ' ' .
-------
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
-------
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
-------
-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
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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
-------
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)
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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
-------
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
-------
' 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'^
-------
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
-------
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. ,'".'-.
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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!
-------
(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
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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
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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!
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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
-------
: 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
-------
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 erofi°'^
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?' ' '
-------
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)
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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
newspapernotices 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.
-------
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
-------
f' '
EPA'S OZONE DEPLETING SUBSTANCE
WAKNINCT
-------
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""
-------
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 ^^.^
-------
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
-------
::; 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°/ns*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
-------
...... 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
-------
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
-------
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
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Reference
Dadd Debra Lynn, 1990. Nontoxic, Natural & Eanhwise, Jeremy P. Tarcher, Inc. , Los
*»J l&CtCo . ' - '
185
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.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
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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
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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
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,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
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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 enviental certification program, the
Wh h Enviroentu 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
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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
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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
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,_..,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, '
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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
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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' :
-------
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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