prepared for:

                 Julie Winters Lynch
             Pollution Prevention Division
        Office of Pollution Prevention and Toxics
      United States Environmental Protection Agency
                 401 M Street, S.W.
               Washington, D.C. 20460
      Principal Investigator: Gary A. Davis, Director
     Center for Clean Products and Clean Technologies
                University of Tennessee
                327 South Stadium Hall
              Knoxville, Tennessee 37996

                   September 1993

            EPA Project No. X 820663-01-0
                   Printed on Recycled Paper


                            TABLE OF CONTENTS

      1.1    Objectives of Project	  1
      1.2    Overview of Environmental Labelling	  1
      1.3    Overview of Life Cycle Assessment	  2
             1.3.1  Goal Definition and Scoping	  4
             1.3.2  Inventory Analysis	  4
             1.3.3  Impact Analysis (Assessment)  	  4
             1.3.4  Improvement Analysis (Assessment)  	  6
             1.3.5  "Streamlined" LCA	  6
             1.3.6  Life Cycle Concept	  6
      1.4    Previous Statement From the United States EPA About the Use of
             LCA in Making Environmental Claims	  7
      1.5    Statements From the LCA Community About the Use of LCA in
             Environmental Labelling	  7


      2.1    International Declarations on Environmental Labelling
             Methodologies	  8
             2.1.1  Berlin Statement on Environmental Labelling	  8
             2.1.2  Lesvos Statement on Environmental Labelling  	  8
             2.1.3  European Communities Eco-Label Regulation	  9
             2.1.4  International Standards Organization/Strategic Advisory
                   Group on the Environment	   10
      2.2    Description of Environmental Labelling Program Methodologies  ...   11
             2.2.1  European Communities Eco-Labelling Program  	   11
          General Procedure  	   11
          Procedures for Setting Criteria with Examples	   12
                   UK Ecolabelling Board "Streamlined LCA"	12
                   Danish "Quantitative and Qualitative" Life Cycle Assessment  .   14
                   French "Ecobalance"  	16
             2.2.2  German "Blue Angel" Program  	   17
          General Procedures	   17
          Procedures for Setting Criteria	   18
          Example  	   19
             2.2.3  French Environmental Labelling Program	   20
          General Procedures	   20
          Procedures for Setting, Criteria	   20
          Example                   	21
             2.2.4  Dutch Ecolabel Program  	   21

         General Procedures	   21
         Procedures for Setting Criteria	   22
         Example	   23
            2.2.5 Nordic Council "White Swan" Program	   23
         General Procedures	   23
         Procedures for Setting Product Criteria	   24
         Examples	   24
            2.2.6 Austrian Program	   25
         General Procedures	   25
         Procedures for Setting Criteria	   26
            2.2.7 Canadian Environmental Choice Program	   27
         General Procedures	   27
         Procedures for Setting Criteria	   28
         Example  	   28
            2.2.8 Green  Seal	   30
         General Procedures	   30
         Procedures for Setting Criteria	   30
         Examples	   31
            2.2.9 Japanese Eco Mark Program	   34
         General Procedures	   34
         Procedures for Setting Criteria	   34
         Examples	   35
            2.2.10 Singapore Green Labelling Scheme  	   36
         General Procedures	   36
         Procedures for Criteria Development	   36
         Example	   36
            2.2.11 Environmental Choice New Zealand	   37
         General Procedures	   37
         Procedures for Criteria Development	   37
         Examples	   38
      2.3   Comparison of Criteria Among Labelling Programs  	   38


      3.1   Single-Attribute Claims Certification	   41
      3.2   Product Environmental Information Profile Approach 	   41
            3.2.1 Scientific Certification Systems Environmental Report Card ...   41
            3.2.2 Dutch Programs  	   44
      3.3   Expert System Evaluations	   45

4.    FINDINGS  	  50



1.1    Objectives of Project

       This report documents the methodologies used by independent, third-party
environmental labelling programs for the development of criteria for certification of
products for environmental labelling. In particular, the project investigated the extent to
which life cycle assessment (LCA) methodologies are being used in environmental
labelling programs worldwide. The report also describes alternative methodologies that
are being used or  that could potentially be used for environmental labelling.

1.2    Overview of Environmental Labelling

       This report focuses on the methodologies used  by environmental labelling
programs that operate as some form of independent third-party certification of the
environmental attributes of products (and sometimes, services). The terms "ecolabelling"
and "environmental labelling" are intended to be interchangeable in this report.

       Seal-of-approval programs, single-attribute certification programs, and product
environmental information ("report card")  labelling programs can be categorized together
as third-party certification programs, while environmental labelling performed by
marketers themselves can be considered "first-party" activity. Like third-party
certifications, however, labels produced or claims made by a first party may also be
based upon objective criteria that are developed internally.

       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 a  manufacturer. Both of these types
of labelling are often referred to as "seal programs", since some type of seal of approval
is awarded that can be displayed on the product label  to indicate that the product meets
predefined environmental criteria. Product environmental information labelling (report
cards) offer  consumers information on the label about a product's and/or a company's
environmental performance in multiple categories (e.g., energy consumption, water
pollution) without necessarily awarding a seal that denotes relative superiority (US EPA

       All of the programs discussed in this report are voluntary, although some
 environmental labelling has been made  mandatory (e.g., energy efficiency labelling, CFC
 labelling). Product environmental labelling in general can be positive, neutral, or
 negative-meaning that labelling information can promote positive environmental
 attributes of products, can disclose information that is neither inherently good nor bad, or
 can require (negative) warnings about the hazards or environmental impacts of products
 (e.g., "contains CFCs"). The labelling programs discussed in this report, with the

 exception of report card type programs, which are intended to be neutral, are all positive
 programs, offering label information as a means of promoting the purchase of cleaner

       All environmental labelling programs that have some type of official governmental
 sanction are third-party seal-of-approval programs. These include the European
 Communities Eco-labelling Program, the Nordic Countries program, and the national
 programs of Canada, France, Germany, Austria, the Netherlands, Singapore, New
 Zealand, and Japan. There are other third-party seal-of-approval programs operated as
 unofficial labelling programs, such as the Green Seal program in the United States, which
 does not have a government-sanctioned program.

       The history and structure of existing environmental labelling programs have been
 described in detail elsewhere (OECD 1991; Danish Technological Institute 1990;
 Environmental Data Services 1989; US EPA 1990; US EPA  1993a). There are currently
 around 13 third-party certification environmental labelling programs  in existence
 worldwide (US EPA 1993a).

       Third-party seal-of-approval programs of the type considered  in the first part of
 this report operate through the development of objective criteria for product categories
 that determine eligibility for a seal of approval denoting that the product is
 environmentally superior to others in its class. In most of the  product criteria developed
 to date, only a limited number of aspects of the product's life cycle environmental
 impacts are considered. For instance, some criteria for paper products include only the'
 recycled  content. The environmental impacts considered in developing labelling criteria
 for different products can include a wide  variety, such as ozone depletion, global
 warming, smog formation, human toxicity, noise, energy use, and non-renewable
 resource depletion.

 1.3    Overview of Life Cycle Assessment

       EPA defines life cycle assessment  (LCA) as follows:

       A concept and methodology to evaluate the environmental effects of a
       product or activity holistically, by  analyzing the whole life cycle of a
       particular product, process, or activity. The life-cycle assessment consists
       of three complementary components—inventory, impact, and improvement—
       and an integrative procedure known as scoping (US EPA 1993b).

       The definition/description of life cycle assessment developed internationally
through the Society for Environmental Toxicology and Chemistry (SETAC) is as follows:

       Life cycle assessment is an objective process to evaluate the environmental
       burdens  associated with a product, process or activity by identifying and

      quantifying energy and materials used and wastes released to the
      environment, to assess the impact of those energy and material uses and
      releases to the environment, and to evaluate and implement opportunities to
      affect environmental improvements. The assessment includes the entire life
      cycle of the product, process or activity, encompassing extracting and
      processing raw materials; manufacturing, transportation and distribution;
      use, re-use, maintenance; recycling and final disposal (SETAC 1993).

      In the last three years a major effort nationally and internationally has been
undertaken by the United States EPA, the  Society for Environmental Toxicology and
Chemistry, and other national and international organizations to develop the tool of LCA
to the point of scientific acceptance and policy relevance (US EPA  1993a; SETAC  1991;
SETAC  1992; CML 1992). The most recent international activity was the SETAC LCA
Code of Practice Workshop held in March 1993, in which LCA experts developed a
consensus on guidance for practitioners in  the performance of life cycle inventory
analysis  and on the need for further developments in impact analysis and improvement
analysis  (SETAC 1993). The details of the development of a scientific consensus
concerning LCA are beyond the scope of this  report, but the basic elements of LCA and
their status of development are central to the use of LCA as part of the methodology for
environmental labelling.

      LCA is composed of four components  as illustrated in Figure 1, below:

                                  Figure 1

     Impact Assessment
        - Classification
        - Characterization
        - Valuation
      Source: SETAC 1993
Inventory Analysis
 - Resource Acquisition
 - Manufacturing
 - Waste Management

•      goal definition and scoping;
•      inventory analysis;
•      impact analysis (assessment); and
•      improvement analysis (assessment) (US EPA 1993b; SETAC 1993).

Full life cycle assessment has been represented visually as involving the three analytical
processes with goal definition and scoping taking place throughout all three (See Figure

1.3.1  Goal Definition and Scoping

       This component consists of the definition and purpose of the study, the scope of
the study, the establishment of the functional unit being considered, and the procedure for
the quality assurance of the results. Goal definition and scoping take place throughout the
LCA study. The scope of the study defines, first and foremost, the system boundaries
that are necessary to ensure that the analysis addresses the purpose of the study. The
scope also  includes definition of assumptions, data requirements, and limitations of the
study.  The functional unit is the measure of performance that the system being  studied
delivers. For instance, "the amount of detergent necessary for a standard household
wash"  or "the coating of a surface area with paint for a defined period of time" (US EPA
1993b; SETAC 1993). Goal definition and scoping in LCA studies is considered well-
defined as a process (SETAC 1993).

1.3.2  Inventory Analysis

       The inventory  analysis component of an LCA is a "technical, data-based process
of quantifying energy and raw material requirements, atmospheric emissions, waterborne
emissions,  solid wastes, and other releases for the entire life cycle of a product, package,
process, material or activity" (US EPA 1993b). The life-cycle inventory (LCI)
methodology has been evolving since the  1960's, although the initial focus was  on energy
use, with major companies using LCI to make internal product improvement decisions.
Most LCA studies,  to date, have really been LCI studies, since they did not go beyond
the quantification of resource and energy inputs and pollutant releases throughout the life

       The methodology for inventory analysis is considered to be well-defined and
understood, but there are some key issues that are still being discussed in the practitioner
community. These include  the sources, availability and quality of data, the allocation
procedures for co-products, the inclusion of waste management impacts, and the
allocation of inputs and outputs in a system involving recycling (SETAC 1993).

1.3.3  Impact Analysis (Assessment)

       Impact analysis in LCA  is "a systematic process to identify, characterize, and

value potential ecosystem, human health, and natural resource impacts associated with the
inputs and outputs of a product or process system" (US EPA 1993c). SETAC uses the
term "impact assessment" instead of analysis to connote the sometimes qualitative nature
of the process (SETAC  1993). Impact analysis is used to  evaluate the significance of the
results of a life cycle inventory, which typically are long  tables of quantities of resources
and energy used and specific pollutants or wastes released to air, water, or soil during the
stages of the life cycle.  In studies of the past, these were merely aggregated and summed
as total energy used, total mass of natural resources used, total mass of air pollutants,
total mass of water pollutants, and total mass of solid wastes generated. This "less is
best"  approach does  not allow for evaluation of trade offs between totally different types
of potential impacts, such as global warming versus human toxicity.

       Impact analysis is currently under development, and there is, as yet, no generally
accepted methodology (SETAC 1993). Nonetheless, there are practitioners  using various
types of impact analysis methodologies in LCA studies that are being used  for making
real decisions in product design and, in some cases, the development of environmental
labelling criteria.

       The conceptual framework for life cycle impact analysis that has received some
degree of consensus  includes three steps: classification, characterization, and valuation
(US EPA 1993c; SETAC 1993). Classification  is the assigning of inventory items
(quantitative inputs and  outputs from the LCI) to impact categories based upon an
elaboration of impact networks, which are the potential cause-and-effect linkages between
inventory items and  ultimate impacts on human health, the ecosystem, and  resources. For
instance, in  the classification step, air pollutants that can  cause ozone depletion are
assigned to the ozone depletion impact category, and air pollutants that cause acid
precipitation are assigned to an acid precipitation impact category. A single pollutant may
give rise to  more than one type of impact (e.g., NOX, which can cause acidification and
can also participate in the formation of photochemical smog) (US EPA 1993c).

       Characterization is the  process of aggregating and quantifying impacts within the
impact categories, where possible, which involves an understanding of the  environmental
processes that lead from the inventory item to the ultimate impact of concern. For
instance, the global warming potential of several different greenhouse gases released
during the life cycle can be  aggregated and expressed as CO2 equivalents.  This step is
much less defined for outputs  that may cause only localized impacts, such as releases of
acutely toxic, non-persistent chemicals, since life cycle studies are rarely site-specific and
aggregating toxic chemical releases over different stages of the life cycle that would be
conducted in different locations does not present an accurate picture of the risk created by
the releases in any one  location.

       Finally, valuation is  the step where the different impact categories are considered
in relation to each other in order to further aggregate the results of the impact assessment
or to allow for further interpretation of the results (US EPA 1993c; SETAC 1993). The

 valuation step is not an objective process, but depends upon social and cultural values and
 preferences. For instance, the importance ascribed to human health impacts versus
 ecological impacts is a cultural, ethical, and political issue.

 1.3.4  Improvement Analysis (Assessment)

       The improvement analysis is the component of LCA in which options for reducing
 the environmental impacts throughout the life cycle of the system under study are
 identified and evaluated (US EPA 1993b). Again, SETAC uses the term assessment
 instead of analysis to connote the sometimes qualitative nature of the exercise (SETAC
 1993). The inventory analysis, alone, may be used to reveal aspects of the product life
 cycle that can be improved. The use of impact analysis may be necessary when the
 inventory results present a "mixed bag" of inputs and outputs, with no clear picture of the
 most significant stages  of the life cycle or the most significant impacts. Although the
 methodology for improvement analysis has not been elaborated in the way the inventory
 and impact analysis components have, improvement analyses based upon life-cycle studies
 have been conducted and are  being used today (SETAC 1993).

 1.3.5  "Streamlined" LCA

       A full life cycle assessment, as that term  has been defined, requires a tremendous
 amount of data to complete even the inventory component for all of the inputs and
 outputs for every  component of a product in every stage of the life cycle. The impact
 analysis and improvement analysis components require even more hard-to-obtain data
 and, as noted above, require methodologies that  have not been fully developed. For some
 purposes, the use of "streamlined" LCA, which  does not attempt to collect data for every
 input and output for every component of a product in every stage of the life cycle, may
 be sufficient, although there is no agreement among the life cycle practitioner community
 about whether such a streamlined LCA should be done or about the methodology for
 performing one. Forms of streamlined LCAs are being used, however, by environmental
 labelling  programs in the development of product labelling criteria, as discussed below.
 Some form of streamlined LCA can make the use of LCA in environmentally labelling
 more practicable.

 1.3.6  Life Cycle Concept

       The life cycle concept  is  simply the holistic approach to evaluating the
environmental impacts of a product system from  cradle to grave. Life cycle assessment in
its fully quantitative form is the rigorous analytical application  of the life cycle concept. It
should be recognized that the  life cycle concept can be utilized without the application of
full quantitative life cycle assessment.

1.4   Previous Statement From the United States EPA About the Use of LCA in Making
      Environmental Claims

      The United States EPA has previously stated a position about the use of LCA in
making environmental claims. In Ms testimony before the Federal Trade Commission
(FTC) Hearings on Environmental Labeling, Deputy Administrator F. Henry Habicht n
stated that "EPA believes it is premature for a company to use the results of lifecycle
analysis to promote its product as better for the environment than another." He stated
further that, "Lifecycle analysis  simply is not well enough developed as a technical tool
to allow such kinds of specific comparisons" (Habicht 1991).

1.5   Statements From  the LCA Community About the Use of LCA in Environmental

      The potential use of LCA in environmental labelling has  been recognized from the
beginning of the recent discussions about LCA methodology. The recently developed
SETAC Guidelines for Life-Cycle Assessment contain the following statement:

      The use of LCA results in the public domain such as setting criteria for
      Eco-labelling or to substantiate environmental claims is cause for debate.
      Even with great care of disclosure, information from certain applications
       such as the use of LCI information as the only basis for broad sweeping
      environmental claims should be used and interpreted with caution. The use
      of LCA to support these activities should be subject to the guidance
      provided  herein. However, it is recognized that the LCA methodology  may
      influence the way in which labeling programs are  designed (SETAC  1993).

       The recent United Nations  Environment Programme Expert Seminar  on Life Cycle
Assessment and its Applications, held June 9-10, 1993, in Amsterdam, resulted in the
following conclusions related to environmental labelling:

       An important application concerns the (use) in ecolabelling schemes ...  It
       should be clear however that LCA never can be a substitute for decision
       making. LCA can be a decision support tool only.

       The methods used to support the rewarding or refusing of ecolabels now
       differ strongly between countries. Therefore there is a need for a  guidance
       document, as by the EC  (European Communities), to standardize  the way
       LCA is used here . . . LCA can also play a role in supplying information
       for product certification, for instance the minimum percentage of  recycled
       material to be used.

       Sometimes a product scores better on one environmental aspect and a
       second product on another  . .  . One then has to compare apples and  pears.

       In such case a balance may be struck by an independent representative
       panel of experts (Udo de Haes 1993b).

       As discussed below, although some organizations and some LCA practitioners
may have reservations about the use of LCA  in environmental labelling, the methodology
is currently being used to support the development of product criteria in several
environmental labelling programs.

2.1    International Declarations on Environmental Labelling Methodologies

       Environmental labelling methodologies have received attention in the last three
years as more and more programs have been developed. Following are some international
declarations concerning these methodologies, with the European Communities having
embodied the life cycle concept in an EC  Directive that is binding on the twelve member

2.1.1  Berlin Statement on Environmental Labelling:

       The following consensus statement resulted from an early environmental labelling
conference held in Berlin in  1990:

       Objective environment-related product labelling demands that the products
       and/or product groups be looked at in a comprehensive and technically
       sound way. The products to be labelled are therefore to undergo a
       thorough assessment taking the form, for example, of an ecological balance
       sheet, where possible comprising the entire life-cycle of a product and the
       relevant environmental aspects which apply, and depending on the nature
       of the product, the suitability for use and safety (German Federal Ministry

2.1.2  Lesvos Statement on Environmental Labelling:

       The United Nations Environment Programme, Industry  and Environment Office,
and the University of Lund,  Sweden, sponsored an expert seminar on environmental
labelling in 1991, resulting in the following  declaration on methodologies for criteria
development (set out in part):

       The following items were identified as characteristic of environmental
       labelling programmes:

             determination  of criteria based on life-cycle review  of a product


             criteria levels established to encourage the development of
             products/services that are significantly less damaging to the
             environment; . . . (UNEP 1991).

2.1.3  European Communities Eco-Label Regulation

       The Council of the European Communities Regulation No. 880/92 sets out the
framework for the EC Eco-Label Program  (EC 1992). The regulation incorporates the
product life cycle concept in its objectives and in the framework for the methodology to
be used in setting product criteria.

       Article 1 of the regulation states the objectives for the eco-label scheme, which
are 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
             impacts of products, without, however, compromising product or
             workers'  safety  or significantly affecting the properties which make
             a product fit for use.

       Article 5,  paragraph 4, of the regulations contains the requirements  for the
methodology for  setting specific product criteria for award of the eco-label. That
paragraph states:

             The specific ecological criteria for each product group shall be
       established using a 'cradle-to-grave' approach based on the objectives set
       out in Article 1,  the general principles set out in Article 4 and the
       parameters of the indicative assessment matrix shown in Annex I. The
       criteria  must be precise, clear and objective so as to ensure uniformity of
       application by the competent bodies. They must ensure a high level of
       environmental protection, be based as far as possible on the use of clean
       technology, and, where appropriate, reflect  the desirability of maximizing
       product life.

 "Cradle-to-grave", as defined  in the regulation, means:

       the life cycle of a product from manufacturing, including the choice of raw
       materials, distribution, consumption and use to disposal after use.

        Annex I to the regulation, the "Indicative Assessment Matrix", is a simple, check-
 the-box, type of matrix, reproduced below:
            Table 1; "Cradle-to-Grave" Matrix for EC Eco-Labelling Scheme

Waste relevance
Soil pollution and
Air contamination
Consumption of
Consumption of
natural resources
Effects on eco-
Stage of Product Life Cycle





2.1.4  International Standards Organization/Strategic Advisory Group on the
       Environment, Environmental Labelling Subgroup

       The Strategic Advisory Group on the Environment (SAGE) has been meeting for
the last two years under the aegis of the International Standards Organization (ISO) to
develop strategies for standardization in the field of environmental management tools and
has formed a new Technical Committee to develop ISO standards in the environmental
management field. The ISO/SAGE process included a subgroup on environmental
labelling, which met four times. That subgroup developed recommendations to
ISO/SAGE, which included a recommendation "that the Criteria developed for [third-
party seal-of-approval programs], where possible, follow scientific information relating to
the life cycle  of the product" (ISO/SAGE 1993).

       The ISO Technical Committee, Environmental Management, established by ISO in
early 1993, includes a Subcommittee on Environmental Labelling  that will develop
appropriate standards in the environmental labelling field. Among the recommended

activities for the Secretariat of the Subcommittee, which is the organization Standards
Australia, is to develop a database of environmental labelling criteria for product
categories that have been adopted by the different environmental labelling programs
worldwide (ISO/SAGE 1993).
2.2    Description of Environmental Labelling Program Methodologies

2.2.1  European Communities Eco-Labelling Program      General Procedure

       The EC Eco-labelling program operates through official environmental labelling
bodies in the member states and an approval process by the EC Commission, the
governing political body of the EC. Proposals for product categories and criteria are
made by member states to the Commission, which engages in consultation with a
Consultation Forum of interest groups in choosing categories. A category is assigned to
the participating  Competent Body in  a member state, which drafts criteria for
certification. The draft criteria are sent back to the Commission, which consults with the
Consultation Forum, and then sends  them to the Committee of Member States  for
approval. If approved, they are adopted by the Commission.(UK Ecolabelling Board
1993a; US EPA  1993a).

       The EC Program began in  1992 by assigning member countries five different
classes of products for development  of labelling criteria.  Additional product classes have
been assigned since that time. Following are products and the countries assigned (UK
Ecolabelling Board  1993a):

       washing machines (UK)
       paints and varnishes (France)
       copy paper and paper towels  (Denmark)
       packaging (Italy)
       laundry detergents (Germany)
       hair spray (UK)
       soil improvers (UK)
       light bulbs (UK)
       dishwashers (UK)
       domestic  batteries (France)
       solar heating systems (Germany)
       insulation material (Denmark)
       toilet paper (Denmark)
       writing paper (Denmark)
       refrigerators (Italy)
       ceramic tiles (Italy)

       cat litter (Netherlands)
       shoes (Netherlands)
       dishwasher detergents (Germany)
       household cleaning products (Germany)
       shampoos (France)
       antiperspirants/deodorants (UK)
       female sanitary products (UK)
       hairstyling aids (UK)
       bed linen (Denmark)
       tee shirts (Denmark)

       The launch for the EC scheme was planned for June 1993. As of February 1993,
 however, six member states of the EC had failed to designate competent bodies to
 administer the scheme. Two product groups, washing machines and dishwashers, have
 had criteria accepted by the European Environment Committee, and it is anticipated that
 four others (hair sprays, paper towels, toilet paper, and light bulbs) will be ready in time
 for the launch (Whitehead 1993).      Procedures for Setting Criteria with Examples

       The development of proposed labelling  criteria by the six countries that have done
 so has resulted  in different methodologies for fulfilling the "cradle-to-grave" requirement
 of the EC regulation. The EC is considering the appointment of an LCA expert to advise
 the Eco-Labelling scheme on the application of LCA to ecolabelling (Udo de Haes

       Following is a discussion of the approaches that have been used by the EC
 countries contributing proposed standards to the EC Eco-Labelling scheme.

       UK Ecolabelling Board "Streamlined LCA"

       The UK Eco-Labelling Board, which is operating in the EC program, performs
 what is called a "streamlined LCA". Consultants have been contracted to perform each of
 the streamlined  LCAs that have been used by the UK Board for developing labelling
 criteria, including consultants with experience in LCA (e.g., PA Consulting Group,
 Chem Systems,  Ltd.)

       Representative products from the product class are chosen and an evaluation of the
life cycle is performed. The purpose of this evaluation is not to compare the products  in
detail or to draw conclusions about the specific products chosen, but to identify those
aspects of the life cycle of the products that have the most significant environmental
impacts (PA Consulting 1992; UK Ecolabelling Board  1993c).

       The "streamlined LCA"  methodology does not attempt to quantify every input and

output from every stage of the life cycle, but instead incorporates a screening step in
which the "impacts" from certain stages of the life cycle are estimated or ignored based
upon information obtained and judgment by the study practitioner. For instance, in the
washing machine evaluation, the environmental impacts of extraction of raw materials for
production of washing machines was deemed to be minor and too difficult to quantify,
although the consumption of raw materials in manufacturing was considered as a measure
of environmental impact (PA Consulting 1992).

       In the washing machine LCA environmental releases during the production of
materials, such as steel and plastics, were quantified using existing LCA models and
databases, and an estimate was made for the actual manufacturing of the washing machine
as a percentage of the total materials production impacts. Estimates were made for other
stages of the life cycle using existing life cycle inventories adjusted for European
machines and European impact analysis methods.  The study determined that the use of
washing machines contributes the vast majority of environmental impacts as compared to
the other stages of the life cycle,  and the resulting labelling criteria focussed on energy
consumption, water consumption, and detergent consumption during use (PA Consulting

       In the "streamlined LCA" for hairsprays, two "typical" product formulations were
selected from the product class (aerosol with ethanol solvent, butane propellant, tinplate
steel can;  pump with ethanol plus water and HDPE bottle) and a quantitative life cycle
inventory was performed using a combination of manufacturer supplied data, in-house
data, and published databases. "Minor"  material uses, defined as those under 5 percent of
total feedstocks to a process step, were excluded from the evaluation. Impact analysis  was
performed by aggregating inventory results into impact categories and using the critical
volume approach to scale and aggregate toxic pollutants (UK Ecolabelling Board 1993c).
The critical volume approach divides specific pollutant releases (in mass units) by
established regulatory standards for the specific pollutant (in mass/volume of air or
water). This results in a volume of air or water polluted at the regulatory standard and
allows aggregation of these critical volumes across different types of pollutants.

       Based upon the inventory and impact analysis, the criteria recommended for
hairsprays were for minimization of VOC content, while precluding ingredients that
deplete stratospheric ozone and limiting significant increases in constituents that
contribute to global warming. Criteria for packaging emphasized maximum container
weight per dose and minimum recyclability of the container (UK Ecolabelling Board

       A "streamlined LCA" was also performed  for the development of criteria for light
bulbs. The consultant first determined through quantitative life cycle inventory with
impact analysis, using existing databases, that fluorescent bulbs, being more energy
efficient during use, were preferable to incandescent bulbs.  Then a more detailed
evaluation of the  life cycle of fluorescent bulbs was performed to identify further

opportunities to improve the environmental performance of fluorescent bulbs. The
resulting recommended criteria include an energy efficiency criteria that eliminates the
current incandescent from consideration, limitations on heavy metal content and
radioactivity, and criteria for recycled content of packaging (UK Ecolabelling Board

       Danish "Quantitative and Qualitative" Life Cycle Assessment

       The Danish Environmental Protection Agency is the participating body from
Denmark in the EC Ecolabelling scheme. Denmark has been designated the lead country
on thermal insulation materials, paper products, and textile products. The Danish EPA
has contracted with consultants to perform the environmental evaluations of these classes
of products (Jensen 1993).

       The "cradle-to-grave" methodology used by the Danish in evaluating paper
products, the first group  of products evaluated, could also be described as a streamlined
LCA, since it focusses on particular stages of the life cycle. In addition, it does not rely
exclusively on quantitative data, but also makes use of qualitative information on
environmental impacts (Danish EPA 1991). For subsequent groups of products, a more
complete life cycle inventory is being performed. Based upon the inventory, key features
of the life cycle are selected for more in-depth impact assessment and the development of
criteria for labelling. The purpose is still to identify the most significant stages  of the life
cycle and the most significant impacts for development of criteria (Jensen  1993).

       The Danish methodology differs from others in its inclusion of the concept of
"hurdles" and "points" in the recommended criteria for labelling. "Hurdles" are specific
criteria that must be met for the award of a label, such as compliance by the
manufacturing facility with all applicable EC environmental regulations. The "point"
system assigns scores to  certain environmental attributes of the life cycle of a product,
such as the level of water pollution  or the amount of energy used throughout the life
cycle, and sets a maximum total number of points as a criterion for labelling (Danish
EPA 1991). In principle, such a point system would give manufacturers flexibility to
balance materials and manufacturing processes in the different stages of the life cycle to
meet the overall performance standard. It may be difficult to implement such a
performance-based standard, however,  and  the concept has not yet been adopted by the
EC Eco-label Program.

       The concept has recently been refined to include a weighting of the various
parameters (e.g.,  emissions of SO2 or use of non-renewable resources) by both a
"Production Improvement/Impact" weighting and a "concern factor" weighting. The
"Production Improvement/Impact  (P/I)" factor is the relative importance of moving the
particular industry from the "worst" to the "best" in relation to the total impact of the
particular parameter. The P/I factor for paper products, for instance, for a particular
pollutant "X", is defined as the difference in emissions of X in the "worst" (i.e. dirtiest)

mills as compared to the emissions of X in the "best" (i.e. cleanest) mills divided by the
total emissions of X from all sources, globally or regionally. The P/I factors are
calculated for each parameter and ranked in orders of magnitude with the highest P/I
being ranked "large" and lower orders of magnitude ranked "medium",  "small", and
"non-significant". The "concern factor" is a subjective ranking of the importance of the
particular parameter in four steps:  "large, medium,  small, and non-significant" (dk-
Teknik 1992).

       The overall weight factor to be applied to the "load points" for each parameter is
a combination of the P/I and the concern factor rankings, so that a large P/I and a large
concern factor will give an overall weight factor of 3, and a small P/I and a small
concern factor will give an overall weight factor of 0.03. Non-significant in either
category will yield a weight factor of 0 (dk-Teknik  1992).

       The Danish approach also differentiates between impacts that are considered
global or regional versus those that are considered local. Local impacts  are sometimes not
considered in  the eco-labelling criteria, since it is assumed that the purpose of the eco-
labelling program is to deal with global and regional impacts and  that regulations will
take care of local impacts.  For instance, in the proposed paper criteria,  discharges to
water of biological oxygen demand (BOD) and total suspended solids are deemed local
impacts and not considered, while discharges of chemical oxygen  demand (COD) and
chlorinated organics are considered global or regional impacts and are included in the
criteria setting (dk-Teknik 1992).

       A recent draft by the Danish consultant working with the Danish EPA on
ecolabelling criteria for thermal insulation materials adopts the points and hurdle system
and separates  impacts into categories of resource consumption, global, regional,  and
local, including occupational exposure, indoor air pollution, and fire behavior. A life
cycle inventory was performed by another consultant for representative insulation
materials, and the results were evaluated  using a form of impact assessment. Labelling
criteria, developed through application of a point system, are proposed for the use of
fossil fuels per unit of product, for percentage of recycled material, for global warming
potential of emissions per unit of product, for ozone depletion potential  of emissions per
unit of product,  for SO2 emissions per unit of product, and for VOC emissions per unit of
product.  Weighting factors were then applied to  the points, with global warming
pollutants and SO2 emissions being weighted less than fossil fuel use, emissions of VOCs
and emissions of ozone depleting chemicals. Hurdles are proposed by the Danish
consultant for the use of chlorinated organics and heavy metals as flame retardants, for
occupational exposures to man-made mineral fibers, styrene, phenol, methylene diphenyl
diisocyanate, boron, organic dust and cellulose, and for both occupational exposures and
indoor air exposures to formaldehyde (dk-Teknik 1993).

       The points system allows there  to be one set of criteria for products made up of
very different materials,  instead of simply selecting  preferred materials.  The goal is to

create an incentive to improve the environmental attributes of all insulation materials
during the whole life cycle (Jensen 1993).

       French "Ecobalance"

       The French have developed draft criteria for labelling paints and varnishes in the
EC program and are also developing criteria for shampoos and batteries. The French
have a national environmental labelling program, called the NF Environment Mark
(described below), that operates separately from the EC program. Both the EC
participation and the NF Environment Mark are managed by the Association Franc.aise de
Normalisation (AFNOR), the French standards organization, with participation and
funding by French governmental agencies (French Ministry of the Environment 1993).

       The approach used by the French program, both in the EC Eco-labelling scheme
and in the national program (since June 1992), includes the use of life cycle inventories
for every  product category for which labelling criteria are developed. The French use the
term "ecobalances" for these life cycle inventories.

       LCI is used in the French labelling programs in a five-step procedure:

       1.      A market and product survey is performed for the product group in
       2.      Products are selected that are representative of the market and of
              environmental issues for the product group in question.
       3.      Life cycle inventories are conducted for the representative products.
       4.      The results of the life cycle inventories are evaluated in order to identify
              the main environmental issues associated with the products throughout their
              life cycles.
       5.      A discussion is held in a representative group of experts concerning the
              product group to draft the labelling criteria taking into account: the main
              environmental issues identified in the LCI; the available technologies for
              alleviating those main environmental problems; and the economic
              feasibility of meeting labelling criteria.

       The evaluation of paints and varnishes was performed by  the consulting firm
Ecobilan under contract with the French Ministry of the Environment. Ecobilan
performed a life cycle inventory for eleven representative products in the paints and
varnishes category (Ventere 1993). A functional unit was chosen for the paint products,
and data was gathered from the actual manufacturers on the resource inputs,
environmental releases and energy use for most ingredients. The data was  aggregated to
insure confidentiality (Ecobilan 1992). Funding for this first life cycle  labelling effort was
provided by the public authorities, including the French Ministry of the Environment, the
Ministry of Industry, the Ministry of Consumer Affairs, and the Agency for Environment
and Energy Conservation (ADEME) (Ventere  1993).

      The life cycle inventories developed by Ecobilan were used to:

•     determine inputs and outputs in different stages of the system;
•     define the relative contribution of each stage and of each input and output to
      different impacts  (global warming, ozone depletion, depletion of natural
      resources); and
•     evaluate the contribution of the product system to the overall impacts considered
      (e.g., total releases of greenhouse gases)  (Ecobilan 1992).

      The representative group formed by AFNOR to develop criteria from the
inventory results included manufacturers, consumer organizations, environmental
organizations,  retailers, and three government agencies (Ministries of Environment,
Industry, and Consumer Affairs). The representative group attempts to develop a
consensus,  first on the most important environmental impacts to be addressed in the
labelling criteria, and second on the criteria to address those impacts. The draft criteria
for paints and  coatings are still under discussion within the EC, where they are being
evaluated by an EC-wide representative committee of over 40 experts (Ventere 1993).

      The French program has also sponsored ecobalances for shampoo products for the
EC program, but in this case, the manufacturers of shampoos shared the approximately
$170,000 cost of the LCI studies with the government agencies (Ventere 1993).
2.2.2  German "Blue Angel" Program       General Procedures

       The German environmental labelling program, that has become known as the
"Blue Angel" Program,  has been in  operation since 1978. The decision-making process
for establishing criteria for environmental labelling is a joint effort of the German Federal
Ministry of the Environment, including the Federal Environmental Agency, the German
Institute for Quality Control and Labelling, and a representative Environmental Labelling
Jury. Although the government is involved in the process, the Environmental Labelling
Jury and the Institute for Quality Control,  which make decisions on criteria and
administer the program, are non-governmental (German Ministry for Environment 1990).

       The Federal Environmental Agency provides the initial scientific review of the
product category and drafts the labelling criteria.  Then, the Institute for Quality Control
and Labelling convenes  expert hearings to discuss the criteria proposed by the
Environmental Agency.  The representative Environmental Labelling Jury, which has
members from industry, environmental organizations, consumer associations, trade
unions, environmental professional associations, and the federal states,  makes the final
decisions on criteria for product categories based upon the proposal by the Environmental
Agency and the comments in the expert hearings  (German Ministry for Environment

Procedures for Setting Criteria
       The Blue Angel Program has issued more than 75 sets of labelling criteria, many
of which focus on a limited number of attributes of the product class. The Program
states, however, that it has always considered the life cycle of the product in establishing
criteria, usually by the use of a simple qualitative matrix of environmental impacts in
each of the life cycle stages. The criteria that are ultimately developed are oriented
toward the "state-of-the-art" technology and are intended to create significant
environmental benefits as compared to the generally used technologies (Neitzel 1992a).
The "life cycle" matrix that is used is presented in Table 2 below.

         Table 2: "Life  Cycle" Matrix Used by German Program (OECD 1991)

Hazardous Substances
Waste Minimization
Resource Conservation
Fitness for Use



       In the further development of the Blue Angel Program a more detailed life cycle
evaluation is now used for development of criteria for certain products, especially where
there is a need for quantitative data for determining  impacts of competing ingredients or
materials. For instance, the Program is doing a quantitative LCI for evaluating laundry
detergents and hand drying systems (e.g.,  electric dryers versus cloth towels). A
screening approach is still used for products that present fairly clear pictures of
environmental benefits that result from relatively simple criteria (e.g. recycled paper)
(Neitzel 1992b).

       The current procedure has been described as  stepwise, first using the checklist or
matrix approach to identify important parts of the life cycle and the most significant
environmental attributes of the product class. This is supplemented by the use of expert

panels. If there is insufficient information to develop criteria from this screening
approach, an LCA will be done or an existing LCA will be relied upon. As an example,
the Program utilized an existing LCA on hand drying systems and determined that there
were no significant environmental differences among the various options. Therefore,
criteria were set to improve the environmental attributes of each option (Neitzel 1992b).

       Most of the Blue Angel standards do not deal directly with the production process,
and the Blue Angel is one of the few programs that does not require producers to
demonstrate that they meet national environmental standards in the production process.
Two reasons are given for this omission: (1) analytic methods are frequently unavailable
to separate the impacts of the product being considered from the whole manufacturing
facility's impacts;  and (2) such manufacturing standards would penalize countries with
less stringent environmental standards and may constitute a trade barrier contrary to
GATT regulations (Neitzel 1993).

       When a quantitative LCA is done in the German Program, it is for the purpose of
defining the scope of the product category and for identifying the stages of the life cycle
and the most significant environmental impacts for development of product criteria. The
product criteria are then developed through expert judgment and a consensus-building
process with the use of the Environmental Labelling Jury and expert hearings. There has
been no attempt to create a direct connection between LCA and the criteria for labelling
(Neitzel 1993).
       The Federal Environmental Agency has performed a "stepwise" life cycle
assessment to aid in the development of the criteria for laundry detergents. The three
steps in the process are as follows:

•     Screening Step: an evaluation matrix/check list approach is used in a qualitative
       analysis to attempt to identify the most significant stage(s) of the life cycle.
       Available data is used to assess the impacts of the priority life cycle stage(s).
       Criteria can be developed for reducing the impacts in the priority stage(s).
•     Refined Step: this is a confirmatory step for the priority life cycle stage(s) with
       collection of missing data and further quantification of inputs and outputs and their
       impacts. Criteria can be revised and updated for the priority stage(s).
•     Detailed Step: this is a full, quantitative life cycle assessment, including some
       form of impact assessment. Additional stages  of the life cycle are considered as
       are additional, more global impacts, such as global warming and resource
       depletion. Such an assessment may be necessary to set criteria  that prefer certain
       raw materials, processes, or disposal processes. (Poremski 1991).

       In applying this approach to laundry detergents, the Federal Environmental
Agency first performed an evaluation matrix qualitative approach and a screening LCA

 for the energy consumption and water pollution for the surfactant component of
 detergents. In the screening LCA three life cycle stages were determined to be the most
 significant for energy use: surfactant production, raw materials production, and use in the
 washing machine. For water pollution, the use stage was determined to be the  most
 significant (Poremski 1991).

       The Agency recommended that labelling criteria could be set based upon the
 screening LCA and that a refined step and detailed step could follow to revise the criteria
 later. Criteria recommended included the use of a component system (detergent, bleach,
 and water softener as separate components) so that only ingredients that are needed are
 actually used; a limit on the dosage per load; exclusions of certain compounds  that can
 cause water pollution impacts, such as phosphates; biodegradability requirements; aquatic
 toxicity limits; and packaging recycled content requirements  (Poremski 1991).
 2.2.3  French National Environmental Labelling Program       General Procedures

       The French standards organization Association Franc.aise de Normalisation
 (AFNOR) is the secretariat for the French environmental labelling program (NF
 Environnement Mark), which was launched in June 1992. This program is a national,
 voluntary, seal-of-approval labelling program, which has chosen to develop French
 standards in addition to the French participation in the EC program (French Ministry of
 the Environment 1993).

       AFNOR is the convener of a Labelling Committee for each of the product groups
 being considered. This representative Committee includes the manufacturers of the
 products in the groups (particularly  those companies whose products are selected as
 representative products for life cycle studies), retailers, consumer and environmental
 organizations, and the French Ministries of Environment, Consumer Affairs, and
 Industry.  The labelling criteria are developed in a consensus  process by these
 Committees, an open meeting is held to discuss the draft criteria, and the final criteria
 are submitted to the three Ministries for final approval.
Procedures for Setting Criteria
       Since June 1992, the NF-Environnement has decided to perform a life cycle
inventory (called "ecobalance" in France) for each product category for which labelling
criteria are being developed (Proia 1993; Ventere 1993). The program began by using the
life cycle matrix approach (similar to the German program) for the development of
criteria for labelling, then suspended work in June 1992 to develop a new methodology
which involves the use of quantitative life cycle inventories. The life cycle inventory is
performed using industry data from actual companies for representative products in the

product category being considered (Heintz 1992). The five-step process discussed in
Section, above, under the EC Eco-labelling Program, is used to develop labelling
criteria from the inventory results.

       AFNOR is also working on a methodological framework for "public oriented"
LCA, as compared to internal use of LCA. The framework is intended to define ethical
rules for conducting LCAs for public decisions, like ecolabelling, including the manner in
which LCA results are communicated (French Ministry of Environment 1993).
       The only NF-Environnement labelling criteria published to date is for paints and
coatings, which was developed without the full use of the LCI process that is now being
used. The program  has completed LCIs for trash bags and is in the process of developing
the criteria in the representative Committee.  The LCI studies performed looked at seven
representative products, and the seven companies whose products were being evaluated
participated with the French Ministries in financing the  studies. The seven studies cost
approximately $96,000. These seven companies have also participated on the
representative Labelling Committee developing the labelling criteria (Ventere 1993).
2.2.4  Dutch Ecolabel Program       General Procedures

       The Dutch ecolabelling program was started in 1992 to be the implementing
organization for the EC Eco-label and to operate a separate national program in the
Netherlands. The program is administered by Stichting Milieukeur, a non-profit
foundation independent of the government. The program is financed initially by the
Ministry of Housing,  Physical Planning and the Environment and the Ministry of
Economic Affairs but is expected to become financially independent in five years
(Stichting Milieukeur  1993).

       Criteria for labelling are set by a Board of Experts  representing different segments
of society, including consumer groups, environmental groups, manufacturers, the
government, and retailers. A consultant first performs an environmental evaluation of the
product class and recommends criteria for labelling to the Board of Experts. The Board
of Experts then reviews the evaluation and recommendations and develops consensus
criteria from them (Verhees 1993a). Before criteria are finalized there is an opportunity
for comments  from the public and  a public hearing (Wijnen 1993).

Procedures for Setting Criteria
       In the Dutch program the research to support development of criteria for labelling
 is performed by consultants who make use, to the extent possible, of existing life cycle
 assessment studies dealing with the class of products. The program, however,  does not
 require a full, quantitative LCA for every product category, but seeks to ensure that a
 "cradle-to-grave" approach has been pursued (Giezeman 1993).

       The program, therefore, does not depend on the development of the perfect LCA
 methodology, but uses the available information to develop product criteria with expert
judgment. The program recognizes that an LCA does not automatically  make the choices
 of the greatest opportunities for environmental improvements in product classes that have
 to ultimately be made by the Board of Experts based on the available information
 (Giezeman 1993).

       The first step is the selection of a product group, which is a group of products
 that, according to the consumer, have the same practical purpose and belong to the same
 market sector. An environmental label can only be set up  for a product  group in which
products differ in degrees of environmental impacts (Giezeman 1993).

       The core of the life cycle evaluation that is performed  by the consultant is a
matrix of 6 life cycle stages and 25 environmental aspects that must be considered.
Research is divided into two parts. In the first part, as much quantitative information as
possible is generated on the environmental impacts in each stage and each impact
category, and the most important environmental aspects of the product group are selected
based upon this information. This is done on the basis of a defined functional unit, so that
different products in the class can be evaluated in the same framework (Giezeman 1993).

       The consultant relies as much as possible upon existing studies. If a cell from the
matrix cannot be filled in quantitatively, the approach is to consider the  matter
qualitatively (Giezeman 1993). If insufficient information exists overall,  then the
development of product criteria for that class of products is deferred (Verhees  1993a). A
complete LCI is not required in order to fill in the matrix. A less detailed approach can
be used because the purpose is not to compare every aspect of two or more actual
products, but to select the most important environmental aspects for development of
product criteria (Giezeman 1993).

       After the inventory, those cells are selected that provide the greatest
environmental benefit. The point is to determine whether a product, as a whole, causes
significantly less environmental damage. This does not mean that the product has to score
more favorably in every stage and with regard  to every environmental impact (Giezeman

       In the second part of the study the criteria for labelling and the methods of

 measuring compliance with the criteria are formulated. In this stage the product
 performance is also considered to determine whether functional requirements have an
 impact on the environmental attributes and to insure that inferior products are not
 awarded the label. In this stage, the following considerations are used to formulate
       the environmental requirements aim at the largest possible reduction of
       environmental damage;
       the environmental requirements are within the reach of manufacturers;
       the environmental requirements are higher than those of statutory requirements;
       at least one product or brand for sale has to be able to meet the requirements
       within the foreseeable future;
       functional quality has to be sufficient; and
       it is possible to set requirements for labelling information and packaging
       (Giezeman 1993).
       As of August 1993, the Dutch program has criteria for the following products:
light bulbs,  shower heads, writing paper, paints, and coffee makers (Verhees 1993b). The
light bulb criteria illustrate the way in which the methodology functions. The
environmental evaluation indicated that the most significant opportunities for
environmental improvements were the energy use during use of the lamps, the heavy
metal and radioisotope content of the lamps that could be released through incineration or
disposal, and the useful life of the lamps, which influences material use in manufacturing
as well as volume of solid waste for disposal. Criteria for labelling focussed on energy
use per lumen of illumination and on heavy metal and radioisotope concentrations, with
label information provided to encourage consumers to dispose of the lamps in the Dutch
collection system for small quantity hazardous waste (Giezeman 1993).
2.2.5  Nordic Council "White Swan" Program       General Procedures

       The Nordic Council Ecolabelling program is a joint program of Sweden, Finland,
Norway, and Iceland, founded in 1989. Just as in the EC program, lead countries take
responsibility for certain product groups.  Within each country an organization is set up to
administer the program. In Sweden and Finland the program is administered through the
standards-setting institutes, with an Environmental Labelling Board established to provide
representative decision-making from different interested sectors of society (consumer and
environmental organizations, government, businesses, and research institutes); in Norway
through a special Foundation for Environmental Product Labelling, also with a
representative board; and in Iceland through the Ministry of the Environment (Nordic

Council 1991).
Procedures for Setting Product Criteria
       The criteria for products in the Nordic program are established based upon an
evaluation of the life cycle of the product class, including production, use, and disposal
stages, and take into account factors such as consumption of natural resources and
energy, emissions  to air, water, and soil, and generation of waste and noise (Nordic
Council 1991). In  principle, this entails an assessment of the whole life cycle. In practice,
product criteria are set in a pragmatic fashion for those  stages of the life cycle and
environmental impacts that are deemed through expert judgment to be the most
significant. Where insufficient information exists to set criteria for certain stages of the
life cycle, then no criteria are set for that stage, but other stages are  still addressed.

       The Swedish Standards Institute refers to the evaluation as a "life cycle review"
(Assarsson 1993a). Some of the earlier product evaluations reviewed leave out whole
stages of the life cycle where, in the judgment of the evaluator, the life cycle stage does
not contribute significantly to overall environmental impacts or is not significantly
different for different products within the product group. Some of the evaluations also
leave out certain environmental parameters,  such as energy use, where sufficient
information is not available to form conclusions. Quantitative information is obtained for
the environmental impacts within the life cycle stages that are deemed to be the most
significant. Since no detailed elaboration of the methodology used was available,
descriptions of examples are used to illustrate the approach.
Fine Papers for Printing, Writing, and Copying

       The environmental evaluation of fine papers and the resulting criteria for labelling
focussed principally on the emissions and use of chemicals during manufacturing. The
evaluation excluded energy use in the life cycle due to the difficulties and expense of
performing the detailed evaluation necessary. The evaluation also excluded consideration
of the impacts of producing the chemicals used in the production of paper. Nor did the
evaluation attempt to compare the environmental  attributes of recycled fiber versus virgin
fiber. Instead, fine paper from virgin fiber is accepted provided that it meets the criteria
for emissions and chemical use and can be recycled. On the other hand, tissue paper,
which cannot be recycled, must be produced from recycled fiber to meet the criteria for
labelling (Norwegian Foundation 1991; Assarsson 1993b).

       The criteria for labelling include the following:

•     restrictions on the chemicals that can be used in manufacturing, including
       restrictions on solvents used to clean equipment and on surfactants used for

      deinking recycled fiber;
•     a limit on the combination of total organic halogens (AOX) and COD water
      discharges and sulphur air and water emissions per ton of paper; and
•     a prohibition on the use of chlorine to bleach recycled fiber (Norwegian
      Foundation 1991).

Marine Engines

      The evaluation of marine engines appears to have been more comprehensive. It
looked at the pollution, material consumption, and energy consumption during the
manufacturing stage and evaluated the emissions during use. The evaluation found no
significant differences in the manufacturing processes of different engines that could be
used to  set criteria for labelling.  The resulting criteria for labelling focussed on limits on
emissions during use, on extending the life of the engines, and on provisions  for
recycling the engines after use (Norwegian Foundation 1992).


      The life cycle review for dishwashers appears to have been performed principally
in qualitative fashion, with an approximate calculation of energy use during the different
life cycle stages. The review identified the following as the most significant
environmental impacts throughout the  life cycle:

•     energy consumption during use;
•     consumption of detergent, water, and rinsing agent during use
•     noise from use;
•     emissions of solvents and heavy metals from surface coating in manufacturing;
•     disposal of dishwashers at the end of their useful life.

       The resulting criteria focussed  on detergent use, water use, and energy use, but
also included a requirement that plastic parts be coated with solvent-free methods, that
plastic parts be identified as to type of plastic to make recycling easier, and that transport
packaging  contain no products for which CFCs  were used in the manufacturing (SIS
 2.2.6  Austrian Program       General Procedures

       The Austrian Eco Label Program was created in  1991. The Eco Label is awarded
 by the Minister for Environment, Youth and Family for a period of validity of two years
 (Wendler 1993). Four groups are involved in the process of developing and approving

 product labelling criteria: the Federal Environmental Agency suggests product categories
 for labelling; the Austrian Consumer Organization, a non-profit, non-governmental
 organization, works out criteria with experts and representative groups; a representative
 Eco Label Committee makes recommendations on criteria; and the final decision on
 labelling criteria is made by the Ministry for Environment, Youth and Family. The
 Austrian Quality Certifying Institute administers the application and label contract process
 (Wendler 1993, Reuter 1992).

       The representative Eco Label Committee, which meets twice a year, is composed
 of representatives of industry, the Ministry of Economic Affairs, consumer organizations,
 government procurement offices, environmental organizations, the Austrian Institute for
 Standardization, the Austrian states, scientific organizations, the Ministry for
 Environment,  Youth and Family, the Federal Environmental Agency, the Working Panel
 on Product Quality, and the Austrian Consumer Organization (Wendler 1993). Labelling
 criteria have been established for the following product categories:

              refrigerators and appliances for cooling
              sanitary paper
              fine paper
              exercise books
              washing machines
              wooden furniture
              filing systems
              sealing varnishes
              water-saving toilets made of non-PVC plastics
              electronic control systems for sanitary installations
              reprocessing of toner-modules, ribbon cassettes and ink-cartridges
Procedures for Setting Criteria
       The Austrian Program has decided that a quantitative life cycle assessment is not
necessary for setting criteria for all products, although the life cycle is considered in the
criteria development. Where certain product improvements have clear environmental
advantages, criteria are developed without the use of LCA. LCAs are being performed
for some product categories, including baby diapers and insulating materials. The Federal
Ministry of the Environment has provided funding for the diaper LCA through the
Consumer Organization (Reuter 1992).

2.2.7  Canadian Environmental Choice Program
General Procedures
       The Canadian Environmental Choice Program has been operating since 1988 with
labelled products first appearing on the shelf in 1990. The Environmental Choice
Program is a government-based program located in, funded by, and indemnified by
Environment Canada, the federal environmental agency of Canada (OECD  1991).

       An independent representative Board originally managed the Program and made
preliminary decisions on product criteria for labelling that were adopted by the Minister
of the Environment.  Since a change in the process in June 1992, the Board serves as
more of an advisory  body to the Minister of the Environment than as a management
group. Members include representatives of environmental, manufacturing, retailing, and
consumer groups.

       The technical evaluation and development of labelling criteria was originally
performed by the Canadian Standards Association (CSA) under contract with the
Program. CSA is an independent standards-setting organization and is the Canadian
member body of the International Standards Organization. CSA is serving as the
Secretariat  of the new ISO Technical Committee on Environmental Management recently
created to set standards for environ menial management tools,  including life cycle
assessment and environmental labelling. Following the change in structure of the
program, CSA is no longer directly involved and criteria are now developed by
Environmental  Choice  staff and consultants working with product category review
committees composed of representatives from affected manufacturers and environmental
and consumer groups (Douglas 1993; Novak 1993).

       Anyone may propose a product category for labelling. The Environmental Choice
staff reviews all proposed categories, assesses their potential market impacts based on
market/environmental impact analysis, and recommends those with the greatest potential
impacts to  the Board. The Board reviews the information from the staff and may accept
or reject recommended categories or request more technical information (Novak 1993).

       If the Board accepts a product category the Environmental Choice Program
employes a consultant to prepare a "briefing note", which assesses the environmental,
technical, market, and  economic considerations associated with the product category. The
environmental part of this assessment is called a "life cycle review"  by the Program
(Douglas 1993; Novak 1993).

       With input from this briefing note and other sources, the Board determines
whether to proceed to the development of draft criteria. The drafting of the criteria is
done by the specially convened review committees working with the Program  staff
(Novak 1993).

       The Board considers the draft criteria and may accept them, suggest revisions, or
 send them back for further work. If the Board accepts the draft criteria, an announcement
 that they are available for public review and comment is published and the criteria are
 circulated to interested parties for a 60-day public comment period. After the comments
 are reviewed, the Program staff may make amendments before presenting them to the
 Board for approval.  When the Board approves the criteria, they receive a final review by
 the Minister of the Environment, who then promulgates them as final and publishes an
 approval announcement in the official government administrative journal (Novak 1993).
Procedures for Setting Criteria
       The "life cycle review" in the briefing note performed by the consultant and the
 Program staff forms the basis for the setting of criteria for labelling. It is not a formal
 quantitative life cycle assessment, but seeks through a qualitative and quantitative review
 of each stage of the life cycle to identify the most significant environmental impacts of
 the product for the development of criteria (Douglas  1993).

       There are three guiding principals for labelling criteria:

 •     Long-term environmental issues are given precedence, instead of short-term issues
       that are likely to be addressed through regulations.
 •     The entire life cycle of the product should be  considered,  although the criteria
       developed will not necessarily address all of the product's environmental aspects.
 •     The criteria set should promote industry leadership by identifying and certifying
       existing environmentally superior products (Novak 1993).

       The "life cycle review" portion of the briefing notes are relatively short, mostly
 qualitative reviews of the most significant environmental "issues" associated with each of
 the life cycle stages. They consider for both product and packaging the manufacturing
 impacts, the use impacts, and disposal impacts. For each stage, there is a consideration of
 resource and energy use, chemical and biophysical impacts, and occupational health and
 safety. The determination of the significance of particular environmental issues is based
 upon the judgment of the consultant performing the review (Marbek 1991).
Laundry Detergents

       The Environmental Choice criteria for laundry detergents was adopted in
December 1993 after over two years of evaluation and discussion (Environmental Choice
Canada 1993). The original Briefing Note was prepared by a consultant, who identified
principal ingredients, profiled the market, and qualitatively assessed the environmental
parameters of each stage of the life cycle of the principal ingredients (Environmental
Choice Canada 1991). Stages of the life cycle and environmental impacts within those

stages that were addressed are listed below:

  •    Resource Issues

       Feedstocks (renewability, energy consumption, environmental burdens)
       Packaging (solid waste disposal, heavy metals content, concentration of product)

  •    Manufacturing

       Environmental impacts (water pollution, air pollution)

  •    Use of Product

       Energy Consumption (efficacy at lower temperatures)
       Environmental impacts (biodegradability, eutrophication, aquatic toxicity, human
       health effects)

The Briefing Note also addressed socio-economic issues, including product efficacy and
impacts on manufacturing, markets, and employment.

       The Briefing Note recommended that Environmental Choice consider the
following labelling criteria:

       use of renewable resource feedstocks
       complete biodegradability within a given period
       minimal nutrient contribution to algal plant growth (eutrophication)
       good ecotoxicological profile
       no unacceptable human health impacts
       concentrated formulation
       good performance in cooler washwater temperatures
       low impact packaging (e.g., minimal materials, recycled materials, reusable,
       recyclable) (Environmental Choice Canada 1991).

       Draft labelling criteria were developed based upon the Briefing Note and
circulated for public comment. Discussions were also held with representatives  of
detergent manufacturers and with the environmental community. These draft criteria
included a list of acceptable and unacceptable ingredients, a limit on phosphorous and
nitrogen builders, limits on heavy metal content, biodegradation criteria, aquatic toxicity
criteria, bioaccumulation limits, and a packaging reduction requirement (Duffy  1992).
The comments on the draft criteria were evaluated by a consultant and an options paper
was prepared for the Environmental Choice Program (Duffy 1992).

       After additional input from manufacturers and the public, final criteria were
adopted that have the following main attributes:

        Choice to either demonstrate that ingredients meet "environmental protection
        factor tests" or are on a list of "acceptable ingredients". The environmental
        protection factor tests include acute and sub-chronic aquatic toxicity and
        Prohibition on ingredients that are designated as carcinogens.
        Biodegradation requirements.
        Prohibition on EDTA.
        Packaging criteria, which include a weight/dose limit to reduce packaging by
        approximately 50%, recycled  content requirements, and heavy metal limits.
        Performance requirements for performance at two temperatures, one of which
        corresponds to heated water. (Environmental Choice Canada 1993).
 2.2.8  Green Seal
General Procedures
       Green Seal is an independent, non-profit environmental labelling program
operating in the United States. Green Seal makes all decisions on criteria for labelling
internally after soliciting input from affected industry groups, environmental
organizations, government agencies, consumer groups, and other interested members of
the public. Green Seal was formed by environmental and consumer organizations and is
overseen by a Board of Directors that includes the directors of several of these

       Criteria for labelling are developed by  Green Seal through a technical evaluation
of the product category that may be conducted by Green Seal staff or by outside
consultants. Draft criteria are circulated for  comment, and final criteria are developed
after careful review  of the comments received. A document responding to and discussing
substantive comments on the draft criteria is also  prepared at the same time that the final
criteria are prepared. The testing of products and the monitoring of compliance with
certification standards for those products and manufacturers that apply for and receive the
Green Seal is performed generally by Underwriters Laboratories, Inc. under contract with
Green Seal (Green Seal 1992a).
Procedures for Setting Criteria
       Green Seal has not performed quantitative life cycle assessments in the
development of product labelling criteria, but has used an "environmental impact
evaluation", which attempts to identify the most significant environmental impacts in each
stage of the product's life cycle. The intent is to "reduce to the extent technologically and
economically feasible, the environmental impacts associated with the manufacture, use,
and disposal of products" (Green Seal 1992c).  Although Green Seal has attempted to
utilize formal LCA studies  in its environmental evaluations if those studies are made

available by manufacturers, Green Seal states that it does not attempt to perform LCA for
each of its product categories because LCA is not yet fully developed as a tool
(Weissman 1993).

       These environmental impact evaluations have utilized published  information on
products and their production processes and information provided by product
manufacturers. Both quantitative and qualitative information is utilized in the evaluations.
Where quantitative life cycle inventories have been performed on behalf of manufacturers
or trade associations, Green Seal has attempted to obtain these for use in the criteria
development process. For instance, in the evaluation of windows for labelling Green Seal
relied upon an LCA performed by the University of Amsterdam in the  Netherlands to
focus the criteria on the use stage of the life cycle (Green Seal 1993a).

       Once Green  Seal staff or consultants have evaluated the environmental impacts of
the product category throughout its life cycle, criteria are drafted that aim to reduce the
most significant impacts identified. The criteria are based upon expert judgment and
attempt to use standard tests and methodologies whenever available.

       The criteria  developed may address only one or two stages of the life cycle if the
evaluation shows that the most  significant impacts are in  those stages. For instance, the
proposed Green Seal criteria for household appliances (washing machines, refrigerators,
dishwashers, etc.) focus on energy efficiency during use as the major source of
environmental impacts (Green Seal 1993b). Furthermore, if there is great uncertainty
concerning choices  between materials or ingredients in a stage of the life cycle, and if
that stage is not clearly the most significant stage in terms of overall environmental
impacts, Green Seal may choose not to address that stage in its criteria, calling for more
input and more study.

       Informal consultations with manufacturers and others take place during the
environmental evaluation and in the development of the criteria. The formal comments on
the proposed standard are an important part of the criteria development, since they give
affected manufacturers and others an opportunity to present scientific information that
may have been overlooked in the evaluation and to comment on the technical and
economic feasibility of the criteria.       Examples

Tissue Paper

       In the  environmental impact evaluation for tissue paper, Green Seal's consultant
evaluated the process of manufacturing tissue paper from both virgin pulp and recycled
fiber. Data was obtained on the resource and energy use of both processes and on the
emissions from both processes. The evaluation identified significant reductions of most
toxic pollutants and of use of energy, water,  trees, and other natural resources by

manufacturing tissue from waste paper as compared to virgin fiber. The evaluation also
noted that recycling mills can produce significant impacts, such as the toxic water
pollutants from bleaching recycled pulp with chlorine and the water pollutants, sludge,
and air pollution from deinking recycled pulp with chlorinated solvents. Finally, the
evaluation addressed the packaging of tissue products and additives that do not contribute
to their function (Green Seal 1991).

       The standard that was ultimately adopted required 100 percent recovered paper
material, including 10-20 percent post-consumer material; a limit on the amount of
organic halogens (AOX) in the effluent from bleaching the paper, with an ultimate
restriction on the use  of chlorine or its derivatives for bleaching; a restriction on the use
of added pigments, inks, dyes, or fragrances; a minimum square footage of tissue per
package to reduce  packaging waste; and a requirement that the packaging should be made
of recycled fiber and  not contain excessive levels of heavy metals (Green Seal 1992a).

Compact Fluorescent  Lamps

       Green Seal  recently published criteria for labelling of Compact Fluorescent Lamps
(CFLs) (Green Seal 1992c). Concluding after a preliminary evaluation that the use stage
for electric lamps presents the most significant environmental impacts because of energy
use,  Green Seal excluded incandescent lamps from labelling after an evaluation of the
energy use per lumen of light delivered by incandescent  lamps as compared to CFLs. The
evaluation also showed that  CFLs would likely have advantages from a  manufacturing
and disposal perspective, because they last significantly longer than incandescent lamps.

       Once the decision was made that CFLs had the better overall environmental
profile, aspects of  the life cycle of CFLs that could be improved by setting labelling
criteria were evaluated.  To insure that CFLs with  the Green Seal provided benefits during
use,  an energy per lumen of light delivered standard was set, plus other performance
criteria, including  operating life. Criteria to address manufacturing and disposal impacts
were also included, such as  mercury content and radioisotope content. Finally, labelling
language was included to instruct the consumer on the most efficient usage of CFLs
(Green Seal  1992c).

General Purpose Household Cleaners

       Green Seal  has also developed draft criteria for labelling general purpose
household cleaners. These criteria were drafted initially for Green Seal by the University
of Tennessee Center for Clean Products and Clean Technologies after a review of the life
cycle environmental attributes of representative products  and their packaging. The class
of products is extremely diverse, and it was impossible to cover all possible ingredients,
so major ingredients were evaluated as to reported environmental impacts in raw
materials extraction and manufacturing. An evaluation was also performed of the potential
impacts from use and  disposal of major ingredients and of the life cycle impacts of

packaging alternatives (UT 1992).

       There were no existing LCA studies available that could be used to perform a
comprehensive quantitative evaluation, although a major household cleaner manufacturer
provided a summary of the results only of two studies:  one which compared different
surfactants, and one which compared a typical commercial household cleaner formulation
with a "make-your-own" formulation. The summary of the results presented for the
surfactant LCA indicated that it was difficult to differentiate gross levels of environmental
releases and energy use for surfactants  using natural oils or fats as basic raw materials
when compared to those using petrochemicals as raw materials. The summary of the
results of the typical household cleaner LCA that were  made available indicated that if
any household cleaner required the use of hot water for dilution,  the energy use for
heating the water would be a significant source of gross environmental releases (UT

       The initial recommendations for labelling criteria attempted to include criteria for
each stage of the product life cycle. Although surfactants  with natural oils as raw
materials were not preferred over those with petrochemical raw materials from a
renewable resource perspective, the release of carcinogens and reproductive toxins from
the manufacturing process was recommended as an exclusion criteria for ingredients,
which would have resulted in the exclusion of most ingredients made from
petrochemicals. For the use and disposal stage for the cleaner itself, exclusions for toxic
ingredients and limits on VOCs were recommended as well as criteria for biodegradation
and aquatic toxicity. For packaging, an exclusion for PVC and aerosol cans was
recommended as well as recycled content requirements  for other  packaging materials. It
was also recommended that the label contain a statement that only cold tap water should
be used for dilution (Green Seal  1992b).

       The household cleaner criteria have undergone public review and are being
redrafted by Green Seal. Several comments were received concerning the toxics releases
in manufacturing criteria,  stating that there was not enough basis for selecting toxic
chemical releases as the sole environmental indicator for the production process without a
life cycle assessment (Green Seal 1993c).

       The development of the household cleaner criteria demonstrates the difficulties of
developing criteria for  product categories that are characterized by several  different types
of formulations with competing raw materials and competing packaging materials. Most
of the criteria that are being considered in the final standard are intended to improve the
environmental attributes of any formulation in the use and disposal stages and to improve
the environmental attributes of any packaging material.

 2.2.9  Japanese Eco Mark Program       General Procedures

       Japan's Eco Mark Program was launched in 1989 to encourage conservation of the
 environment by certifying products and services deemed relatively beneficial to the
 environment. The program is operated by the Japan Environment Association (JEA), a
 non-governmental organization operating under the guidance of the National Environment

       Two Committees operate within the JEA: the Promotion Committee and the
 Expert Committee.  The Promotion Committee is responsible for selecting product
 categories for labelling and for developing labelling criteria in consultation with the
 Expert Committee.  It is a representative committee with members from academia, local
 governments,  manufacturers and distributors, the Environment Agency, and the National
 Institute for Environmental Studies (Hashimoto 1990).

       The Expert Committee determines whether products qualify for the label.  This
 committee is more technically based, including representatives from consumer
 organizations, local governments, environmental researchers, and technical experts  from
 the Environment Agency and the National Institute for Environmental  Studies (OECD
 1991, Hashimoto 1990). Manufacturers apply to the Expert Committee submitting
 relevant information, and the Committee may request testing by a third party. There is no
 public comment process for the setting of criteria or the award of the label to particular
 products (OECD 1991).
Procedures for Setting Criteria
       Rapid procedures that do not involve life cycle assessment are used by the Eco
Mark Program for setting criteria. As a result, there were 49 product categories for
which criteria had been developed and over 2,300 products certified by the end of August
1992 (US EPA  1993a). In general, detailed environmental evaluations of classes of
products are not performed to identify significant environmental impacts and  means to
reduce those impacts. Instead, whole categories of products, such as compost bins, are
awarded the label because they meet certain general environmental criteria (US EPA

       The general criteria used to select product categories for labelling are  as follows:

       •     minimal environmental impact from use;
       •     significant potential for improvement of the environment by using the
       •     minimal environmental impact from disposal after use; and
       •     other significant contributions to the environment.

Additional criteria that are required for approval include:

             appropriate pollution control measures at the production stage;
             ease of treatment for disposal of product;
             energy conservation during use of the product;
             compliance with regulations and standards for quality and safety; and
             price not extraordinarily higher than comparable products (Hashimoto

       The idea behind the program appears to be to label products that call attention to
an "environmental"  life style, more than to try to reduce the environmental impacts of
general consumer products. Activities considered  as part of this "environmental"  life style
may also receive the label. The Eco Mark program  has studied LCA but has decided that
the methodology is not yet ready to be used for environmental labelling  (US EPA 1993a).
       Examples of product criteria, which illustrate the methodology used, include the
following (OECD 1991):

•      personal care aerosol sprays without CFC-11, 12, 113, 114, or 115
•      beverage cans with stay-on tabs
•      home compost bins (no criteria for materials of construction)
•      soap made from used cooking oil (at least 50%  of the fat and fatty acids from
       used cooking oil  from homes or industry)
•      Toilet paper with 100 percent recycled fiber and produced in compliance with
       local environmental regulations, which can be more stringent than national
•      printing paper with 35 percent recycled fiber and produced in compliance with
       local environmental regulations, which can be more stringent than national
•      "green books" -- books and magazines of environmental subject matter printed on
       paper containing  10% recycled fiber
•      solar heating systems for home use that provide a reasonable return on investment
       through fuel savings
•      products using solar batteries that do not contain cadmium, organic halogens,  or
       harmful chemical substances

2.2.10        Singapore Green Labelling Scheme      General Procedures

       The Singapore Green Labelling Scheme was created in May 1992 and is
administered by the Ministry of the Environment. For each product category selected by
the Secretariat of the program  a workgroup is formed to develop draft criteria comprising
experts from within the Ministry of Environment and the academic institutions. The draft
criteria are then reviewed by the Advisory Committee, which is composed of
representatives of manufacturers, academic institutions, and government organizations,
and includes organizations such as the Singapore Institute of Standards and Industrial
Research, the Trade Development Board, the National University of Singapore, the
Consumer Association of Singapore, the Singapore Manufacturers Association, and the
Ministry of the Environment. Once draft criteria are developed, they are released for
public comment, then revised and approved by an Approving Board headed by the
Permanent Secretary for Environment (Singapore Ministry 1992).      Procedures for Criteria Development

       The Green Label program does not use quantitative life cycle assessment, nor does
it always consider all  stages of the life cycle. This choice has been made because of the
state of development of LCA and because it is difficult to weigh different environmental
impacts of different substances (Loo Hak Jan 1993).

       The program uses instead what it calls  a  "simplified LCA".  The few most
important parameters from the raw material, production, and distribution to disposal
stages are carefully reviewed by a technical workgroup. The workgroup develops
labelling criteria that address the parameters that it considers necessary  to make the
product "environmentally friendly" (Loo Hak Jan 1993).      Example

Compact Fluorescent Lamps

       The technical workgroup that was assembled to develop the criteria for compact
fluorescent lamps identified three parameters as most important: energy use per lumen;
radioactive isotopes in the starter; and mercury content.  Criteria were set for energy use
(e.g., 50 lumens per watt for lamps < 10 watts) and mercury content (< 10 mg of
mercury), but no criteria were  set for radioisotopes after consultation with a radiation
specialist in the Ministry of Health  who found that the use and disposal of the lamps
should not pose an environmental or health hazard (Loo Hak Jan 1993).

2.2.11       Environmental Choice New Zealand     General Procedures

       The Environmental Choice New Zealand Program is administered by Telarc,
which is a government-owned accreditation and certification authority. The Telarc
Council, the governing body for Telarc, establishes the criteria for product labelling after
receiving recommendations from its Environmental  Choice Management Advisory
Committee (ECMAC).  The ECMAC is a representative body composed of persons with
expertise in environmental science, consumer interests, manufacturing, wholesaling,
retailing, environmental policy, and environmental improvement (Telarc 1992).

       ECMAC selects product categories for evaluation, and Task Groups consisting of
experts of different interests in the relevant field are set up to develop product criteria.
The Task Groups present a draft of criteria to the ECMAC, which is released to the
public, and a public comment period is held. The Task Group then revises the criteria
based upon the comments and presents the revised criteria to the ECMAC for approval
(Telarc  1992).     Procedures for Criteria Development

       The procedures  used to develop product criteria include an assessment of
environmental impacts in the product category throughout the product life cycle, as far as
is practicable. The assessment is used to choose those aspects for which a significant
environmental gain can be achieved (Telarc  1993).

       The ECMAC Guidelines for Task Groups contain the following note about the use
of life cycle assessment:

      It may have to be clearly acknowledged that the aspect(s) chosen are
      considered the best practicable option(s). Other aspects of the product's life
      cycle which deserve attention may not be considered (at a particular time)
      because  of the unavailability of information,  particularly of overseas
       materials and components, and the inadequacy of the programme's
      resources to fully investigate the product's life cycle.

      Ideally, within a chosen product category the environmental impacts of a
      product's entire life-cycle should be considered (i.e., a "cradle-to-grave"
      approach). While this ideal is what the programme should aim for it will
      often be very difficult to achieve it. When such difficulties occur the
      criteria document should explain the difficulty and detail any assumptions

      The guidelines also reflect a concern that certain choices between materials are

premature given the state of information on the environmental attributes of materials. The
guidelines state that no stance should be taken on the issue of whether plastic or paper is
environmentally preferable, for instance, and that such an approach will apply to other
similar situations (Telarc 1993).      Examples

       Examples of product criteria from Environmental Choice New Zealand do not
reflect the use of quantitative life cycle assessment in the evaluations performed to
develop the criteria. They each contain the preliminary statement that "based upon a
review of currently available information, the following product category requirements
will produce a net environmental benefit" and that "as information and technology
change, product category requirements will be reviewed, updated,  and possibly


       The paint criteria focus on the ingredients of the paint and attempt to reduce VOC
content and the content of halogenated solvents, hydrocarbon solvents, aromatic
hydrocarbon solvents, and toxic compounds. It is assumed that the reduction of these
constituents, and in particular, VOCs, will result in a net environmental benefit
throughout the product life cycle (Environmental Choice New Zealand 1993).

Carbon Zinc and Zinc Air Batteries

       The criteria for both carbon zinc and zinc air batteries focus on reducing levels of
mercury in the batteries and do not address any other environmental impacts
(Environmental Choice New Zealand 1992a).

Plastic Products  Using Recycled Plastics

       The criteria for plastic products using recycled plastics assumes that plastics
recycling produces a net environmental benefit and focusses only on recycled content
(Environmental Choice New Zealand 1992b).
2.3    Comparison of Criteria Among Labelling Programs

       Tables 3 and 4, below, compare labelling criteria for two products among
labelling programs with different methodologies for developing labelling criteria. From
this comparison it can be seen that labelling programs address the same general
environmental issues for the same product categories, in spite of differences in


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3.1    Single-Attribute Claims Certification

       Single-attribute labelling programs are distinguished from other seal-of-approval
type programs in that they focus on only one product environmental attribute without
regard to whether the attribute that is the subject of the label provides overall
environmental benefits or is one of the most significant environmental attributes of the
product. For instance, a label certifying that a household cleaner is biodegradable says
nothing about whether biodegradability is the most significant indicator of the product's
overall environmental impacts or whether the product may have other properties that are
significantly detrimental to the environment. Almost by definition, single-attribute claims
certification does not involve the use of life cycle assessment.

       Independent single-attribute claims certification is important in the sense that
government agencies have been actively encouraging product environmental
improvements for certain single attributes through procurement guidelines and market
development programs,  such as increased use of recycled material and increased energy
efficiency. In addition, the United States Federal Trade Commission  (FTC) and certain
state agencies have institutionalized criteria for certain specific environmental claims.
Finally, consumers have come to believe that certain environmental attributes of products
are relatively beneficial to the environment, and manufacturers are making such claims in
order to sell products. The independent certification provides the consumer with
assurance that the claim has been verified and that the attribute has been measured in
some objective fashion by some preset criteria.

       Two programs that have been operating for single-attribute claims certification
include Scientific Certification Systems, a private environmental labelling organization in
the United States, and Environmental Choice Australia (US EPA 1993a).
 3.2    Product Environmental Information Profile Approach

       The use of a label that represents an environmental information profile of a
 product represents a significantly different approach than seal-of-approval type programs.
 Instead of certifying that a product has certain superior environmental attributes as
 compared to other products in its class based on preset criteria, the environmental
 information profile approach seeks to simply convey information about the environmental
 attributes of the product to the consumer in quantitative or qualitative fashion without
 preset selection criteria or selection of superior products.

 3.2.1  Scientific Certification Systems Environmental Report Card

       One private environmental labelling organization in the United States, Scientific

Certification Systems (SCS), has launched such a label that it calls an "Environmental
Report Card." The purpose of the label is to provide the consumer information
concerning the results of a life cycle inventory of the actual product bearing the label in
an aggregated format using the concept of "environmental burdens"  (SCS 1993a).

       SCS uses an LCI model developed by Dr. Ian Boustead of Great Britain to
generate quantitative information on inputs and outputs for the product system. Data is
collected directly from the manufacturer of_the product for the stages of the life cycle that
are controlled by the manufacturer. Upstream or downstream data is provided by a
database furnished with the Boustead model that is supplemented by data from the
literature, government reports, published LCI studies, and other studies conducted by
SCS (Rhodes 1993a). SCS staff visit manufacturers' facilities to verify data on inputs and
outputs and,  in some cases, attempt to verify supplier data through contacts with suppliers
(Rhodes  1993a).

       In order to present data from  the inventory in a format that will fit on a product
label, SCS aggregates the inputs and outputs from the model into categories called
"environmental burdens". Resource and energy inputs are aggregated based upon
chemical or physical properties  which can be scientifically identified. Emissions and
waste outputs are aggregated based upon  government reporting categories under federal
environmental regulations in the United States or important international treaties, such as
the Montreal Protocol. Emissions  of chemicals that have not been so classified are
aggregated and reported as "unclassified" for completeness (Rhodes  1993b).

These environmental burdens include the following:

       Resources Depleted

             Coal, Natural Gas,  Oil (Non-fuel)
             Animal Products

       Energy (total used)

       Air Emissions

       •      Carbon dioxide
       •      Carbon monoxide
       •      Sulfur oxides
       •      Nitrogen oxides

             Ozone depleting chemicals
             Hazardous air pollutants
             Unclassified emissions
       Water Emissions
       •     Total solids
       •     Oxygen depleting chemicals
       •     Toxic pollutants

       Solid Waste

       •     Hazardous waste
       •     Unclassified waste

(SCS 1993b; Rhodes 1993b).

       This aggregation of LCI data into "environmental burdens" is not intended to be a
form of life cycle impact assessment. In the EPA and SETAC framework for impact
assessment, the first step is classification of inputs and outputs into impact categories.
These impact categories represent a step beyond the SCS environmental burden categories
in relating the inputs and outputs to some type of environmental impact. For instance,
nitrogen oxides are listed as an SCS environmental burden, but in life cycle impact
assessment these pollutants would be classified and aggregated with  sulfur oxides as
acidification emissions or with carbon monoxide and hydrocarbons as smog forming

       The version of the Environmental Report Card that was launched in August 1993
presents the aggregated environmental burdens as bars on a bar chart. The scale is an
exponential scale, so that several orders of magnitude for the different burdens can  be
represented on the same chart. The label "Better: Lower Burdens" is at the left end of the
horizontal bar chart and the label "Worse: Heavier Burdens"  is on the right end of the
bar chart. The aggregated totals for emissions, etc., are presented in numerical form also
(SCS 1993c).

       The stated goal of SCS for the Environmental Report Card is to function in
similar fashion as nutritional labelling and energy efficiency labelling, providing neutral
information to consumers that allows them to assess the relative "quality" of the product.
SCS claims that the report card approach, as a full disclosure system, also provides
consumers an important educational opportunity to learn about how products produce
environmental burdens and demonstrates that every product produces environmental
burdens and that there are frequently tradeoffs between different types of environmental


       The label recently launched by SCS goes beyond the information-only approach,
however, and approaches a seal of approval by including a prominently displayed Green
Cross logo in a box on the front of the label titled in bold letters, "Certified
Environmental Advantages". The labels for trash bags made with recycled plastic list in
this box advantages of the products as compared with trash bags made from virgin
plastic, although no virgin plastic products bear the Environmental Report Card (SCS
1993c). The addition of the "Certified Environmental Advantages" box with the Green
Cross logo obviously implies environmental superiority and endorsement.

       SCS is promoting the report card as preferable to the seal-of-approval approach
used by all government-sanctioned  environmental labelling programs. SCS claims that the
report card approach eliminates the subjective judgment that goes into developing criteria
for award of a seal.  Another claimed advantage for report cards over seal-of-approval
approaches is that report cards recognize incremental improvements in  reducing burdens,
instead of creating a pass/fail dividing line like most labelling criteria do (Rhodes 1993b).

       Criticisms of the report card approach as an environmental labelling system for
consumer products include concerns that the presentation of life cycle inventory results
without all of the information on assumptions, boundaries, and equivalent use, can be
misleading; that the selection of environmental burden categories for the report card and
the presentation of widely different environmental burdens on the same scale represents
subjective judgment and implies a form of impact assessment that has not been
performed; and that having the label appear on one or a few products on the shelf creates
the impression of endorsement, even if the burdens may be greater than those for other
products that do not carry the label.
3.2.2  Dutch Programs

       The Dutch Ministry of Housing, Physical Planning, and Environment is
developing two schemes to make use of product life cycle environmental information. In
addition to the Dutch Ecolabelling scheme discussed above, the Ministry is developing a
system whereby qualitative information on a product's most important environmental
attributes would be required by the government to be  presented on the label. The product
groups and the information to be reported would be specified by the Ministry (Geelen

       The Dutch have also been developing the concept of "integrated chain
management", where environmental information concerning the materials and ingredients
of a product are shared by producers all along the chain from raw materials to final
production. Having this information in usable form would enable producers to assess and
reduce their environmental impacts up and down the chain. The "environmental profiles"

proposed in this scheme could resemble the Environmental Report Card, discussed above,
or something like a Material Safety Data Sheet now used for chemical products (Geelen
3.3    Expert System Evaluations

       Given that the primary use of LCA in most environmental labelling programs is
for the identification of the most important stages of the life cycle and the most
significant inputs and outputs resulting in potential environmental impacts, it may be
possible to perform this identification step without the time and expense required for a
quantitative data-based study. The German Blue Angel Program's assessment matrix is a
qualitative approach that uses expert judgment to focus in on important life-cycle stages
and input/output parameters (Neitzel 1992a).

       As in  the German experience, such qualitative assessments may be sufficient for
setting certain types of criteria for certain product categories.  One problem with
qualitative approaches such as these, however, is that the expert judgment may come only
from one source, with one set of values and experiences, and may be exercised in a non-
systematic manner.

       The University of Tennessee Center for Clean Products and Clean Technologies
has tested a more formal expert system approach to qualitative life cycle evaluations. The
study was done by selecting an expert system decision-making protocol, called the
Analytical Hierarchical Process (AHP), that arrives at decisions by a series of paired
comparisons (Saaty 1990). An expert questionnaire was developed for evaluating the life
cycle environmental impacts of two competing product systems, kraft paper grocery sacks
and polyethylene plastic grocery sacks, and the results were analyzed using Expert
Choice*, commercially available software embodying the AHP methodology (Manseill

       The questionnaire broke the life cycle of each product down into four stages: raw
materials extraction,  production of intermediates,  fabrication of final product,  and
transportation, use and disposal of the product. Basic information was given about each
product system, such as functional unit assumptions (4 pounds of paper sack carries same
amount as 1 pound of polyethylene sack), raw materials used, and a process flow
diagram. The information provided did not quantify or even identify the environmental
impacts associated with each stage of the product systems, since the purpose of the
questionnaire was to  determine if the relative magnitudes of these impacts could be
determined through expert judgment without extensive data collection. The experts asked
to complete the questionnaire were asked  to rely upon their knowledge and experience to
determine the relative environmental impacts of the different stages of the life cycles of
both product systems, both within each product system and across the product systems.

       Thirty-three experts were selected to receive the questionnaire. They were selected
based upon their experience in the paper industry or the plastics industry or in general
assessment of environmental impacts. The former category included engineers in the
paper or plastics industries and university professors. The later category included
environmental consultants and government agency scientists. Out of the experts solicited,
ten completed and returned the questionnaire, which took most over two hours to

       The questionnaire asked the experts to judge the relative importance of each of the
following impact categories for each stage of the life cycle of the two products:

       Air Pollution:

              acidification releases
              greenhouse gases
              ozone depleting chemicals
              smog forming releases
              hazardous chemicals

       Water Pollution:

              toxic chemicals
              oxygen depleting discharges

       Solid Waste

              hazardous solid
              other solid

       Energy Use

For categories like greenhouse gases,  ozone depleting chemicals, and hazardous air
pollutants, lists of particular chemicals from regulations or scientific journals were
provided to the experts as a reference.

       For both products, for almost every impact category, the production of
intermediates stage of the life cycle was judged by the experts to be the most significant.
Table 5 and 6 , below, illustrate the impact categories for the different stages of the life
cycle of each product that the experts judged to be most significant ("X" indicates that the
categories rated highest). For paper sacks, the three most significant impact
categories/life cycle stages were hazardous solid wastes, smog forming air pollutants,  and

oxygen depleting water pollutants, all in the production of intermediates stage. For
polyethylene sacks, the three most significant were energy use, toxic water pollutants,
and hazardous air pollutants, all in the production of intermediates stage (Manseill 1993).

       These results could be used to focus data collection efforts in a subsequent
quantitative life cycle inventory on the production of intermediates stage for each product.
They could also be used as grounds  for a decision to focus on labelling criteria that
would reduce the need for production of intermediates in the life cycle of each product.
Recycled content criteria for both types of sacks would be one way of reducing this
production. An evaluation  would have to be made of the environmental attributes of
recycled material versus virgin material before reaching a conclusion that such criteria
would reduce environmental impacts.

            Table 5: Results of Expert System for Kraft Paper Grocery Sacks
Impact Category/
Life Cycle Stage
Ozone Depleting
Smog Forming
Hazardous Air
Particulate Air
Other Air
Water Toxic
Oxygen Depleting
Other Water
Hazardous Solid Waste
Other Solid Waste
Energy Use
Extraction of Raw


Production of



Fabrication of Final

Transportation, Use, and





communication, The Hague, The Netherlands, June 18, 1993 (1993a).

Verhees, G., Dutch Stichting Miliekeur (Ecolabelling Organization). Comments on Draft
Report, August 23,  1993 (1993b).

Weissman, Arthur, Green Seal. Comments on Draft Report, August 18, 1993.

Wendler, Susanna, "The Austrian Eco Label: Discussion Paper", Vienna,  Austria, 1993.

Whitehead, Kathy. "Situation Report, EC Ecolabelling Scheme," UK Ecolabelling Board,
London, U.K., April 16, 1993.

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