United States Office of Prevention, Pesticides EPA 742-R-98-009
Environmental Protection and Toxic Substances December 1998
Agency (7409)
Environmental Labeling
Issues, Policies, and
Practices Worldwide
Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postconsumer)
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Environmental Labeling
Issues, Policies, and Practices Worldwide
December 1998
prepared/or:
Pollution Prevention Division
Office of Pollution, Prevention and Toxics
U.S. Environmental Protection Agency
(7409)
401 M Street, SW
Washington, DC 20460
(202) 260-4000
EPA Contract No. 68-W6-0021
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Table of Contents
Environmental Labeling: Scope of this Report xii
1. Introduction 1
2. Environmental Labeling: The US Perspective 5
2.1. Background 5
2.2. Environmental Labeling in the US 6
3. Definition of Environmental Labeling 9
3.1. Positive Labeling Programs 11
Seal-of-Approval 11
Single-attribute Certification Programs 11
3.2. Negative Labeling Programs 12
Hazard/Warning Labels 12
3.3. Neutral Labeling Programs 13
Information Disclosure Programs 13
Report Cards 13
4. Overview of Labeling Programs Worldwide 15
4.1. Introduction 15
4.2. Fundamental Information 15
Program Type 16
Participation 18
Label Type 19
Administration 21
Financing 22
Year Founded 22
Product Categories 24
Number of Awards 25
4.3. Geographic Representation 26
4.4. Program Methodology 35
Program Goals 35
Program Methodologies 36
Stakeholder Involvement 38
4.5. Program Breadth 39
Use of Non-Environmental Attributes 39
Use in Procurement 40
Use Beyond Retail 42
Other Programs/Activities 44
4.6. Changes to Environmental Labeling Programs 45
Table of Contents i
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4.7. Coordination Efforts Among Programs 46
4.8. Trade Issues 48
5. Forces Affecting Environmental Labeling Programs 51
5.1. Public/Societal Interests 52
5.2. Consumer Interest 54
5.3. Retailer's Interests 55
5.4. Producer's Interests 55
5.5. Operating Costs and Profit 56
5.6. Standardization of Environmental Labeling Programs 57
5.7. Procurement Programs 57
6. Recent Trends and Future Outlook 59
6.1. The Proliferation and Globalization of Environmental Labeling Programs .... 60
6.2. Standardization 62
6.3. Wedge Issues 64
Program Goals 64
Limitations to Standardization 65
6.4. Future Outlook 66
Appendix A: Overview Table of Environmental Labeling Programs
Covered in This Report A-l
Appendix B: Summaries of Environmental Labeling Programs
Covered in This Report
List of Environmental Labeling Programs Covered in This Report B-i
Austrian Eco-label B-l
Introduction B-l
Recent Developments B-l
Program Summary B-l
Program Methodology B-2
Other Information B-3
References B-3
Product Categories B-3
Table of Contents
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Canada's Environmental Choice"1 Program: the Ecologo"1 B-5
Introduction B-5
Recent Developments B-5
Program Summary B-5
Program Methodology B-6
Other Information B-7
References B-8
Product Categories B-9
China's Ecolabeling Program B-13
Introduction B-13
Program Summary B-13
Program Methodology B-14
References B-15
Product Categories B-15
Croatia's Environmental Label B-17
Introduction B-17
Program Summary B-17
References B-18
Product Categories B-18
The Czech Ecolabel B-21
Introduction B-21
Program Summary B-21
Program Methodology B-21
Other Information B-22
References B-22
Product Categories B-22
The Nordic Council's Nordic Swan Label B-23
Introduction B-23
Recent Developments B-23
Program Summary B-24
Program Methodology B-26
Other Information B-27
References B-27
Product Categories B-28
Table of Contents iii
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European Union Eco-label Programme B-31
Introduction B-31
Recent Developments B-31
Program Summary B-33
Program Methodology B-34
Other Information B-37
References B-38
Product Categories B-39
France's NF-environnement Mark B-41
Introduction B-41
Recent Developments B-41
Program Summary B-42
Program Methodology B-43
Other information B-44
References B-44
Product Categories B-45
Germany's Blue Angel B-47
Introduction B-47
Recent Developments B-47
Program Summary B-48
Program Methodology B-49
Other Information B-50
References B-50
Product Categories B-51
Germany's Green Dot Program B-55
Introduction B-55
Recent Developments B-55
Program Summary B-55
Program Methodology B-56
Other Information B-57
References B-57
India's Ecomark B-59
Introduction B-59
Recent Developments B-59
Program Summary B-60
Program Methodology B-60
Other Information B-61
References B-63
Product Categories B-64
iv Table of Contents
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Japan's Ecomark B-65
Introduction B-65
Recent Developments B-65
Program Summary B-66
Program Methodology B-66
Other Information B-67
References B-67
Product Categories B-68
South Korea's Eco-mark B-71
Introduction B-71
Recent Developments B-71
Program Summary B-71
Program Methodology B-72
References B-72
Product Categories B-72
Malaysia's Product Certification Program B-75
Introduction B-75
Program Summary B-75
Program Methodology B-76
Other Information B-76
References B-77
Product Categories B-77
Netherland's Stichting Milieukeur B-79
Introduction B-79
Recent Developments B-79
Program Summary B-79
Program Methodology B-80
Other Information B-81
References B-81
Product Categories B-81
New Zealand's Environmental Choice B-85
Introduction B-85
Recent Changes B-85
Program Summary B-85
Program Methodology B-86
Other Information B-87
References B-87
Product Categories B-87
Table of Contents
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Singapore's GreenLabel B-89
Introduction B-89
Recent Developments B-89
Program Summary B-89
Program Methodology B-91
Other Information B-91
References B-92
Product Categories B-92
Spain's AENOR - Medio Ambiente B-95
Introduction B-95
Recent Developments B-95
Program Summary B-95
Program Methodology B-96
Other Information B-96
References B-96
Product Categories B-96
Sweden's Good Environmental Choice B-99
Introduction B-99
Program Summary B-99
Program Methodology B-100
Other Information B-100
References B-100
Taiwan's Green Mark Program B-101
Introduction B-101
Recent Developments B-101
Program Summary B-102
Program Methodology B-104
Other Information B-104
References B-105
Product Categories B-105
Thailand's Green Label Scheme B-107
Introduction B-107
Recent Developments B-107
Program Summary B-107
Program Methodology B-108
Other Information B-108
References B-108
Product Categories B-109
vi Table of Contents
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US PROGRAMS
Rechargeable Battery Labeling B-l 11
Introduction B-l 11
Program Summary B-l 11
Program Methodology B-l 12
Other Information B-l 13
References B-l 13
Product Categories B-l 13
The Chlorine Free Products Association (CFPA) B-l 15
Introduction B-l 15
Program Summary B-l 15
Program Methodology B-l 16
Other Information B-l 16
References B-l 16
Product Categories B-l 16
US Environmental Protection Agency's Consumer Labeling Initiative B-l 19
The Rainforest Alliance - ECO-O.K. Certification Program B-121
Introduction B-121
Program Summary B-121
Program Methodology B-121
Other Information B-123
References B-123
HVS Eco Services' Ecotel® Certification B-125
Introduction B-125
Program Summary B-125
Program Methodology B-127
References B-127
Product Categories B-128
The Energy Guide: Household Appliance Energy Efficiency Labeling B-129
Introduction B-129
Program Summary B-129
Program Methodology B-131
References B-131
Product Categories B-132
Table of Contents vii
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US EPA Energy Star Programs B-133
Introduction B-133
Recent Developments B-133
Program Summaries B-133
Program Methodology B-137
References B-137
Product Categories B-138
Fuel Economy Information Program B-139
References B-140
Pesticide Labeling under the Federal Insecticide, Fungicide, and Rodenticide Act B-141
Introduction B-141
Program Summary B-141
Enforcement B-150
References B-150
Green Seal B-153
Introduction B-153
Recent Developments B-153
Program Summary B-153
Program Methodology B-154
Other Information B-155
References B-156
Product Categories B-157
EPAS Ozone Depleting Substance (ODS) Warning Label B-161
Introduction B-161
Recent Developments B-161
Program Summary B-161
References B-163
California Proposition 65 B-165
Introduction B-165
Recent Developments B-165
Program Summary B-166
Program Methodology B-167
References B-167
viii Table of Contents
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Scientific Certification Systems' Environmental Claims Certification Program B-169
Introduction B-169
Recent Developments B-169
Program Summary B-169
Program Methodology B-170
Other Information B-170
References B-170
Product Categories B-171
Scientific Certification Systems' Certified Eco-profile Labeling System B-173
Introduction B-173
Recent Developments B-173
Program Summary B-174
Program Methodology B-175
Other Information B-176
References B-177
Product Categories B-178
Scientific Certification Systems' Forest Conservation Program B-179
Introduction B-179
Recent Developments B-179
Program Summary B-180
Program Methodology B-181
Other Information B-182
References B-182
Product Categories B-183
Scientific Certification Systems' Nutriclean Food Safety Management Program B-185
Introduction B-185
Recent Developments B-185
Program Summary B-186
Program Methodology B-187
Other Information B-187
References B-187
Product Categories B-188
Product Labeling under the Toxic Substances Control Act (TSCA) B-189
Introduction B-189
Program Summary B-189
Examples of TSCA Labels B-190
References B-192
Table of Contents ix
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Vermont Household Hazardous Product Shelf Labeling Program B-193
Introduction B-193
Recent Developments B-193
Program Summary B-194
Program Methodology B-195
References B-195
Product Categories B-195
Water Alliances for Voluntary Efficiency (WAVE) B-197
Introduction B-197
Program Summary B-197
Program Methodology B-199
References B-199
Product Categories B-199
Buying Guides B-201
Greening the Government: A Guide to Implementing
Executive Order 12873 B-201
References B-201
The Green Pages B-201
References B-202
US EPA National Volatile Organic Compound Emission Standards
for Architectural Coatings B-203
Introduction B-203
Program Summary B-203
Program Methodology B-205
References B-205
Product Categories B-205
Programs Under Development B-207
Brazilian Association for Standardization's "ABNT - Qualidade Ambiental" B-207
Introduction B-207
Program Summary B-207
Program Methodology B-209
Other Information B-209
References B-209
Product Categories B-209
Small Spark-Ignited Engine Environmental Labeling Program B-210
References B-210
Electric Utility B-210
References B-211
Table of Contents
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Indonesian Environmental Labeling B-211
Introduction B-211
References B-212
Germany's Type III Eco-report Card B-213
References B-213
Hong Kong Ecolabeling Scheme B-213
References B-214
Select Bibliography on Environmental Labeling Bibliography-1
Table of Contents xi
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Table of Figures, Tables, and Charts
Figure 1: Classification of Environmental Labeling xv
Chart 1-1: Flow of Information from Manufacturers to Consumers 2
Chart 3-1: Classification of Environmental Labeling 10
Chart 4-1: Program Type 17
Chart 4-2: Participation in Labeling Programs 18
Table 4-1: Participation by Program and Label Type 20
Chart 4-3: Programs by Label Type 20
Chart 4-4: Programs by Organization Type 21
Chart 4-5: Programs by Financing Source 22
Chart 4-6: Number of Programs Founded by Year (<1997) 23
Chart 4-7: Product Categories in Seal-of-Approval Programs 24
Chart 4-8: Number of Awards in Seal-of-Approval Programs 25
Figure 2: Positive and Neutral Third Party Ecolabeling Programs Worldwide 27
Figure 3: Positive and Neutral Third Party Ecolabeling Programs in Europe 29
Figure 4: Positive and Neutral Third Party Ecolabeling Programs in Pacific Rim 31
Figure 5: Positive and Neutral Third Party Ecolabeling Programs in
North and South America 33
Table 4-2: Missions/Goals Given for Programs Covered in This Report 36
Chart 4-9: Programs by Methodology 37
Chart 4-10: Programs by Stakeholder Involvement 38
Chart 4-11: Programs that use Non-environmental Attributes 40
Chart 4-12: Programs used in Procurement 42
Chart 4-13: Use on Retail/Non-retail Products 43
Chart 4-14: Programs With Other Activities 44
Chart 4-15: Programs with Foreign-based Licenses 46
Chart 4-16: Programs that Indicate Working with Other Countries 47
Chart 4-17: Programs that Participate in ISO 48
Chart 4-18: Programs that Report Trade Conflicts 50
Table 1: Toxicity Category Definition B-144
Table 2: Hazard to Humans and Domestic Animal Precautionary Statements B-146
Table 3: Acute Oral Toxicity Study* B-146
Table 4: Acute Dermal Toxicity Study B-147
Table 5: Acute Inhalation Toxicity Study B-147
Table 6: Primary Eye Irritation Study B-148
Table 7: Primary Skin Irritation Study B-148
Table 8: Dermal Sensitization Study B-148
Table 9: Physical or Chemical Hazard Precautionary Statements B-149
xii Table of Contents
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Environmental Labeling: Scope of this Report
Labeling programs can be classified according to a number of program characteristics, as
illustrated on the following figure (Figure 1). The most important is whether the program relies
on first-party or third-party verification1. The former is performed by marketers on their own
behalf to promote the positive environmental attributes of their products. Programs relying on
first-party verification are not addressed in this report. Third-party verification is carried out by
an independent source that awards labels to products based on certain environmental criteria or
standards. Environmental labeling programs can also be characterized as positive, negative, or
neutral. Positive labeling programs typically certify that labeled products possess one or more
environmentally preferable attributes. Negative labeling warns consumers about the harmful or
hazardous ingredients contained in the labeled products. Neutral labeling programs simply
summarize environmental information about products that can be interpreted by consumers as
part of their purchasing decisions. Third-party environmental labeling programs can be further
classified as either mandatory or voluntary. Mandatory programs include hazard or warning
labels, and information disclosure labels. Voluntary labels are typically positive or neutral, and
are further classified as either report cards, seal-of-approval, or single-attribute certification
programs.
The US programs covered in this report include mandatory government programs, voluntary seal-
of-approval programs, single-attribute programs, hazard warning programs, and information
disclosure programs. Due to the scope of this report, not every labeling program that may be in
existence today is covered (e.g., food is not covered), and the report should not be seen as a
comprehensive study of all labeling programs worldwide. The report presents a snapshot of the
major environmental labeling programs in existence during the research phase for which
information was available.
1 Verification refers to an evaluation process or determination that products or services meet specified
criteria or claims.
Scope of Report xiii
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Figure 1: Classification of Environmental Labeling
Environmental Labeling
First-Party
Environmental Labeling Programs
Third-Party
Environmental Labeling Programs
Product-Related
/
/
Claims
(e.g., Recyclable)
On Products
or Shelf labels
Corporate-Related
Mandatory
Hazard or Information
Warning Disclosure
(e.g., Pesticides, (e.g., EPA fuel
Prop. 65) economy label)
Cause-Related / \
Marketing Cause-Related Promotion of
(e.g., "Proceeds Marketing Corporate Env.
donated to...") (e.g., Company Activity or
supports WWF) Performance
In Ads
Voluntary
Environmental
Certification
Programs
Report Seal of Single
Card Approval Attribute
Certification
xv
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Environmental Labeling Issues, Policies, and Practices Worldwide
1. Introduction
This research is part of the EPA's overall effort to educate and inform product users about the
environmental attributes and consequences of products they purchase. It documents the state of
environmental labeling worldwide and provides a basis for anticipating trends.2 This report
focuses on environmental labeling efforts aimed specifically at retail consumers; however, many
of the labeling activities and programs covered have non-retail applications. The findings are
expected to educate and inform those who may be directly affected (e.g., environmental policy
makers, product manufacturers, organizations/governments making large purchases of consumer
products) or indirectly affected (e.g., trade officials) by environmental labeling programs on the
operation and development of environmental labeling programs. This report should also advance
the debate about the utility of environmental labeling programs.
The term "environmental labeling" covers a broad range of activities from business-to-business
transfers of product-specific environmental information to environmental labeling in retail
markets. Labels, as well as other labeling program activities, serve a variety of purposes and
target a number of different audiences.
At one end of the spectrum, business-to-business environmental labeling includes activities such
as the provision of Material Safety Data Sheets (MSDSs), product stewardship programs, hazard
communication programs, and product manifests. All of these activities are meant either to
provide industrial customers and workers with information on the health, safety, and
environmental effects of the products they purchase or to encourage them to use these products in
ways that minimize their eventual impact on human health and the environment. At the other
end of the spectrum, environmental labeling programs have been established worldwide to help
consumers evaluate the environmental attributes of the products and services they are considering
buying. In this case, the term "consumer" is not limited to private citizens but includes
governments and large institutions seeking to incorporate environmental considerations into their
procurement processes.
One goal of such programs, typically, is to promote environmental improvement by encouraging
consumers to choose products and services considered to be environmentally preferable.3
This report builds on the Status Report on the Use of Environmental Labels Worldwide (EPA Document
#742-R-9-93-001) by updating findings and documenting changes.
3 Gaining more prominence in the past few years is the environmental certification of certain service
industries such as hotels. Issues such as water conservation and energy efficiency are among the environmental
attributes most frequently evaluated. For ease of presentation, the term "products" will be used throughout the
Introduction
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Related information dissemination activities include, but are not limited to, the Environmental
Protection Agency's (EPA) Consumer Labeling Initiative (CLI), the Environmentally Preferable
Procurement (EPP) Program and other numerous product labeling programs, the International
Organization for Standardization's (ISO) efforts to develop standardized environmental labeling
criteria, and the Federal Trade Commission's (FTC) guidelines for making environmental claims.
Additionally, there are information disclosure activities among U.S. state programs. For
example, the state of California's Proposition 65 program mandates that information on a set of
listed toxics be disclosed on product labels. Similarly, Vermont's Household Hazardous
Products Shelf Labeling Program requires retailers to place a label on store shelves that stock
household products containing hazardous materials. These types of programs do not lead to
product labeling per se, but provide consumers with added information about the products they
purchase.
Information concerning the health and environmental effects of products and product constituents
is currently available through a number of pathways, of which labeling is just one. Much of this
information is already generated by manufacturers and is available at various stages of product
manufacture. For some but not all products, environmental information may be passed on to
retail customers (see Chart 1-1).
Chart 1-1: Flow of Information from Manufacturers to Consumers
Reprocessing
Manufacture > Point of *Use »• Disposal
and Distribution Purchase
Raw * Finished > Used
Materials products products
Environmental ^ Manufacturers/ > Consumers
Information retailers
For example, the Occupational Safety and Health Act (OSHA) requires manufacturers to
generate an MSDS that includes a description of the product's physical and chemical properties,
as well as its health, fire, and explosion hazards. MSDSs must be provided to workers, industrial
customers (e.g.., formulators and distributors) and Local Emergency Planning Committees.
report to refer to products and services.
Introduction
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Warning information is required by the US Department of Transportation (DOT) during
interstate transport of hazardous materials such as explosives, flammables, radioactive materials,
and pathogens. Many of the chemical manufacturing, formulating, and distributing sectors have
adopted the tenets of product stewardship. Companies practicing product stewardship take a
"cradle-to-grave" approach to their products by encouraging the safe use and disposal of their
products after they have been sold to industrial customers. Product stewardship can take the
form of voluntary services offered to customers in the form of brochures, training videos, and site
audits, as well as mandatory requirements that determine whether or not the company will sell or
ship to a specific company. The Chemical Manufacturers Association's Responsible Care
Program is one example of a product stewardship program. These information dissemination
activities serve different purposes and typically, neither reach the general public, nor are
organized into a format that would be readily understandable by consumers. With the current
increase in consumer right-to-know initiatives, particularly in the US, and interest in its uses as a
soft policy tool, the demand for environmental labeling has been increasing.
The type of information presented on labels varies widely, depending on issues specific to the
product and whether labeling is mandatory or voluntary. For example, products subject to the
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) requirements must carry labels that
list the active ingredients in the product, first aid statements, environmental, physical and
chemical hazards, directions for use, and instructions for storage and disposal. Other products
may carry voluntary labels specific only to environmental attributes such as the percent of post-
consumer recycled content of the product or its packaging. Note that these examples all describe
characteristics of the product during use or disposal: some labels may also present information
about the manufacture of the product. For example, categories like resource consumption,
energy use, pollutant releases to the environment, and workplace and ecosystem effects may be
addressed.
Environmental labels provide an opportunity to inform consumers about product characteristics
that may not be readily apparent. For example, it may be unsuitable to pour unused cleaning
product down the drain, due to the product's potential aquatic toxicity. Additionally, labels allow
consumers to make comparisons among products. Armed with this information, consumers have
the ability to reduce the environmental impacts of their daily activities by purchasing
environmentally preferable products and minimizing their consequences during use and disposal.
Labels help consumers vote their preferences in the marketplace and therefore potentially shift
the market toward products that minimize environmental impacts. Label information helps
consumers to use safely and properly recycle or dispose of both products and packaging.
The purpose of this report is to provide an overview and analysis of environmental labeling
programs worldwide. Chapter 2 provides an overview of environmental labeling from the
perspective of the United States. The chapter sets out some important background issues,
history, and definitions, all of which are critical to understanding the development of
environmental labeling to date, as well the future outlook for US programs. Chapter 3 describes
Introduction
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the types of environmental labeling programs, including specific definitions of program types.
Chapter 4 presents an overview of environmental labeling programs worldwide. Topics covered
include program breadth, methodology, recent changes, and coordination with other programs.
Summary statistics are also provided. In Chapter 5, the forces affecting environmental labeling
programs, such as public/societal interests, consumer interests, retailer's interests, producer's
interests, operating costs/profits, standardization, and procurement programs are discussed.
Chapter 6 discusses recent program changes and possible future trends. Finally, Appendix A
summarizes the labeling programs covered in this report, and Appendix B provides detailed
program summaries. The findings and summaries contained herein are based on a number of
efforts that provide complementary research, including EPA's direct experience with
environmental labeling and labeling programs, EPA's involvement in related governmental
initiatives, literature reviews and investigations into labeling and program administration, and
EPA's coordination with domestic and international programs.
Introduction
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2. Environmental Labeling: The US Perspective
2.1. Background
In all of the seven major industrialized nations (the "G7"), continual efforts have been made to
compile environmental performance information specific to a wide range of products and
services.4 Such information is disseminated to consumers through hundreds of labeling
programs, both governmental and non-governmental. These programs are implemented at
various points throughout the manufacturing process, from raw material extraction to use and
disposal. It is important to note that environmental labeling has practical implications in the
marketplace, where goods and services compete for consumers, as well as public policy
implications for governments, which are typically charged with the protection of environmental
quality — a "common good" owned collectively by society. Labeling in the US is no longer
separable from labeling activities in foreign countries, such as ecolabeling programs, nor from
international activities, such as the International Organization for Standardization (ISO) 14000
standard-setting process. Thus, the scope of this report focuses on US programs, yet includes
active foreign "ecolabeling" programs.
In simple terms, environmental labeling is defined as making relevant environmental information
available to the appropriate consumers. Environmental labeling is the practice of labeling
products based on a wide range of environmental considerations (e.g., hazard warnings, certified
marketing claims, and information disclosure labels). Labeling contributes to the
decision-making process inherent in product selection, purchasing, use and disposal, or
retirement. Yet unlike most regulations that affect the behavior or actions of a limited number of
entities (e.g., facilities or companies), labeling is designed to influence all consumers. In this
context, the definition of "consumers" encompasses all individuals and organizations making
purchase decisions regarding products and services, ranging from procurement officers of
governments and corporations to individual retail consumers. Environmental labeling often also
affects manufacturers and marketers as they design and formulate products that must compete
based on quality, price, availability and, to varying degrees, environmental attributes.
Current initiatives to harmonize programs worldwide and to establish labeling standards
recognize the diversity among the many types of environmental labels and the many programs
now active. Some programs highlight just a single attribute of a product, such as the recycled
fiber content of paper; others examine multiple attributes. Some programs, such as those
developing automobile fuel economy labels, are neutral (i.e., they make no comparisons among
similar products), while other programs attempt to identify environmentally preferable products
for the consumer. Some, such as the US Environmental Protection Agency's (EPA's) pesticide
labeling program, establish mandatory requirements (typically issued by the government as part
4 "G-7" consists of Canada, France, Germany, Italy, Japan, USA, and the UK.
Environmental Labeling: The US Perspective
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of statutory requirements), whereas other programs are operated by independent third parties and
are typically voluntary. Another form of labeling includes self-declarations made by
manufacturers. While many programs target the retail consumer, programs such as EPA's
Environmentally Preferable Products (EPP) program target institutional decision-makers, e.g.,
federal procurement officials.
Each of these labeling and program characteristics is closely related to the underlying
methodologies used to evaluate the products' environmental attributes. The most comprehensive
methodologies examine a product's entire life cycle, from material extraction, through
production, to use and disposal. Whereas there is no single established standard, life cycle
approaches are the most commonly used by labeling programs. Life-cycle approaches are usually
adopted due to the difficulty of selecting a small set of attributes to represent what are in fact
complex site-specific environmental consequences. Some programs, however, such as the US
Energy Star program, assess products on a life-cycle approach but look primarily at a single
characteristic of whether products meet energy-efficiency criteria.
Whereas much debate exists surrounding what constitutes an optimal program, and what
information and format are most useful to those making purchase decisions, all such efforts
contribute to the generation and dissemination of environmental information in the marketplace.
Furthermore, the increased amount of information regarding environmental attributes and
performance affects manufacturers upstream by pressuring them to take environmental attributes
into consideration when designing or manufacturing their products. Overall, the combined effect
is greater availability and use of such information in the US and in other marketplaces throughout
the world.
2.2. Environmental Labeling in the US
Much of the current research on environmental labeling programs focuses on the emerging third-
party environmental labeling programs. (Third-party labeling programs use an independent
source for their verification process.) Most of these programs are designed to either identify
environmentally superior products or to inventory the products' environmental impact or burden
categories (so that consumers can make such determinations themselves). While such programs
exist in the US and many foreign markets, they do not and cannot represent the full spectrum of
environmental labeling. In the US, such programs are relatively new compared to third-party
environmental labeling programs in other countries, which are typically run by governments.
Furthermore, there are tremendous differences among the missions of US programs. The
existing US government programs often exist to implement specific requirements of statutes or
regulations. For example, to be effective, hazard/warning labels typically are mandatory, and
usually only governmental authorities have the power to impose such requirements on all
products in the marketplace.
Environmental Labeling: The US Perspective
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From a domestic perspective, environmental labeling in the US encompasses over 20 programs.
In addition to the governmental warning labeling programs mentioned above, there are also:
*• federal government programs dealing with disseminating relative performance
information, such as the Energy Guide;
*• governmental and private programs establishing performance or attribute standards and
collecting information for decision-makers, although not necessarily involved in point-of-
purchase labeling;
> private third-party programs, issuing both neutral and positive labels;
> environmental marketing claims made by manufacturers and marketers with guidance
issued by the Federal Trade Commission; and
*• federal, state, and local hazard warning programs.
Taken collectively, the labeling activities and coverage (re: product categories) of these programs
play a substantive role in the US marketplace. The fact that US labeling is dispersed among
many different programs requires greater attention to coordination, particularly during bilateral or
multilateral harmonization and negotiations.
Since the creation of the Pesticide Labeling Program in 1947, EPA and its prior organizational
entities have been involved in product evaluation and the administration of an environmental
labeling program. Today, EPA is involved in 13 such programs, ranging from warning labels
under the Toxic Substances and Control Act to the development of standards, used in the
Agency's own Green Buildings and Energy Star programs and life cycle research for selected
products and processes. (A full list of these programs is presented in Chapter 4.) EPA is also
involved in other governmental programs, such as the Energy Guide for appliances, which is
administered jointly with the Department of Energy.5 Finally, EPA has contact in some form
with almost all environmental labeling programs, both foreign and domestic. Such contact
ranges from intermittent briefings and discussions, to exchanges of technical information used in
developing standards to joint participation in International Organization for Standardization
(ISO) activities.
Environmental labeling in the US marketplace is both active and wide-ranging. Consequently,
the model of a single centralized labeling program does not fit the US experience, nor is it
warranted, given the number of longstanding programs in existence and lack of a (federal)
mandate to consolidate such activities. Summary information and the interrelationships among
environmental labeling programs, both US and foreign, are examined in detail in the following
chapters.
5 All of these efforts involve research efforts, some of which resulted in published reports, such as the
Status Report on the Use of Environmental Labels Worldwide, The Use of Life Cycle Assessment in Environmental
Labeling, and Determinants of Effectiveness for Environmental Certification and Labeling Program.
Environmental Labeling: The US Perspective
-------
-------
3. Definition of Environmental Labeling
Labeling programs can be classified according to a number of program characteristics (see Chart
3-1). One of the most important is whether or not the program relies on first-party or third-party
verification.6 The former is performed by marketers on their own behalf to promote the positive
environmental attributes of their products.7 Programs relying on first-party verification are not
addressed in this report. Third-party verification is carried out by an independent source that
awards labels to products based on certain environmental criteria or standards. Environmental
labeling programs can also be characterized as positive, negative, or neutral. Positive labeling
programs typically certify that labeled products possess one or more environmentally preferable
attributes. Negative labeling warns consumers about the harmful or hazardous ingredients
contained in the labeled products. Neutral labeling programs simply summarize environmental
information about products that can be interpreted by consumers as part of their purchasing
decisions. Third-party environmental labeling programs can be further classified as either
mandatory or voluntary. Mandatory programs include hazard or warning labels, and information
disclosure labels. Voluntary labels are typically positive or neutral, and are further classified as
either report cards, seal-of-approval, or single-attribute certification programs. A classification
of each type of positive, negative, and neutral labeling program is presented on the following
page.
Verification refers to the process by which an assessment and/or verification determines that products and
services meet specified criteria or claims.
7 Attributes refer to certain unique characteristics of the product.
Definition of Environmental Labeling
-------
Chart 3-1: Classification of Environmental Labeling
Environmental Labeling
First-Party
Environmental Labeling Programs
Third-Party
Environmental Labeling Programs
Product-Related
\
Corporate-Related
/
/
/
/
/
Claims
(e.g., Recyclable)
On Products
or Shelf labels
Mandatory
Hazard or Information
Warning Disclosure
(e.g., Pesticides, (e.g., EPA fuel
Prop. 65) economy label)
/ i
Cause-Related / \
Marketing Cause-Related Promotion of
(e.g., "Proceeds Marketing Corporate Env.
donated to...") (e.g., Company Activity or
supports WWF) Performance
In Ads
Voluntary
Environmental
Certification
Programs
Report Seal of Single
Card Approval Attribute
Certification
10
-------
3.1. Positive Labeling Programs
Third-party verification programs are typically voluntary in nature and identify positive or
neutral environmental aspects of a product. Labeling programs focusing on the positive
attributes of a product are divided into two types: seal-of-approval (the most common) and
single-attribute certification programs. They are described below.
Seal-of-Approval Programs
Seal-of-approval programs award or license the use of a logo to products that the program judges
to be less environmentally harmful than comparable products, based on a specific set of award
criteria. The operation of each such program differs slightly, but in general they follow a three-
step process: product category definition, development of award criteria, and product evaluation.
First, product categories are chosen. These categories can generally be suggested by either
manufacturers or program officials. Once a product category has been decided upon, criteria are
set for receiving a label within that category.
These criteria are usually based on some form of life-cycle consideration, (not necessarily a full
life-cycle analysis (LCA)). There is usually a public review of program decisions. After criteria
are set, applications are received, candidate products are evaluated, and awards are granted. In
general, criteria are reviewed about every three years, and contracts have to be renewed. The
review process is designed to provide for a continuous tightening of award criteria, such that only
a small percentage of products will qualify for the label, thus providing an incentive for all other
product manufacturers to improve the environmental attributes of their products. It is a complex
task requiring the consideration of many factors, including environmental policy goals, consumer
awareness of environmental issues, trade positioning, effects on imports and exports, and
economic effects on domestic industry. Well-known seal-of-approval programs include
Germany's Blue Angel, Canada's Eco-logo, and the US's Green Seal.
Seal-of-approval programs tend to have similar administrative structures. In a typical program,
the government's environmental agency is involved to some extent. In some situations a
government agency administers the program; in others they simply provide informal advice or
funding. The bulk of the responsibility rests with a central decision-making board typically
composed of academics and scientists, business and trade representatives, consumer groups,
environmental groups, and government representatives. Technical expertise is provided by the
government, standards-setting organizations, consultants, expert panels, and/or ad hoc task forces
established to work on specific product categories.
Single-attribute Certification Programs
Single-attribute certification programs certify that claims made for a single-attribute of a product
meet a specified definition. Such programs define specific terms such as "recycled" or
"biodegradable" and accept applications from marketers for verification that their product
attribute meet the program definition. If the programs verify that the product attributes meets
their definitions, the program awards the use of the logo to the marketer. The primary single
Definition of Environmental Labeling 11
-------
certification program in the US is the Scientific Certification System's (SCS) Single Claim
Attribute Certification. Alternatively, programs can set definitions of claims and manufacturers
must meet these requirements. This is the case with the US Energy Star program, which sets
stringent energy-efficient standards that products must meet before being awarded the "Energy
Star."
3.2. Negative Labeling Programs
Hazard/Warning Labels
Hazard or warning labels are mandatory labels that appear on certain products containing
potentially harmful or hazardous ingredients. The purpose of such labels is to point out the
negative characteristics of the product clearly and encourage the safe use of potentially hazardous
products. Hazard or warning labels are typically mandatory programs that are initiated by a
third-party (e.g., a government agency), which require that information be disclosed to consumers
for health and safely reasons. Alternatively, manufacturers may voluntarily provide
hazard/warning information on their products for liability purposes.
Well known hazard/warning labels in the US include pesticide labeling under FIFRA, which
provides important warnings and advice for users; the Surgeon General's warnings on cigarettes;
and the skull and crossbones label on poisons. Warning labels specific to health hazards include
the State of California's Proposition 65 (see Program Summary Appendix for greater detail),
which requires chemicals known to cause cancer or developmental or reproductive toxicity to be
listed by the governor. Warnings must also be provided by businesses for a number of specific
reasons, which include intentional exposure of individuals to these listed chemicals at significant
levels.
Proponents of such disclosure warning labels claim that manufacturers will remove the offending
chemicals rather than suffer the market setbacks (e.g., adverse publicity and loss of market share)
that a hazard/warning label might cause. They argue that this approach provides a stronger
incentive to reformulate products (to avoid hazardous ingredients) than would a voluntary
environmental certification program. If true, the results/benefits of such an approach would be
more certain to cause marketplace shifts.
12 Definition of Environmental Labeling
-------
3.3. Neutral Labeling Programs
Information Disclosure Programs
Unlike hazard/warning labels, which identify negative attributes, information disclosure
programs are neutral. That is, the label contains summary facts that can then be used by
consumers in making their purchasing decisions. One important requirement of information
disclosure programs is that information needs to be simplified and comparable across products.
Since the facts disclosed are not always positive selling features and may not otherwise be
reported by marketers, information disclosure programs are usually mandatory. Unlike
hazard/warning labels, which usually are mandated for health and safety reasons, information
disclosure labels are developed because the program believes that consumers have the "right to
know" about the product.
Perhaps the best known information disclosure label is the US Food and Drug Administration's
(FDA) nutrition label. The food label must appear on most processed food sold in the US;
labeling of unprocessed fruits and vegetables is voluntary. Examples of environmental
information disclosure labels include the automobile Fuel Economy Information Program and the
Energy Guide program. The Fuel Economy Information Program is an EPA/Department of
Energy (DOE) initiative; the Energy Guide is an EPA initiative. The automobile Fuel Economy
Information Program requires that a label listing the mileage rating be affixed to all new cars and
trucks sold. Begun as a voluntary program in 1973, it soon became mandatory for auto makers to
report the mileage rating of new vehicles. The Energy Guide program requires that a label
disclosing energy consumption per year or an energy efficiency rating be affixed to certain
household appliances, such as refrigerators, refrigerator-freezers, freezers, water heaters, clothes
washers, dishwashers, furnaces, room air conditioners, central air conditioners, and heat pumps.
An interesting hybrid of the information disclosure label is the battery labeling program. This
program, administered by the EPA Office of Solid Waste, requires that a label appear on certain
batteries and rechargeable consumer products, stating the chemical name (nickel-cadmium or
lead) and the phrase "BATTERY MUST BE RECYCLED OR DISPOSED OF PROPERLY."
While this type of labeling is mandatory and presents neutral information (the chemical name), it
also notifies users/consumers of their legal obligation to dispose of the product properly.
Report Cards
The report card label, one type of information disclosure label, uses a standardized format to
categorize and quantify various impacts/burdens that a product has on the environment. Specific
and consistent information (for example, pounds of air emissions) is presented on the label,
allowing a comparison across categories. By providing the consumer with standardized detailed
information and little interpretation, the report card allows consumers to make judgments based
on their particular environmental concerns.
In the US, Scientific Certification Systems (SCS) has prepared an eco-profile that can be applied
Definition of Environmental Labeling 13
-------
to any product category. These eco-profiles are based on a life-cycle assessment (LCA), which is
the first step in the more comprehensive Life Cycle Stressor Effects Assessment (LCSEA). The
SCS eco-profile evaluation is a multi-step process involving the identification and quantification
of inputs and outputs for every stage of a product's life cycle including raw materials extraction,
material processing, manufacturing, distribution, use, and disposal. Based on the assessment,
three claims of achievement may be certified:
*• certified environmental state-of-the-art,
> certified environmental improvements, and
*• certified environmental advantages.
14 Definition of Environmental Labeling
-------
4. Overview of Labeling Programs Worldwide
4.1. Introduction
This chapter provides an overview of a variety of different types of labeling programs in the US,
and primarily voluntary, seal-of-approval, programs in other countries. The majority of the
overseas programs covered in this report are government- or quasi-government-run programs.
Typically, there is one such national (voluntary) labeling program in each country. In contrast,
the US, lacking such a national labeling program, has a variety of different types of programs in
operation. The US programs covered in this report include mandatory government programs,
voluntary seal-of-approval programs, single-attribute programs, hazard warnings programs, and
information disclosure programs. Charts are provided throughout this chapter to illustrate the
discussion; often, these charts are used to show the difference between the programs in the US
and the rest of the world.
Due to the scope of this report, not every labeling program that may be in existence today is
covered (e.g., food is not covered), and the report should not be seen as a comprehensive study of
all labeling programs worldwide. The report presents a "snapshot" of the major environmental
labeling programs in existence during the research phase and for which information was
available. Unless otherwise noted, the charts in this section include all programs surveyed as
part of this report.
Section 4.2 provides some fundamental information about labeling programs, such as label and
program type, how programs are administered and financed, and changes to programs over the
years. Section 4.3 includes several maps that show the geographic distribution of the labeling
programs covered in this report. Section 4.4 provides an overview of the reasons environmental
labeling programs are initiated, as well as the methodologies used by each program to establish
product categories and award criteria. A discussion of the ways in which environmental labeling
is being used today, either for procurement purposes or in trade, is given in Section 4.5. Section
4.6 provides a brief discussion of the changes that have occurred in labeling programs. Finally,
Section 4.7 describes the efforts countries are making to coordinate their environmental labeling
programs with each other.
4.2. Fundamental Information
This section helps to define the basics of existing environmental labeling programs by
summarizing information and characteristics fundamental to each environmental labeling
program. Characteristics discussed include program and label type, program administration,
financing, and age, as well as number or range of product categories and awards. It should be
noted that certain program characteristics are frequently linked. For example, programs
identifying negative product attributes are, by necessity, mandatory. Furthermore, mandatory
Overview of Labeling Programs Worldwide 15
-------
programs are typically administered by governments, since environmental regulations may
provide them with the authority to require mandatory labeling. In the case of the State of
California's Proposition 65, considered to be a hazard warning program, businesses that
knowingly expose individuals to any of a list of chemicals are required to provide a warning of
such exposure. Most seal-of-approval programs, however, are third-party and voluntary. As
their name implies, such programs award labels for (relative) positive environmental attributes.
For a listing of the programs covered in this report, refer to the overview table in Appendix A.
For detailed summaries of the programs contacted and included in this report, refer to the reports
in Appendix B.
Program Type
The programs reviewed issue one of three kinds of labels: positive, negative, or neutral. Most of
the programs discussed in this report award positive labels indicating to the consumer that the
environmental attributes of the labeled product in some way outperforms the environmental
attributes of other similar products. Certification of the positive environmental attributes of a
product provides manufacturers with an incentive to apply for an environmental label in the
hopes of capturing more market share and improving corporate goodwill.
Negative labels, on the other hand, are typically required by law and are used to present the
hazards associated with use and disposal of the product. For example, Vermont's Household
Hazardous Product Shelf Labeling Program requires all retailers stocking household products
containing hazardous constituents to identify those products via a shelf label. Given that most
regulations establish guidance only, mandatory labeling programs require a statement of fact, and
do not necessarily result in a comparable labeling format or information across products. In
addition, differing requirements across jurisdictions for mandates that are not updated to reflect
the current state of the economy can result in clutter on the label and/or higher labeling costs for
marketers.
Neutral labels, such as the US Energy Guide, simply report summary facts about the product and
allow consumers to make their own judgments based on their particular concerns. Such labels
can also provide information for manufacturers and others who may use the information for
internal use (e.g., benchmarking studies). The container's size, however, may dictate how much
neutral label information can be included.
16 Overview of Labeling Programs Worldwide
-------
As shown in the following chart, there is an fairly even split in the number of positive, negative,
and neutral US programs covered in this report. As mentioned above, however, the majority of
other countries' programs covered in this report are positive programs, reflecting the fact that
most of these are seal-of-approval programs (see Chart 4-1).
Chart 4-1: Program Type
(based on programs reviewed)
Overview of Labeling Programs Worldwide
17
-------
Participation
Participation in labeling programs can be either mandatory or voluntary. This report includes
voluntary programs worldwide and mandatory and voluntary programs in the US; due to the
scope of this report, not every existing program was surveyed. Of the programs surveyed, most
are voluntary (this is exclusively so for the programs outside the US). US programs covered in
this report are fairly evenly split between mandatory and voluntary programs (see Chart 4-2).
Chart 4-2: Participation in Labeling Programs
(based on programs reviewed)
Participation
Mandatory
Voluntary
With voluntary programs, manufacturers choose to participate in a program and typically submit
an application for a specific product to be labeled. To encourage manufacturers to participate,
emphasis is placed on the positive attributes of a product. Because these programs are propelled
by their market influence, manufacturers apply for a label when it increases their product's
marketability as well as their competitive edge.
Mandatory programs, on the other hand, can require the identification of negative product
characteristics, and are typically one element of a regulatory approach to consumer and
environmental protection. For example, the US battery labeling requirements mandate that
rechargeable cadmium and/or lead batteries carry labels that inform users of the contents of the
batteries and indicate that batteries must be recycled and/or properly disposed. Whether or not a
program is mandatory or voluntary will influence the extent and type of information about
environmental attributes on labels in the marketplace. Typically, mandatory programs result in
more comprehensive dissemination of information in the marketplace, since all similar products
are required to carry a label.
18
Overview of Labeling Programs Worldwide
-------
Label Type
The types of labels awarded by programs fall into the following categories: seal-of-approval,
single-attribute, hazard warning, information disclosure, and report card. Most programs
discussed in this report award "seal-of-approval" labels; they license use of a seal (label) for one
or more superior product characteristics. These programs generally evaluate multiple attributes of
a product and employ some form of life-cycle assessment (LCA) to evaluate the environmental
impacts of the product. (LCA is a process that encompasses consideration of all aspects of the
manufacture of a product from natural resource extraction to product disposal.)
Some of the programs contacted analyze only a single product attribute and award a label
certifying the environmental preferability of only that attribute. For example, Germany's Green
Dot program certifies that packaging manufacturers participate in an established source reduction
or recycling program for consumer packaging waste. As mentioned above, hazard warning
programs identify the negative attributes of a product and are generally mandatory. Finally,
information disclosure programs and report cards both present neutral summary information on
an established set of environmental attributes.
The choice of label type by program will have an effect not only on the level of information
consumers receive about environmental attributes, but on the way in which they are likely to
interpret this information. For example, single-attribute labels provide information on only one
environmental attribute. Report card labels provide information on a number of environmental
attributes. While the single-attribute label may suggest to the consumer that the product has an
environmentally preferable attribute, this may not be the attribute that the consumer cares most
about. Alternatively, while the report card label may present information on all the attributes the
consumer cares about, the consumer may not be able to judge the overall environmental
preferability of the product. To better understand the relationships among label type,
participation and program type, Table 4-1 compares the associations among these various
categories.
Overview of Labeling Programs Worldwide 19
-------
Positive
Neutral
Negative
Table 4-1: Participation by Program and Label Type
Mandatory Voluntary
N/A
Information Disclosure
Hazard warning
Seal-of-approval
Single-attribute
Report card
N/A
The majority of programs contacted for this report are seal-of-approval programs. This is
overwhelmingly so for the overseas programs; 30 out of the 33 overseas programs covered in this
report are seal-of-approval programs. Though the majority of US programs included in this
report are also seal-of-approval programs, they exhibit a greater variety of label type. This may
be a reflection of the fact that the US does not have a national third-party labeling program,
whereas seal-of-approval programs are the national program for many of the other countries (see
Chart 4-3).
Chart 4-3: Programs Reviewed, by Label Type
o>
o.
0>
_Q
03
oecai ui /-vppiuveu
Single Attribute
Hazard Warning
Report Card
Information Disclosure
Other
^^"
4
^^"
-
• 1
— 3
9
•6
30
0 5 10 15 20 25
# of Programs in this Report
30
Legend
Outside US •
US
20
Overview of Labeling Programs Worldwide
-------
Administration
Programs are sponsored and/or administered by governments, private companies (for profit and
non-profit), non-governmental organizations, or some combination of the above (quasi-
governmental). This is true for both US and non-US programs. A program is defined as quasi-
governmental if two or more groups are involved in the administration of the program and one is
a governmental entity. Frequently, programs are considered quasi-governmental because they
were started by or are supported by a government, while also relying on a private company to run
their daily activities. Among those included in this report, the US is dominant in programs that
are privately run. Green Seal and SCS are examples of programs run by private companies. The
distribution of programs included in this study by administration type can be found in the chart
below (see Chart 4-4). Programs' administrative bodies affect the longevity of the program in a
number of ways. The administrative body often provides (or can provide if necessary) the
financial backing and other resources (e.g., office space, supplies) for the program. Thus,
governmental or quasi-governmental-backed programs are expected to survive in the long run
due to the possibility of other formal and informal subsidies. Similarly, non-governmental
organizations (other than private companies), such as a National Standards Institute, may also
have other operations or resources from which the labeling program may draw. Of the programs
contacted for this report, most are run by governments; very few are run by private organizations.
Chart 4-4: Programs by Organization Type
(based on programs reviewed)
Government
Private-Nonprofit ^^m .
o
'•§
• S Private-For Profit
OS
&B
^ Non-Govt Org
Quasi-Govt
0 2 4 6 8 10 12 14 16
# of Programs in this Report
I US
D Outside US
Overview of Labeling Programs Worldwide
21
-------
Financing
Many labeling programs are not yet fully self-sufficient, and require additional financing to cover
their operating costs. Programs are financed a number of ways (see Chart 4-5). They can be
financed by the government, by fees collected for their services, by revenue streams from other
operations, by other sources such as payment from private companies and donations from private
and public organizations, or by a combination of any of these. As shown in the figure below,
fees and government funding are the major sources cited by those programs contacted for this
study. Those programs funded solely by fees may have a somewhat higher credibility risk
because of the inherent conflict between independent selection of product categories (and setting
of award criteria) and the need to generate revenue (i.e., have customers for licenses) to cover
both fixed and operating costs. Yet, even those programs that are government subsidized have
stated goals of financial self-sufficiency.
Chart 4-5: Programs by Financing Source
I
o
C/)
'o
c
(C
Govt Funding
Fees
Govt Funding & Fees
Private
Fees & Member Dues
(based on programs reviewed)
3
02468
# of Programs in this Report
10
Outside US
US
Year Founded
The year the program was founded establishes a timeline of environmental labeling program
formation. Programs that began in the early 1970s and pre-1970 are primarily US programs.
The exception is Germany's Blue Angel program, the oldest seal-of-approval program in
existence. The US programs that began in these early years of environmental labeling are the
Energy Guide, the Fuel Economy Information Program, the US EPA Pesticide Program (FIFRA),
which began in 1947, and EPA's toxic substances control program under the Toxic Substances
22
Overview of Labeling Programs Worldwide
-------
Control Act (TSCA). Most of these are mandatory programs (with the exception of Energy
Guide and Fuel Economy, which are both information disclosure programs), and were initiated
by the US government when it became evident that health and safety information, particularly
about agricultural pesticides, had to be conveyed to consumers. The recent growth in
environmental labeling is illustrated in Chart 4-6, which presents the start-up year of programs
included in this report.
Chart 4-6: Number of Programs Founded by Year
(based on programs reviewed)
Pre-1970 1970-1979 1980-1989
Year
1990-1997
US
Outside US
Overview of Labeling Programs Worldwide
23
-------
Product Categories
The number of product categories covered helps to identify the size and scope of a program, as
well as the program's stage of development and how long it has been in existence. The
following chart (see Chart 4-7) indicates the current number of product categories covered by
each program surveyed in this report. Note that this chart includes only seal-of-approval
programs that are already developed; other types of programs tend to only have one or two
product categories and are therefore not as relevant to this breakout. The number of categories
currently ranges from fewer than 10 (10 programs) to more than 50 product categories (3
programs). It should be noted, however, that all programs are continually developing product
categories. As programs are increasingly sharing more information, the rate of product category
definition and criteria development is rising.
Chart 4-7: Product Categories in Seal-of-Approval Programs
(based on programs reviewed)
12
6
2
f 4
<10 11 to 20 21 to 50 >50
Number of Product Categories
The types of products for which criteria are developed also varies. Appendix B contains a
detailed list of product categories for each program summary. The most prevalent categories are
paper products (including towels, toilet paper, office paper), detergents, office equipment, and
dishwashers. (Selection of such categories reflects products for which the environmental impacts
have been studied in detail over time.) It is relatively easy for programs to adopt standards for
these categories, hence their occurrence in almost all environmental labeling programs. Less
typical categories usually reflect the particular needs or conditions of individual markets. For
example, to accommodate one of its largest export products, India's Ecomark program is
considering the establishment of a category for leather goods. In Japan, standards have been
developed for fusuma and shoji paper made from recycled pulp. In Germany, because of a
sensitivity to noise pollution, standards have been developed for products that generate
comparatively less noise, such as low-noise construction machines, low-noise compost choppers,
and low-noise mopeds.
24 Overview of Labeling Programs Worldwide
-------
Number of Awards
The number of awards conferred by a program depends on how many product categories it has
established and how long it has been in existence. For example, long-standing, well-established
programs such as Germany's Blue Angel have had years to select product categories, develop
criteria, and garner support among manufacturers, government, and consumers. Programs such as
these may have bestowed thousands of awards. Such programs are well known in the
marketplace and thus will have the potential for reaching many consumers. Moreover, these
programs may have gone through several criteria revisions and thus added product categories
over time. A strong market presence may encourage programs to set higher standards, thus
creating incentives among manufacturers to continue to strive for improvement in their products.
New programs have had little time to establish product categories and criteria or award many
labels. If a program has little visibility, manufacturers may not have an incentive to apply for the
label, thus reducing the number of labels that a program will be able to award. Also, the cost to
apply for the label will likely affect the number of awards bestowed. To encourage more people
to apply for the GreenLabel, the Singapore Ministry of the Environment bears all the costs of the
program, thereby minimizing the manufacturer's fees. The results have been that manufacturers
have applied for the GreenLabel in relatively large numbers; over 700 products have been
awarded the label. The US SCS program, which has been in existence since 1984, now has over
400 growers who have applied for their products to obtain the SCS Nutriclean label.
The following chart indicates the current number of awards given by the developed seal-of-
approval programs (see Chart 4-8).
Chart 4-8: Number of Awards in Seal-of-Approval Programs
(based on programs reviewed)
12
<20
21-50 51-150 151-500
Number of Awards
501-1000
>1000
Overview of Labeling Programs Worldwide
25
-------
Differences in the number of labels awarded may also be due to differences in "accounting"
practices. While most programs count a product receiving an award (e.g., Company X's recycled
paper product) as one award, other programs count an awarded company as one award (e.g., even
though Company X may have an award for two of their products, towels and copier paper, they
are only counted once). Other programs count each awarded product that sits on the shelf as one
award (e.g., each labeled package of recycled paper is counted once).8
4.3. Geographic Representation
The following maps identify information about the major programs in each country. Figure 1
locates each program covered in this report on a world map. Figures 2, 3, and 4 divide the world
into three regions (Europe, Pacific Rim, and North and South America) and provide the country
name, program name, and whether the program is part of the European Union (EU), a G7 nation,
or both.
This report does not count the total number of products sold or total number of companies receiving a
license as the number of awards per program.
26 Overview of Labeling Programs Worldwide
-------
Figure 2: Positive and Neutral Third Party Ecolabeling Programs Worldwide
Covered in this Report
-------
-------
Figure 3: Positive and Neutral Third Party Ecolabeling Programs in Europe
Country 1 Program
Austria
Croatia
Czech Republic
Denmark
Finland
France
Germany
Greece
Iceland
Italy
Luxembourg
Netherlands
Norway
Portugal
Spain
United Kingdom
Austrian Ecolabel
Croatia's Environmental Label
Czech Ecolabel
Nordic Swan
Nordic Swan
NF-Environment Mark
Blue Angel & Green Dot
EU Ecolabelling Scheme
Nordic Swan
EU Ecolabelling Scheme
EU Ecolabelling Scheme
Stichting Milieukeur
Nordic Swan
EU Ecolabelling Scheme
AENOR Medio Ambiente
EU Ecolabelling Scheme
DenmarkC7 /^/vnx
(EU) S f VjL-
^ Netherlands
United4- -A ^vv^
Kingdom
Covered in this Report
-------
-------
Figure 4: Positive and Neutral Third Party Ecolabeling Programs in the Pacific Rim
Country
Program
China
India
Indonesia
Japan
Malaysia
New Zealand
Singapore
South Korea
Taiwan
Thailand
Ecolabeling Program
India's Ecomark
In Development
Japan's Ecomark
Product Certification Program
Environmental Choice
Green Label
Korea's Ecomark
Green Mark Taiwan
The Thai Green Label Scheme
>
JL
Singapore^
(\^NTX) Malaysia^
iN" '
Indonesia
~? \
New
Zealand
1-
Covered in this Report
-------
-------
Figure 5: Positive and Neutral Third Party Ecolabeling Programs in North & South America
Country | Program
Brazil
Canada
United States
ABNT - Environmental Quality
Canada's Environmental Choice Program
Ecotel, Energy Guide, ECO-O.K., Scientific
Certification Systems, Chlorine Free
Products Association, Battery Labeling,
Green Star & Energy Star
Covered in this Report
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4.4. Program Methodology
This section describes the various reasons for which environmental labeling programs are
initiated, as well as the methodologies used by each program to establish product categories and
develop award criteria. A discussion of stakeholder involvement in this process is also
presented; such involvement is key to the transparency and nondiscrimination called for in draft
ISO standards. Similarities or differences between adopted methodologies will influence the
extent to which programs will be able to standardize or mutually recognize their operations with
those of other programs. The analytical methodologies employed by programs are also closely
linked to programs' credibility.
Program Goals
All environmental labeling programs aim to improve some aspect of environmental quality in
their respective countries by reducing pollution. Typically, they are formed with the country's
specific environmental improvement goals and needs in mind. In general, environmental
labeling programs work toward this goal by recognizing manufacturers that produce and market
products that are (relatively) less harmful to the environment and by encouraging consumers to
purchase products labeled as environmentally preferable. If consumers buy environmentally
preferable products due to label information, it's hoped that market forces will encourage other
producers to change their manufacturing procedures to reduce environmental harm. For
example, Canada's TerraChoice program seeks to "reduce the stress on the environment by
encouraging the demand for and supply of environmentally responsible products and services."
Another common goal expressed by environmental labeling programs is to educate consumers
and increase environmental awareness. It is hoped that through widespread visibility of
environmental labels, consumers will be educated, and information will be disseminated
regarding environmentally preferable products and "green consumerism." Japan's Ecomark, for
example, seeks to "disseminate information on the environmental aspects of products and to
encourage consumers to choose environmentally sound products." Similarly, Singapore's
GreenLabel specifically seeks to "promote green consumerism and increase environmental
awareness." The EU program sees its role as an information disseminator, responsible for
formulating a consensus standard across EU markets.
Some programs have focused their environmental improvement or consumer education/
information dissemination goals by addressing specific environmental problems. For example,
the US Energy Star program seeks to reduce air pollution by reducing the burning of fossil fuels.
Energy Star is pursuing this goal by encouraging the production and use of energy- efficient
products that require less electricity. Many of the mandatory programs have narrower, specific
environmental goals and target specific environmental issues. For example, the US EPA's
mandatory Ozone Depleting Substances label warns consumers of products manufactured with
Overview of Labeling Programs Worldwide 35
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ozone-depleting substances and their harmful effects. Similarly, the State of Vermont's
Hazardous Household Products Shelf Labeling program seeks to reduce the use of toxic
substances by identifying household products containing one or more of a list of hazardous
chemicals. A missions/goals summary is presented in Table 4-2.
Table 4-2: Missions/Goals Given for Programs
Covered in this Report
Program Characteristic
Program missions/goals
Number of Programs that Report this
Mission/Goal
Promote production and use
of environmentally preferable products -
Information dissemination/education - 8
Target specific environmental problems
19
- 12
Note: Numbers of programs reporting these missions/goals are not mutually exclusive.
Program Methodologies
A program's evaluation method is one of its most important features, because it reflects the
scientific basis, data sources, and judgment on which product categories are chosen and which
label award decisions are made. Most programs rely on some form of life-cycle assessment
(LCA) to choose product categories and develop criteria for awarding labels. Full LCA is very
detailed, evaluating all aspects of the production process including raw material extraction,
manufacture, transportation, use of the product, recycling, and disposal. Because LCA
encompasses the entire production process and beyond, it is often too expensive and time-
consuming to conduct a full, in-depth LCA. Programs will often, therefore, consider only the
stages of LCA that they find most relevant to their needs. France's NF-Environnement Mark
program utilizes a simplified LCA that identifies the "key stages" in the product's life cycle —
those stages expected to have the most significant environmental impacts. Product criteria are
based on these key stages. Detailed discussions of program methodologies are included in each
individual program summary.
One alternative methodology used by a number of programs evaluates a single environmental
attribute (for example, whether or not the product is recyclable), rather than the product's entire
life cycle. For example, the US Energy Star program evaluates products based on whether they
36 Overview of Labeling Programs Worldwide
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meet Energy Star's energy efficiency standards. This method, however, is not as complete as
LCA. Not only are fewer attributes analyzed, but a product receiving a label for a single attribute
may in fact have an overall negative environmental impact due to its other attributes. The
number of programs by product evaluation methodology (based on their own descriptions) is
shown in Chart 4-9.
Chart 4-9: Programs by Methodology
(based on programs reviewed)
LCA
§5 Modified LCA
"o
|i Single Attribute
Other
0
5 10 15 20
# of Programs in this Report
25
Procedurally, any methodology may include independent testing and studies conducted by
programs themselves to determine the environmental impacts of product categories or individual
products. Such efforts lower the cost, reduce the time needed, and increase harmonization
among the analyses of similar products across programs. Many programs report that literature
reviews and studies conducted by other programs, as well as information about specific product
categories contributed by participating manufacturers, are often used in combination with LCA to
establish award criteria. In certain cases, programs may adopt each others' award criteria, with
modifications. For example, Canada's Environmental Choice program has exchanged
information with both the Taiwan program and the US Green Seal program and has adopted
product standards from these programs.
Overview of Labeling Programs Worldwide
37
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Stakeholder Involvement
Stakeholder involvement in the environmental labeling process can occur at three stages:
program formation, product category selection, and criteria development. Stakeholders generally
consist of representatives from outside groups, such as domestic and foreign manufacturers,
academia, consumer groups, and environmental groups. The general public may also have the
opportunity to provide input. The extent of stakeholder involvement provides insight into the
level of transparency actually provided by environmental labeling programs. Stakeholder
involvement indicates the degree to which programs might be influenced by particular groups or
balanced by including the needs of all interested parties.
Most programs (in this case third-party programs) allow an open process by which any interested
stakeholders may submit proposals for product categories. Product category selection, however,
is usually made by the programs' governing bodies, which typically consist of a limited
representation of interested stakeholders (see Chart 4-10). Many programs do solicit stakeholder
involvement during development of product award criteria. In some programs, draft criteria are
published and comments accepted from the public. Very few programs, however, publish
stakeholder comments and program responses for further public review before finalizing award
criteria. The United States' Green Seal program is an example of a program that does make
stakeholder comments and the program's responses available to the public, but it does so only as
an accompaniment to its already published final award criteria.
Chart 4-10: Programs by Stakeholder Involvement
(based on programs reviewed)
Program Formation
o>
"o
(D
2
o
Product Selection
Criteria Development
24
31
to Involved, Stage Unspecified
0 5 10 15 20 25 30 35
# of Programs in this Report
38
Overview of Labeling Programs Worldwide
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Some programs that claim to have an open stakeholder involvement policy have been accused by
manufacturers of the contrary. For example, some Indian industries have complained that India's
Ecomark has not done enough to involve them in product criteria development, and feel the
Indian Government has "rushed through" the Ecomark development. Additionally, Indian
exporters feel that many of the product categories chosen for Ecomark do not reflect India's
major export products, and that Ecomark has adopted the ecolabeling standards of their export
customers' countries in order to operate in those markets.
4.5. Program Breadth
Program breadth can be illustrated by the following characteristics: whether product evaluations
include non-environmental as well as environmental attributes, whether the label is used in
procurement programs, whether the label is awarded to pre-retail and/or retail products, and
whether the organizing body engages in other programs or activities. The extent to which
programs are visible in the market will influence the success and growth of programs.
Use of Non-Environmental Attributes
Some programs (see Chart 4-11) incorporate social and other conditions in their product criteria.
For example, the ECO-O.K. program run by Rainforest Alliance includes criteria for
environmental education programs, improvement of social and work conditions, and compliance
with human rights legislation. India's Ecomark program also considers non-environmental
attributes when evaluating products. In addition to complying with product-specific criteria,
manufacturers must show that their products are also in compliance with India's Bureau of Indian
Standards' product quality standards.
Overview of Labeling Programs Worldwide 39
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Chart 4-11: Programs that use Non-environmental Attributes
(based on programs reviewed)
Programs that use Non-environmental Attributes
By including non-environmental attributes in their award criteria, programs broaden the type of
information they provide to consumers, and thus may appeal to a wider range of consumer
concerns. The impact of such a broadened scope can be greatest in developing countries where
worker rights and basic living conditions may be of greater concern. Such programs may be
subject to criticism if the criteria for non-environmental attribute(s) are more qualitative than
quantitative in nature, which is often the case when standardized methodologies have not been
established.
Use in Procurement
Governments and large organizations are increasingly considering environmental attributes of
purchased goods and services. In the case of governments, the purchaser's mandate or mission
also includes stewardship of environmental quality. Also, incorporating environmental attributes
either benefits the organization directly (e.g., reduced costs over the life of purchased goods) or
indirectly (e.g., corporate goodwill among stockholders or customers). The use of environmental
labels by procurement programs (i.e., larger customers) typically increases the market presence of
the labeled products and enhances the credibility of the labeling program. This has been the case
with the Energy Star-labeled office equipment program. Initially, the US government mandated
that all federal offices stock Energy Star-labeled office equipment, but as the demand for these
products grew it became evident that not only were government agencies buying these products,
but so too were private organizations.
40
Overview of Labeling Programs Worldwide
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Where procurement programs use labeling programs in their activities, the relationship may be
formally acknowledged or used informally. In a formal arrangement a program's label is
specifically mandated or referenced by the procurement program. For example, governments
frequently have mandates to "buy recycled" or to buy green products. An example of a formal
arrangement in the US is Executive Order 12845 - Requiring Agencies to Purchase Energy
Efficient Computer Equipment, established to ensure that "all acquisitions of microcomputers,
including personal computers, monitors, and printers, meet 'EPA Energy Star' requirements for
energy efficiency." Similarly, Taiwan is in the process of establishing a "Government
Procurement Policy" that would require government agencies to buy products labeled with
Taiwan's Green Mark label. More often, informal relationships are formed.
Large institutions may also include environmentally-labeled products in their goods and services
selection. For example, large companies in the Nordic countries have procurement policies that
require the purchase of products labeled with the Nordic Swan or its equivalent. In addition,
some retailers are actively seeking out environmentally preferable products to offer to their
customers. In some cases, they specifically seek out labeled products. The large US home and
garden equipment retailer, Home Depot, and the United Kingdom's largest do-it-yourself home
products retailer, B&Q, each consider environmental attributes in their product evaluation and
selection. These stores plan to or do stock environmentally preferable alternatives whenever
possible. Chart 4-12 indicates whether the labels (usually seal-of-approval labels) from the
programs in this report are used in procurement programs, and whether the relationship between
the labeling program and the procurement is a formal or informal one. As seen in the chart, the
majority of the US programs are not used by procurement programs, perhaps because many of
the programs are mandatory government programs and thus establish a regulatory floor for all
products in the US market place.
Overview of Labeling Programs Worldwide 41
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Chart 4-12: Number of Programs Used in Procurement
(based on programs reviewed)
Used in Procurement
Yes (19)
Formal
US
1
Outside
US
7
Informal
US
3
Not Specified
Outside
US
10
us
2
Outside
US
2
Use Beyond Retail
Although environmental labels are most typically applied to retail products, they are also used in
non-retail applications. In general, retail products are intended for sale to individual customers
and are distributed through retail outlets located near the consumer. The majority of US
programs use environmental labels on retail products only. Pre-retail transactions involve trade
between, for example, raw material suppliers, product manufacturers, formulators/packagers, and
wholesalers. The two most prevalent uses of environmental labeling for non-retail consumers are
commercial enterprises and procurement programs (of governments and large organizations). All
of the programs surveyed for this report target their label to retail products. A number of
programs, however, also apply their label on pre-retail products (or both retail and non-retail
products). When labels are used on pre-retail products, labeling information may inform and
influence the purchasing decisions of upstream consumers and may affect the visibility of labeled
products in the marketplace. For example, if retailers buy products based on environmental
characteristics, then the presence of environmentally preferable products in the market is
increased. For example, several programs do or will provide guidelines for the sustainable
production of timber (e.g., Malaysia and SCS' Forest Conservation Program), certifying the
management of particular forest tracts as environmentally sustainable. Once a forest is eco-
certified, the timber and the subsequent lumber and wood products can be labeled as being
environmentally preferable, as long as it can be determined that the wood came from the original
42
Overview of Labeling Programs Worldwide
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certified forest. This information may affect many purchasing decisions as it is passed from
seller to customer, possibly to the retail level. Chart 4-13 shows the breakdown of whether labels
are being used on retail products, non-retail products or both.
Chart 4-13: Use on Retail/Non-retail Products
(based on programs reviewed)
Use on Retail Products and/or Non-retail Products
Retail
Both
us
19
Outside
US
30
US
9
Non-retail
Outside
US
1
US
9
Outside
US
1
Overview of Labeling Programs Worldwide
43
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Other Programs/Activities
Other support activities such as public education, and involvement and cooperation with related
programs and activities, can be important in increasing peoples' awareness of labeling programs.
Support activities enhance visibility of environmental labeling in the marketplace. For example,
the Vermont Household Hazardous Product Shelf Labeling Program has a consumer education
program aimed at prompting consumers to avoid purchasing hazardous products. The Vermont
Agency for Natural Resources has developed brochures and posters for both consumers and
retailers and has, in the past, launched media and advertising campaigns at recycling depots,
schools, and businesses, to educate people about the program. In addition, programs associated
with or involved in other activities may have a greater financial and resource base on which to
draw. The Scientific Certification System (SCS) provides a variety of other services besides its
Eco-profile label. As part of its NutriClean program, SCS provides importers with testing and
quality management services so that they can apply for US Food and Drug Administration (FDA)
certification more quickly, as well as similar services for US produce exporters so that they can
comply with regulations in their importing country. Green Seal receives grants for education and
outreach programs as well as independent research, in conjunction with their labeling program.
Direct and indirect subsidies help strengthen the position (e.g., by defraying costs) of the
environmental labeling program. The tendency for US programs to incorporate other activities
into their labeling programs is much stronger than for non-US based programs (see Chart 4-14).
Chart 4-14: Programs With Other Activities
(based on programs reviewed)
Programs With Other Activities
Such activities can also include coordination with labeling programs in other countries. For
example, Canada's TerraChoice has started a new program called the Environmental Technology
Verification (ETV) Program, which is being coordinated with US governmental agencies. (ETV
44
Overview of Labeling Programs Worldwide
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expects to issue "certificates of authenticity" to environmental technologies under the new
program. TerraChoice has thus broadened the scope of its activities, an additional labeling
program, and has increased its interaction with US stakeholders and customers.) Similarly,
Malaysia's Product Certification Program has developed an Environmental Management System
(EMS) certification program with reciprocal arrangements with foreign certification programs in
countries that trade with Malaysia. Malaysia coordinates with the Japanese Audit and
Certification Organization, and EMS certifies Japanese companies that export to Malaysia. This
program also works with the Canadian Standards Association (CSA); Malaysian companies are
inspected by the Standards and Industrial Research Institute of Malaysia (SIREVI) in accordance
with CSA requirements and are granted CSA's EMS certification. Of course, some
environmental labeling programs are administered by national standards institutes (e.g., France,
Sweden), which have a wide range of activities.
4.6. Changes to Environmental Labeling Programs
As programs develop, some have experienced significant changes while others have remained
virtually the same. An overview of these changes illustrates how programs are responding to
stakeholders and may indicate the future direction of these programs. Slightly less than half (23)
of the programs covered in this report (including seal-of-approval, hazard warnings, information
disclosure, and single-attribute programs) indicate that they have made significant changes to
their programs. Many of these programs have made minor changes, associated with normal
operation, such as increasing (or decreasing) the number of product categories or number of
products reviewed.
Perhaps the most significant changes occur when a program alters or revises the methodology by
which it chooses product categories and sets award criteria. Some programs, such as France's
NF-Environnement Mark, have simplified their methodology from a full LCA to a simplified
analysis that concentrates on what the program determines to be the most important stages of a
product's life-cycle. France made this revision primarily due to cost considerations. A number
of other programs have undergone administrative changes. Both the Canadian TerraChoice
program and Taiwan's Green Mark program have changed hands from government-funded and
administered programs to programs that are run by independent private companies. This
administrative change suggests that governmental involvement is more beneficial in the early
phases of program development; once a program is established, it may be more efficiently or
effectively run by a private company. Interestingly, in the case of Taiwan, it is hoped that the
shift to an independent company will mean that there will be more flexibility to participate in
international coordination efforts, which the government was not doing.
Other programs, perhaps best exemplified by the European Union's environmental labeling
program, have made efforts to engage in international standardization and harmonization efforts.
The EU program has proposed several revisions to incorporate international trade principals in an
effort toward mutual recognition of other environmental labeling programs, both within and
Overview of Labeling Programs Worldwide 45
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beyond EU borders. In this regard, the program has increased compatibility between the EU
label, national programs of EU member countries, and draft ISO standards.
4.7. Coordination Efforts Among Programs
Many of the programs contacted for this report are trying to incorporate the interests of other
countries into their activities by sharing information and pooling resources with other programs,
as well as investigating mutual recognition of foreign labels and assisting foreign manufacturers
seeking labels. The number of foreign-based licensees listed in the chart (see Chart 4-15)
provides some indication as to the degree to which programs included in this report have
extended their sphere of influence beyond domestic borders, and whether it is feasible for foreign
manufacturers to compete for the environmental label.
Chart 4-15: Programs with Foreign-based Licenses
(based on programs reviewed)
Programs with Foreign-based Licenses
Yes
No
46
Overview of Labeling Programs Worldwide
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The second chart (see Chart 4-16) indicates how many programs included in this report are
coordinating labeling activities with one or more programs in other countries.
Chart 4-16: Programs that Indicate
Working with Other Countries
(based on programs reviewed)
Programs that Indicate Working
with Other Countries
Yes
No
Such coordination can take the form of sharing information, product category justification, award
criteria or standards, or mutually recognizing labels, among others. For example, several
programs indicated that a part of their methodology is to review other programs' criteria when
setting their own. Programs in developed countries are also making a point of reaching out to
programs that are in start-up stages in developing countries. For example, TerraChoice is
specifically working toward mutual recognition of award criteria with Taiwan through
standardization of operations based on ISO standards, mutual recognition of non-product-related
impacts, and cooperation in auditing, verification and testing. It should be recognized that the
effort spent on such coordination varies widely among programs.
Another indication of inter-program coordination is participation in ISO, which was founded in
1947 and has representatives from 130 countries. ISO's main goal is to standardize products and
activities worldwide to promote international exchange of goods and services. It also aims to
foster global communication and cooperation over intellectual, scientific, technological, and
economic matters. ISO standards on environmental labels and declarations state that
environmental labels should communicate accurate and verifiable information about the
"environmental aspects of products and services in order to encourage the demand and supply of
those products and services that cause less stress on the environment, thereby stimulating the
Overview of Labeling Programs Worldwide
47
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potential for market-driven continuous environmental improvement."9 Programs that are
members of ISO or have adopted ISO guidelines have made a commitment to working toward
standardization and thus coordination among programs. Participation in the ISO standards
development itself involves significant inter-program communication. In addition, other
interested parties, such as trade, consumer, and environmental organizations, participate in ISO
standards developments and may aid or provide guidance in evaluating labeling programs'
operations. Chart 4-17 illustrates the number of programs that indicated that they are making
efforts to coordinate with ISO standards.
Chart 4-17: Programs that Participate in ISO
(based on programs reviewed)
Programs that Participate in ISO
Yes
No
4.8. Trade Issues
Trade issues have sometimes been raised in connection with environmental labeling programs.
This report does not discuss trade issues in full, but provides an overview of the discussion
surrounding this issue. Some concerns have been expressed about potential conflicts between
provisions of international trade agreements and certain aspects of environmental labeling
programs. The World Trade Organization (WTO) Agreements contain provisions precluding
discrimination among "like products." Some interpret these provisions as precluding
consideration of (a broader set) of factors, beyond the physical characteristics of the products, as
a basis for distinguishing among products. Many environmental labeling programs, however, as
part of their life-cycle approach, rely on consideration of such a broader set of factors in
ISO Draft International Standards, Series 14020-14024, Environmental Labels and Declarations, 1997.
48
Overview of Labeling Programs Worldwide
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determining criteria for awarding labels. In trade parlance, these factors are sometimes referred
to as process of production methods (PPMs). Environmental labeling programs often consider
environmental aspects of the production process in determining the eligibility of a product for a
label. Some argue that consideration of such a broad set of factors in determining eligibility for
an ecolabel may violate WTO provisions. Others argue that the voluntary nature of many
ecolabeling programs precludes such a conflict. The World Trade Organization (WTO)
agreement now explicitly recognizes the objectives of sustainable development and
environmental protection. It may be inevitable that the WTO develops interpretations that allow
for recognition of environmental impacts of PPMs.
A second conflict arises from the essentially domestic focus of most environmental labeling
programs. Each program typically develops award criteria that are achievable by a least some of
their domestic manufacturers. Foreign producers, particularly in developing countries,
participate less actively in standard development and may be less accustomed to stringent
environmental standards. They may thus face greater problems in getting products certified for an
environmental label. The following example highlights this concern: Country A develops award
criteria for product X. Because Country A has environmental concerns specific to that country,
Country A's award criteria for product X may differ from Country B's criteria for the same
product. Manufacturers in Country B, having reformulated their product and production to meet
domestic regulations, and possibly labeling standards, may not be able to meet Country A's
criteria for product X. If so, this may give rise to a trade issue. This issue can be especially
compelling when the exporter is a developing country that is already struggling to compete in the
global market.
The following chart (see Chart 4-15) lists the number of programs that indicated that they have
experienced trade issues or conflicts. For example, Germany requires companies that do not
participate in its Green Dot program to take back their packaging and bear the cost of recycling
the packaging themselves. There are no exceptions for foreign companies. The take-back
burden is therefore far greater for companies that ship their products long distances to Germany
because they either have to pay the transportation costs of shipping the packaging back to the
country of origin or arrange for in-country processing. Many manufacturers exporting to
Germany from within the EU and beyond claim that the domestic demand for the Green Dot
label places imported goods at a market disadvantage. Manufacturers in India have also reported
trade conflicts with regard to its textile exports. In fact, the Indian Ecomark program recently
added textile products as one if its product categories in response to new regulations, enacted by
Germany and the rest of the EU, banning the use of certain dyes in textiles. Germany and the EU
are two of India's largest markets for garments and textiles, and India has developed criteria that
specifically state that these banned dyes cannot be used in textile production. Thus, labeled
textiles will have an easier time entering the EU market.
Overview of Labeling Programs Worldwide 49
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Chart 4-18: Programs that Report Trade Conflicts
(based on programs reviewed)
Programs That Report Trade Conflicts
Yes
No
Indonesia's Environmental Labeling Program, though still in its developmental stages, was
initiated by demand in the export markets. As a result of the growing concern among consumers
in particular markets for sustainable forest practices, Indonesia plans to develop environmental
labeling criteria and guidelines for sustainable forest management practices, as well as a timber
certification program. (Forest products are Indonesia's second largest exports.) Additionally,
though Hong Kong does not currently have an environmental labeling program, studies have
been conducted by the Institute of Environmental Studies at the Hong Kong University of
Science and Technology (HKUST) to determine the suitability of a labeling program for Hong
Kong. HKUST determined that an environmental labeling program may be established for two
primary reasons: 1) to improve environmental quality and protection through market forces, and
2) to assist industries exporting to markets where environmental-labeled products are available.
HKUST concluded that because Hong Kong is a major exporter, several product categories may
be suitable for a Hong Kong ecolabel.
50
Overview of Labeling Programs Worldwide
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5. Forces Affecting Environmental Labeling Programs
The formation of labeling programs is driven largely by domestic forces. Because environmental
labeling programs serve to inform the public of the relevant country, they tend to form around
environmental goals and needs that are considered high priorities in that country. In general,
these forces include some combination of consumer demand, competition among producers, and
the leadership position of a sponsoring organization. Consumer demand drives program
formation by creating a market for a reliable source of information about the environmental
characteristics of a product. Competition among producers acts as a driving force as producers
seek ways to communicate the environmental attributes of their products to gain a competitive
edge. Finally, sponsoring organizations can also play a role in program formation by promoting
the usefulness of environmental labeling as a tool in a country's overall environmental protection
plan. The relative importance of each of these forces will depend on the type of environmental
labeling desired. In the case of negative labeling, consumers and the sponsoring organization
(typically governments) will be the major forces. On the other hand, producers will have a stake
in promoting positive labeling (which is awarded only to "preferable products") and perhaps, to a
greater extent, neutral labeling (which is available to all products regardless of differences in
environmental attributes).
The diversity in these domestic forces across countries has resulted in a varied group of
environmental labeling programs; each program differs in its mandate, operations, organizational
affiliation, and role in the marketplace. For programs with government involvement, the
program mandate often reflects the government's environmental policy goals, which are typically
stated as the protection of human health and the environment. In such settings, labeling efforts
range from regulatory programs (such as the FIFRA, ozone-depleting substances, and battery
labeling requirements in the US) to "soft" policy tools (such as EPA's Energy Star program in
the US, and the Blue Angel Program in Germany). In addition, there are private and quasi-
government programs that may have similar mission statements but are far more limited than the
government in their mandate and authority over environmental matters. For example, the
keystone of the US SCS program is the dissemination of information on environmental attributes
to consumers. Japan's Ecomark and the Nordic Swan programs report that environmental quality
improvement and/or protection of public health are the most important mandate of their program.
Few take on product categories that may be unpopular or for which the program will not be able
to cover its costs. Government regulatory programs, on the other hand, can address such
categories.
Although there are many other forces involved, the implications of these differences in program
mandates can be profound. For example, EU sees its role as an information disseminator,
responsible for formulating a consensus standard across EU markets. Consequently, the program
is challenged to balance its need for consensus on labeling standards from competent bodies
against the establishment of its own more stringent award criteria for the entire EU market,
which might arguably provide greater environmental benefits.
Forces Affecting Environmental Labeling Programs 51
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Important factors influencing the formation of environmental labeling programs include
public/societal interests, consumer interests, retailer interests, producer interests, operating
costs/profits, standardization, and procurement applications. Each factor is discussed in detail
below.
5.1. Public/Societal Interests
The attraction of environmental labeling to those involved in formulating and implementing
public policies related to preserving and enhancing environmental quality is that, as a policy tool,
the benefits of environmental labeling are closely connected to consumers' concerns regarding
the value of product environmental aspects, general environmental concern, and any tradeoffs
considered in particular purchasing decisions. Thus, the collective shifts in consumer demand
might be expected to reflect the interests of a large portion of society.
For environmental labeling to be an effective policy tool, a number of conditions must hold true.
First, product evaluations must be known and accurate. Second, product standards must be
associated with significant environmental differences among products. Third, this information
must be disseminated to consumers. Fourth, consumers must understand environmental issues
and product-specific information well enough to make informed purchasing decisions. Finally,
the label must have substantial market penetration in order to affect a significant number of
producers.
Environmental labeling programs face several challenges in trying to provide useful information
to consumers that will influence consumption patterns based on environmental considerations.
For product evaluations to be known and accurate, programs must conduct reliable scientific
analyses. Such analyses, however, include life-cycle assessments, which are extensive, time
consuming, and often require information about processes that is not readily, if at all, available.
These types of complications often require that the program make expert judgments; this
practice, however, may come under close scrutiny and debate.
Programs also face the obstacle of disseminating information, a key factor in the success of the
program. For example, Canada has launched a large media and marketing campaign; though it is
fairly new, it could prove to be quite successful. The time, energy, and resources that go into
advertising are immense, however, and pose a significant challenge to the program.
Governmental sponsorship and involvement with labeling programs, which is common among
existing environmental labeling programs, can improve the program's financial stability and
credibility in the eyes of manufacturers and consumers. On the other hand, a non-governmental
program run by a respected consumer or environmental organization may be more immune to the
political pressure that can affect governmental decision-making, and may differ in terms of
consumer credibility and confidence. Private sponsorship, however, has its own drawbacks.
While not subject to the vagaries of the political climate, privately owned and operated labeling
52 Forces Affecting Environmental Labeling Programs
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programs may be heavily influenced by the need to cover costs, and consequently may not take
on the larger environmental mission that a government-sponsored program might. Ultimately,
government involvement in an environmental labeling program depends in part on the
government's ability to act as an advocate in the marketplace, and the role that non-governmental
groups play in consumer protection and environmental policy. One survey found that 37 percent
of the people who considered themselves the "primary food shoppers" of their household
believed that "environmental groups" were the best source of unbiased information about the
environment, 8 percent believed the government was, and 5 percent believed that product
manufacturers were.10
There are also several limitations in using environmental labeling programs as a policy tool. For
example, these programs rely on consumers' ability and willingness to include environmental
considerations in their purchase decisions. Anecdotal information from several environmental
labeling programs, however, suggests that consumers in many countries are aware of
environmentally-labeled products and are willing to pay a premium to purchase environmentally-
preferable products. For example, in a 1988 survey of German households, 68 percent were
familiar with the Blue Angel label and knew that it was linked with the concept of environmental
protection. Similarly, in a 1994 survey of households in Singapore, 78 percent recognized the
GreenLabel as a signature of environmentally-preferable products. Furthermore, 30 percent said
they consider a product's environmental attributes as a part of their purchasing decision process.
In Japan, a 1993 public opinion poll indicated that 53 percent of the population was familiar with
the Japanese EcoMark. A 1996 survey of Canadians found that one in five Canadians said that
they or someone in their household had purchased a product carrying the Ecologo in the past
year. In France, a 1996 survey found that 54 percent of households indicated that they would be
willing to pay up to 10 percent more for environmentally-preferable products (although few
studies have documented such behaviors). Finally, due to a lack of awareness among consumers,
the EU is in the process of revamping its environmental label and the awarding of labels. The
setting of the award criteria will be reduced into a three-step process decided upon by two
groups, the EU Commission and the newly established European Ecolabel Organization (EEO).
The Commission hopes that criteria setting and ecolabel awards will be quicker and more
routine, thus increasing the number and recognizability of EU-labeled products on the market.
(For more information on reform of the EU environmental label, refer to the EU program
summary in Appendix B.)
^Environmental Research Associates, 1990.
Forces Affecting Environmental Labeling Programs 53
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5.2. Consumer Interest
The power of consumer interest in and response to environmental problems is undeniable. The
continued funding and expansion of both governmental and non-governmental environmental
programs throughout the world, many of which have been in existence for over 25 years, is
compelling evidence of the strength of individuals' concerns about environmental issues.
Intermittent consumer activism in the marketplace, as seen in reactions to companies'
environmental performance or disclosure of environmental attributes of particular products, has
been well documented and is often referred to as the power that labeling programs seek to
harness. A recent example is the successful consumer boycott of household detergents in
Sweden, promoted by the Swedish Society for Nature Conservation (SSNC). The boycott gave
rise to the first multi-national environmentally labeled detergent on the Swedish market.
Environmental labeling is also tied to consumer right-to-know initiatives in several developed
markets, particularly the US. The premise is that consumers have a right to know about the
ingredients contained in a product, as well as each ingredient's health and environmental hazards,
so that they can use this information to make informed decisions regarding the products they
purchase. The US Federal Trade Commission's (FTC) Guides for Environmental Marketing
Claims was a direct result of an increase in consumer right-to-know developments. The concept
of a consumer's right to know, however, is relatively new and not widely recognized. As such, it
remains a highly contentious issue. Opponents argue that consumer right to know may, in some
instances, be in direct conflict with GATT's trade efforts and manufacturers' proprietary
interests.
Consumer activism has played a role in creating a market for environmental labeling programs.
First-party cause-related marketing (e.g., "Proceeds donated to..." or, "company supports WWF")
and environmental claims (e.g. recyclable) have sought to capitalize on this consumer demand
for environmentally preferable products and services. The EPA, FTC, and others, however, have
also documented confusion and misunderstanding among consumers regarding environmental
issues, particularly when making choices among products. Environmental claims can create
misunderstanding because they often pertain to product characteristics, such as ozone-friendly,
with which a consumer generally has little or no experience or cannot physically perceive;
consumers therefore have difficulty in evaluating the credibility or value of the claim.
Furthermore, claims such as recyclable and compostable relate to more than just the inherent
qualities of the product being promoted; they also reflect the context in which a product is used,
recycled, or disposed. Finally, some terms used in environmental marketing, such as source-
reduced, are often poorly understood by consumers. These kinds of claims and the existence of
claims that may be false have driven the need for labels that are accurate and verifiable, and
written to be simple and understandable. It has also driven most third-party environmental
labeling programs to provide product-specific information with which consumers can themselves
distinguish among product choices, or to identify products that cause less stress on the
environment based on the program's independent evaluation.
54 Forces Affecting Environmental Labeling Programs
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To ease some of this confusion, the FTC's Guides for Environmental Marketing Claims provides
manufacturers with stringent guidelines for making environmental claims on their products,
which are consistent with consumer understanding of these terms.11 Similarly, the EPA, through
its Consumer Labeling Initiative (CLI), along with other US federal agencies and industry
stakeholders, are investigating ways in which product labels on household cleaners, indoor
insecticides, and outdoor pesticides can be improved to increase consumers' comprehension and
use of information presented on these labels. (For a detailed description of the CLI, refer to the
program summary in Appendix B.)
5.3. Retailer Interests
Retailers can play a role in environmental labeling programs. On the one hand, they can play a
significant role in fostering environmental labeling by selecting products to sell based in part on
environmental attributes. For example, in the United States, Home Depot has made a
commitment to stocking products considered to be environmentally-preferable. On the other
hand, retailers have also attempted introducing their own environmentally-sensitive product
lines. For example, the Texas-based Whole Foods Market has developed its own line of organic
food products as well as other "environmentally sound" products such as personal health care
products. Such actions on the part of retailers can diminish the effectiveness of independent
labels on the retailers' shelves because multiple, competing labeling may cause confusion. The
extent of retailers' impact, however, is tempered by the size of their operations. If they handle a
significant market share of a particular product type (e.g., dishwashing soap), they will have the
power to educate consumers through environmental labeling (and other avenues) as well as to
influence producers production/marketing strategies. By and large, however, most retailers will
function only as intermediaries in the flow of environmental information from manufacturer to
consumer due to their relatively small size in national markets.
5.4. Producer Interests
One of the unique qualities of environmental labeling is that it opens up an untapped source of
information to consumers. Much of the information concerning the health and environmental
effects of products and product constituents is currently generated by manufacturers. This
information, however, typically does not make it to the ultimate consumer in a form that is
readily understandable. Producers have the ability to make information easy to read and
comprehend, but doing so is a double-edged sword because some consumers will switch to
products deemed to be more environmentally sensitive.
Producers cannot ignore that environmental marketing has emerged as an increasingly important
Business and the Environment, vol. 9, no. 6, June, 1998.
Forces Affecting Environmental Labeling Programs 55
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issue for consumers, producers, regulators, and policy makers. Producers have responded to
consumer demand (real, anticipated, or perceived) for products that are manufactured with
environmental considerations in mind. They have done so by increasing environmental
marketing claims, submitting products to environmental labeling programs for certification, and
introducing new or redesigned "green" products. Producers do this primarily to remain
competitive in a market where consumers are demanding environmental information. Any
competitive advantage (such as certification) or handicap (such as a hazard warning) is important
to a producer in that it can set a company apart from its competitors. For example, when an
American paper company was the first to be certified by the Blue Angel program, a number of
German companies quickly followed suit. Conversely, California's Proposition 65 has spurred
manufacturers to change their product formulations to avoid carrying a label that warns of the
risk of cancer and birth defects.
In addition, producers may be motivated by liability or public image concerns. By disclosing
environmental information on product labels, producers say they better equip consumers with
information to use, recycle, and dispose of the product/packaging safely. This may decrease
producers' liability. By having their products certified by an environmental labeling program,
producers may be able to avoid financial and public relations risks as well as to increase sales.
For example, Germany's Blue Angel is credited with creating incentives for manufacturers to
reformulate certain products (e.g., low-VOC paints and high-recycled-fiber-content paper
products) prior to any evidence of consumer demand for such products.
5.5. Operating Costs and Profit
An important factor in the success of any environmental labeling program is its ability to cover
its costs and therefore stay in business. The ease with which programs will be able to cover costs
varies depending on two questions:
*• can the program charge enough in application, testing, audit and other fees to cover its
costs; and
*• can the program subsidize its environmental labeling activities from other program
activities?
Subsidies may be in the form of professional and administrative time, office space and supplies,
etc. Because government-sponsored and/or operated programs will typically have other
resources to draw on, profitability may not be critical to the success or longevity of the program.
The same may be true for quasi-government programs, where there is still some access to
government resources, and for programs run by national standards institutes, for which
environmental labeling is just one part of their operations. For privately-run programs and other
programs that do not have other resources to draw on, however, the ability to cover costs will be
critical to whether or not they remain in operation in the long run. For these programs, there is an
inherent conflict in prioritizing efforts to develop award criteria and issue awards or otherwise
56 Forces Affecting Environmental Labeling Programs
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evaluate products. Programs can lose credibility if they are thought to be motivated by profit in
their selection of product categories or in the awarding of labels.
5.6. Standardization of Environmental Labeling Programs
One of the more recent forces affecting environmental labeling programs is an effort by the
International Organization for Standardization (ISO) to standardize environmental labeling
programs. ISO has set out standardizing criteria and is in the process of developing additional
criteria that prescribe certain elements to be present in environmental labeling programs meeting
the standards. Programs, in turn, have been adopting these principles even in draft form. Because
each program has different product categories, criteria, and environmental preferences, labels are
generally not transferable between one country and another. To avoid this problem, programs
have begun to standardize around the ISO principles, finding ways to harmonize their programs.
The lack of a national, third-party labeling program in the US may affect standardization of
environmental labeling programs. The majority of US government programs often exist to
implement specific requirements of statutes or regulations and have been in place for many years
(e.g., the US EPA's pesticide program, through FIFRA, was established in 1947). Typically,
these are mandatory programs and are therefore usually hazard/warning labels. As a result, they
are specific to domestic US policy needs, and only US governmental authorities have the power
to impose such requirements. It may be more difficult to coordinate non-governmental US
programs with other worldwide labeling programs, particularly during bilateral or multilateral
harmonization and negotiations.
5.7. Procurement Programs
The procurement activities of governments and large organizations are increasingly considering
environmental attributes of purchased goods and services. Such consideration is typically given
because the purchaser's mandate/mission also includes stewardship of environmental quality, as
is the case with governments, or because incorporating environmental attributes either benefits
the organization directly (e.g., reduced costs over the life of purchased goods) or indirectly (e.g.,
goodwill among stockholders or customers). Use of environmental labels in purchasing
decisions, however, has given rise to discussion about a number of issues, such as whether labels
provide purchasers sufficient information to improve decision-making.
Nonetheless, US procurement pilot projects are providing a proving ground for the benefits and
drawbacks of using environmental labels and environmental labeling information in EPA's
Environmentally Preferable Purchasing Program.
Forces Affecting Environmental Labeling Programs 57
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The explicit consideration of environmental attributes in procurement can be addressed in a
number of ways. At one end of the spectrum, the organization or government conducts it own
research and establishes specific environmental attributes which may be preconditions for
submitting bids, used as price preferences. In some cases, however, a third-party environmental
labeling practitioner, rather than the government, may undertake the needed LCA-based analysis.
In situations where a procurement program relies on information provided or analyzed by a third-
party environmental labeling practitioner, it may be important for the procurement process to
include careful consideration of the underlying analysis, data, evaluation methodology, and any
judgments that might be used.
The use of environmental labels by procurement programs has the potential to increase the market
presence of the labeled products and enhances the credibility of the labeling program. Although
most procurement programs do not require that only labeled products be bought, many programs,
such as Japan's Green Purchasing Network (GPN), encourage the purchase of "environmentally
preferable products," which include ecolabeled products. GPN aims to promote "green
purchasing" and has established purchasing guidelines for several product categories, as well as
providing consumers with information on the environmental impact of products through
guidebooks and newsletters. There are 425 companies, 107 government agencies, and over 90
non-profit organizations that are members of the GPN.
A similar program has been established in the US through Green Seal's "Environmental Partners
Program." Businesses, government agencies, universities, non-profit and other organizations who
join the program as Pledged Partners, commit to buying environmentally-preferable products and
services as part of their procurement policies. These partners must annually provide Green Seal
with a list of their purchases as a way to ensure compliance with the pledge. Green Seal provides
all its Partners (pledged partners and those who simply subscribe to the program to receive
information) with the Choose Green Reports, which provide recommendations of specific
environmentally-preferable brands of products, including ecolabeled products, and list places
where these products can be purchased. The Partners program currently has over 400 members,
163 of whom are pledged members.
In the case of private procurement, product evaluations and determinations of environmental
preferability are a matter of cost-effective decision-making and the cost of information.
Government procurement, however, can be much more complicated because of the breadth of
government mandates and decision-making procedures. Though some countries, such as the
Netherlands, Japan, and Germany have informal procurement policies that simply encourage the
purchase of labeled products, particularly as part of a local or national government agency's
policies, only a few labeling programs are associated with formal procurement requirements. For
example, the countries in the Nordic Council require that their local and national governments
purchase Nordic Swan labeled products whenever possible.
58 Forces Affecting Environmental Labeling Programs
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6. Recent Trends and Future Outlook
While there are marked differences among programs, their mission statements are basically
consistent on three major points, which are reflected in the ISO draft on general principles
(14020):
> the objective of environmental labels (and declarations) is market-driven continuous
environmental improvement;
> this will occur if labels can increase the demand for and supply of environmentally
preferable products and services; and
> ecolabels should communicate verifiable, accurate, non-deceptive information on the
environmental attributes of products and services.
Many involved in the formulation of environmental policy and those affected by it see
environmental labeling as one tool that differs dramatically from regulatory command-and-control
approaches affecting manufacturing, yet may offer society a market-based means of capitalizing
on (individual) consumers' interest in environmental protection and improvement. To date, the
effectiveness of labels as a policy tool has not been thoroughly studied. Some successes, such as
Blue Angel's low-VOC paint labeling, have been documented, but worldwide there is insufficient
market penetration to make accurate assessments of environmental labeling's value. This section
identifies a number of overview findings that provide context for the future of environmental
labeling in the near term:
*• There is a marked trend toward globalization of previously domestic programs;
> There is a widespread commitment by the programs to standardize methodologies and
harmonize programs; and
> There are several issues (e.g., free trade agreements) that, depending upon their resolution,
may drive wedges between programs or otherwise constrain the growth and use of
environmental labeling, particularly third-party labeling programs, as a policy tool.
A wide range of government policy makers, manufacturers, and consumers are acutely interested
in whether these trends will continue. Many labeling programs and some manufacturers have
made significant investments in order to participate or compete in labeling. Objections to the use
of environmental labeling have come from several sectors. Certain trade officials and
manufacturers, fearing possible loss of their competitive position, have objected to the use of
LCA-based product standards as contrary to GATT. Companies that do not want the added costs
of certification or having to place an environmental claim on their labels have also raised
complaints. Some foreign manufacturers see ecolabeling programs as a form of protectionism for
domestically manufactured goods. Proponents see labeling as a relatively non-intrusive policy
tool with which to make more transparent the environmental attributes of goods and services. The
future level of environmental labeling activity in the US and world markets depends on a diverse
combination of factors including: prevailing economic conditions; political support for and
opposition to global free trade, societal commitment to consumer right-to-know; ambient
Recent Trends and Future Outlook 59
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environmental quality and goals; local conditions that might affect the environmental impacts of
manufacture; consumer use of labeling information; the development of standardized
methodologies and operating practices for environmental labeling programs worldwide; and their
individual and collective success in the marketplace.
6.1. The Proliferation and Globalization of Environmental Labeling Programs
Of the programs for which information could be collected, 17 had formed as of 1989. By 1997,
the number had grown to 49. This proliferation has occurred for many reasons, including market-
specific reasons. In addition to the increased number, the operations of and interactions among
programs is expanding beyond their domestic origins. From a larger perspective, there are several
drivers of program proliferation and globalization:
> trade in goods has become increasingly global;
*• there has been increasing recognition of consumers' right to know in the US and abroad;
> competitive pressures on manufacturers and countries to initiate programs have arisen; and
*• new programs have been able to accelerate their development based on the experience of
and information generated by existing programs.
As mentioned earlier, foreign trade in proportion to domestic consumption of goods has increased
over the past fifteen years. International trade worldwide has increased from $4.0 trillion in 1985
to $7.3 trillion in 1993. Environmental labeling programs have responded to the changing pattern
of trade and consumption in a number of ways. Programs are having to consider logistical and
cost recovery issues related to evaluations of imported products and to factor in imports in certain
market analyses. In addition, certain programs have been involved in facilitating the entry of
their own country's exports into foreign markets where environmental labeling exists.
Governmental consumer right-to-know initiatives in the US (e.g., the Toxics Release Inventory,
the Federal Aviation Administration's publication of airline performance statistics, and EPA's
Consumer Labeling Initiative) and abroad (e.g., UNEP's Food and Agriculture Organization's
1985 Code of Conduct on the Distribution and Use of Pesticides, as amended in 1989, which
establishes the principle of shared responsibility of governments and others to ensure consumers
are informed and safe through a variety of means including product labeling) have established the
right of consumers to have access to information on potential health and (local) environmental
hazards. Non-governmental right-to-know initiatives may take the form of grass root movements,
such as boycotts, information dissemination such as environmentally-oriented buying guides, or
petitions establishing statutory requirements, such as California's Prop 65. At the same time,
consumer environmental interests have broadened to include information on other environmental
attributes, such as possible environmental impacts at remote locations — often expressed as
concern for sustainable production practices. Product labeling is among one of the most direct
ways to summarize and transmit to consumers assessments of the products' environmental
attributes.
60 Recent Trends and Future Outlook
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New programs have been created for a wide variety of reasons. Among the mission statements
submitted, one of the most frequently cited goals is to inform and provide information to
(domestic) consumers, although no programs referenced a consumer demand study when
providing background on their formation. However, competitive positioning of manufacturers,
trade ministries, and governments has also played a role in the genesis of particular programs. For
example, the Indian government has asked several research institutions in the country to provide
local textile manufacturers with information about dyes that have been banned by the EU, one of
India's largest textile importers. The government and universities are providing Indian textile
manufacturers information about these dyes as well as information about alternative, less toxic
dyes.
In an effort to move toward equivalency, harmonization, and/or mutual recognition, the Global
Environmental labeling Network (GEN) was formed by national and multinational ecolabel
licensing organizations. "The GEN shall foster cooperation, information exchange, and longer-
term harmonization with regard to environmental labeling..." and "... shall promote environmental
labeling programs worldwide." The short-term objectives of GEN are to create an ongoing
framework for information exchange, to ensure that the interests of environmental labeling
programs are represented, and to provide a forum for regular member meetings. In addition, their
long-term goals include moving toward harmonization and offering information to developing
programs. To the extent that groups such as GEN are successful in reducing the barriers to entry,
the number of labeling programs may continue to grow.
Thus far, GEN has 20 members.12 While membership is open to all national and multinational
environmental labeling licensing organizations, they must meet the following criteria:
based solely on voluntary participation for potential licensees;
run by not-for-profit organizations without commercial interests;
exhibit independence from undue commercial interests;
the source of funding shall not create a conflict of interest;
seek advice from, and consult with, stakeholder interests;
legally protected logo;
determination of criteria based on an assessment of the overall life of a product category;
open access to potential licensees from all countries;
criteria levels established to encourage the production and use of products and services
that are significantly less damaging to the environment than other products; and
12They include Austria, Brazil, Canada, Croatia, Germany, Greece, Israel, Japan, Korea, Luxembourg, New
Zealand, Norway, Spain, Sweden, Swedish Society for Nature Conservation, Taiwan (ROC), Thailand, US, and
UK.
Recent Trends and Future Outlook 61
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> periodic review, and if necessary, update of both environmental criteria and categories,
taking into account technological and market place development.13
Coordination and cooperation among labeling programs increases the ability of new programs to
accelerate their development based on the experience of and information generated by existing
programs. For more developed programs, such cooperation can facilitate development of new
product categories or award criteria. One example of inter-program coordination is Green Seal
and Canada's TerraChoice. Both programs recognize each other's product criteria, and have
adopted each other's product criteria for certain product categories.
The increased pace of information transfer has also been fostered by the efforts of several
international organizations, most notably GEN and ISO. Still slightly less than one-half of the
programs responding (21 of 49) reported that they actively work with programs in other countries.
In addition to information transfer, programs have also explored several other harmonization
measures that reduce the hurdles of program formation and development. In general, such
measures recognize the research and judgments of another program, falling into two categories:
mutual recognition and technical equivalence. Mutual recognition means that two or more
programs agree to recognize each other's licensed seal or product assessment. The underlying
premise for mutual recognition is that each program sufficiently captures the environmental
attributes of products given differing local conditions. That is, a product having received a label
in one program is eligible for a label from the second program (typically in another country or
market) and need not undergo complete product evaluation again. For example, paper products
that have been certified under the EU ecolabling program need not go through additional
evaluation if they seek to receive the Nordic Swan label. Technical equivalence means that two or
more programs view the other's product category definition, award criteria, and/or product
assessment methodology as essentially the same as their own. This is true of certain product
categories common to both the US Green Seal program and Canada's TerraChoice program.
Programs can use technical equivalence as a basis for coordinating research, information
gathering, and even mutual recognition.
6.2. Standardization
Since 1992, many labeling programs have participated in a variety of standardization and
harmonization efforts. Most significant is the international coordination of developing
standardized definitions, analytical procedures, and program characteristics under the auspices of
ISO. Product evaluation and program standards are being developed by ISO for two types of
third-party programs: Type I applies to seal-of-approval programs; Type III applies to eco-profiles,
or report cards. As part of this research, programs were asked about their level of participation in
13From World Wide Web site http://www.interchg.ubc.ca/ecolabel/gen.html
62 Recent Trends and Future Outlook
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the ISO process and the program's commitment to ISO draft and/or final standards. In addition,
some less formal standardization occurs as part of harmonization - the formal and informal
cooperation and coordination of programs to increase consistency across programs.
Activities range from using common terminology to the informal sharing of methodological
approaches used to develop award criteria. It should be stressed that the ISO standards
development process is ongoing. Of four proposed standards on environmental labeling, only two
are close to being finalized. In addition, the Organization for Economic Cooperation
Development (OECD), GEN and EU-US bilateral agreements have and will continue to foster
standardization by reducing the very real barriers to information transfer, thus enabling programs
to access the best, most up-to-date information available needed for individual labeling efforts.
For example, research on topics such as product evaluation methodologies and data sources that
occurs under the auspices of OECD (funded by OECD member countries) assists programs
worldwide in learning from one another. GEN provides a current inventory of the existing
standards of its members and facilitates the sharing of individual program's research. Bilateral
agreements can foster mutual recognition of the larger mission of both governments and their
respective labeling programs. They can also assist both parties to identify common interests and
basic areas of cooperation (typically the sharing of methodologies and information). However, to
the extent that the dominant programs differ in their opinions of the benefits of and need to
standardize, there is a risk that ISO standards will not be finalized. If so, environmental labeling
will continue to be characterized by diverse methodological approaches and inconsistency.
One example of standardization's possible effects on individual programs involves the stipulation
that the development of award criteria should be based on some form of life cycle analysis. The
draft ISO standards call for use of life cycle considerations in all phases of labeling: product
category selection, establishment of award criteria, and product evaluation. This approach was
neither feasible nor common in the 1980s, when a number of the currently active programs began.
Recent trends, however, have shown that more and more programs are utilizing either full LCA or
a modified version of LCA. Of the 49 programs covered in this report, 21 of them use life cycle
methodologies. Several older programs, such as Japan's EcoMark, have shifted toward Life-
Cycle-Assessment-based methodologies, but the investment in past standards may be problematic
for programs such as Germany's Blue Angel, which have standards for 88 product categories,
most based on post-manufacture phases of the life cycle. Should that program adopt a full LCA
(following SETAC's guidelines), all existing standards would need to be revisited at a tremendous
cost to the program.
Currently, ISO technical committees, technical advisory groups, and working groups have been
organized to address standardization of a wide range of matters, including general principles of
ecolabeling, guiding principles and procedures for Type I programs, guiding principles and
procedures for Type III programs, and principles and framework of LCA. The draft standards for
program administration recognize the benefits of transparency and non-discrimination, which
some programs have been criticized for not providing. These standards, in conjunction with the
development of product evaluation methodology and LCA standards, are expected to improve
Recent Trends and Future Outlook 63
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programs' interactions with all interested parties, increase the efficiency of operations, improve
the credibility of labeled information in the marketplace, and ultimately drive environmental
quality improvements.
Consensus on the benefits of, the need for, and a definition of LCA may be elusive precisely
because those participating in ISO have differing self interests. Those participating in standards
development in the US delegation include all levels of government, consumer product and
commercial product manufacturers (both US and foreign-owned), trade associations, consultants,
academics, public interest groups, labeling programs, and testing organizations. Many programs
are actively participating in the development of standards pertinent to their program. Some, such
as Japan and the EU, have made interim program improvements that are consistent with draft
standards. However, because the ISO process is lengthy and ever-changing, programs will be
unlikely to commit resources or reinvent themselves to meet ISO standards until they are
finalized.
6.3. Wedge Issues
Several issues may drive wedges between programs or otherwise constrain the growth and use of
environmental labeling as an effective policy tool. Such forces range from those within the
labeling programs themselves (e.g., self interest in preserving the status quo) to forces external to
programs (e.g., international trade agreements) and issues involving the programs and their major
customers/constituents (e.g., self-sufficient financing). The ultimate resolution of these issues
cannot be predicted at this time. Of those identified in this section, some have already had real
effects on labeling programs, for example, GATT prohibition of PPM restrictions. Others, such
as the possible limitations of ISO standards, are described as potential obstacles. Each issue
should be viewed as important and a possible determinant to the future success or failure of
existing labeling programs.
Program Goals
As mentioned above, environmental labeling program mandates are very similar. One important
difference among programs, however, is their differing expectations regarding the ability of
labeling information to inform and educate consumers and to change consumer purchasing
decisions. The seal of approval programs (ISO Type I) assume that the information needed to
accurately describe numerous environmental attributes and LCA results is too complex and too
extensive to present on a label. Consequently, the labeling organization synthesizes this
information and establishes what it hopes to be a credible judgment of preferability (the licensing
of the logo for qualifying products). On the other hand, report card programs (ISO Type III)
believe that individual consumers can themselves prioritize across environmental burden (or
stressor effect) categories (e.g., water consumption and air pollutants released) and that the
consumer needs no interpretation. In that respect, the report cards (e.g., nutritional labeling)
standardize and present environmental information.
64 Recent Trends and Future Outlook
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One important difference between environmental report cards and the nutrition label is that
environmental attributes are far more complex and difficult to standardize. For example,
environmental impacts are typically site-specific, and differences in how the product is used and
disposed of must be assumed. At present there is no conflict between these labeling approaches,
since they have yet to gain significant penetration in the same market. If they do, consumer
confusion might result from labeling clutter. (If products in the same category had different label
types, comparisons cannot be made. Multiple labels on different products might confuse
consumers.) Such differences in how consumers use label information could affect a program's
suitability to label certain products, affect non-retail use of labels and labeling information, and
shape their near-term objectives and goals. In an overarching sense, the competition between the
differing approaches to presenting environmental information on the label can be expected to
constrain information-sharing alliances and may create conflicts among programs.
Limitations to Standardization
ISO and other processes drive standardization and have already prompted several programs to
change their operations. Programs may be limited, however, in facilitating certain changes at the
program level. The most significant limitations may be the adoption of effective program
transparency and how to reconcile new methodologies with existing program protocols and
licensed awards. In addition, harmonization of nontechnical matters, such as cultural norms and
values used in prioritization and tradeoff analyses among attributes, may impede mutual
recognition of award criteria in particular product categories.
In the US, regulatory development is an excellent example of a readily transparent process. The
regulatory agenda is published, as are preliminary proposals. All governmental analyses of the
proposals are publicly available upon request, as are summary reports detailing proposals. Public
comments are solicited for anywhere from 60 to 90 days at several stages. A public docket is
prepared so that anyone may review all comments. Public meetings may be held at various times
throughout the process. Subsequently, the Agency must respond, in the record, to each comment
made, prior to revising analyses or proposals. Several rounds of proposals and public input may
occur prior to the proposal of a final rule along with its estimated impacts and benefits - based on
assumptions, data sources, and analytical methodology that have been thoroughly reviewed. This
is fairly costly for the government and a time-consuming process, but one that is thought to
guarantee transparency and facilitates participation by as many interested parties as possible.
Environmental labeling programs, particularly those with very limited funding, may operate with
limited input on the development and/or limited review of proposals for product category
selection and award criteria. This streamlined approach eases development of new product
categories and criteria and allows the program to better control the process. In addition to the
procedural constraints, there are practical limits to widespread participation when stakeholder
access is limited in duration. For example, foreign manufacturers and public interest groups are
more likely to be excluded from a limited process, or one in which regular participation on ad hoc
Recent Trends and Future Outlook 65
-------
committees is required, because of the high cost of participation. Unless there are changes to the
amount of information made public and how it is disseminated at each step of the process, the
more streamlined labeling programs may not comply fully with the ISO principle of transparency.
Draft ISO standards also call for non-discrimination. That is, all domestic and foreign parties
should be treated on an equal footing. This is an immense challenge for programs because
currently there is no system to disseminate proposals and operational information and to collect
input on an international scale. International information exchange efforts using the Internet, as is
being tried by GEN, may help programs reach the goals of transparency and non-discrimination.
As the ISO process moves forward, each program is assessing how iy might reconcile new
methodologies with its existing program. Even if the methodological differences can be
standardized, mutual recognition remains the only solution to certain inherent differences among
programs. Such country/market differences will certainly result in differences among award
criteria for the same product. For example, Country A's market basket analysis may contain a
small share of environmentally preferable performers (imported from Country B). In Country B,
the share of those products may exceed 50 percent. Country A's labeling program could help to
shift the market toward the environmentally preferable alternatives at the expense of its domestic
manufacturers. Alternatively, the LCA could reveal that the impact of the greatest environmental
burden of the product manufacture differs dramatically between the countries based on local
conditions (e.g., availability of water or suitable disposal capacity). LCA itself does not
incorporate cultural values.
6.4. Future Outlook
In addition to the background information presented in this report, it would be useful to have an
accurate forecast of how environmental labeling activities and programs will interact with
governmental policies and social concerns. Unfortunately, the future of such labeling in the
marketplace is too complex. There are, however, a number of issues that are important for which
trends can be projected into the near term, and others that can be identified as important but for
which the near-term outcome cannot be anticipated at this time.
Given recent history and the interests of those participating, ISO efforts on draft standards are
expected to continue, although there will be differences in rates of standards development and
outcome. To the extent that the standard setting process involves major stakeholders and a
representative (international) group of minor stakeholders, most standards are likely to be
finalized. The extent to which standards are adopted by individual programs will depend upon: 1)
the adoption of programmatic changes called for in draft ISO standards, such as effective and
inexpensive means of ensuring transparency and public participation; and 2) the extent to which
LCA and harmonization issues have been articulated and addressed during in the intervening
period.
66 Recent Trends and Future Outlook
-------
What trade issues will arise, how these conflicts are resolved, and in what venue they will be
resolved (e.g., WTO decisions, bilateral negotiations) are all important near-term drivers
affecting the long-term future of environmental labeling. The fact that the first few will be
precedent-setting throughout the world makes them of particular interest. Consequently, those
labeling programs and efforts less likely to attract trade conflicts (e.g., because their product
criteria do not include PPMs or product content in a significant way), are better positioned to
succeed in the short term. In the longer term, compatibility with ISO standards, trade conflict
resolution precedents, and cost-effective operating practices will play an increasingly important
role in the success of environmental labeling.
Demand for environmental information as provided by labeling programs is generated from
several sources. The major consumers of such information are expected to continue or increase
their demand in the next five to ten years. Governmental procurement programs in the US and
Europe already consider environmental attributes in their decision-making and look to labeling
programs as important contributions to the process. Similarly, product stewardship and vendor
screening activities as related to ISO 14000 programs will foster use of such information in
private sector procurement and product design. Regulatory requirements will also increase
demand for environmental information. In the US, for example, facilities covered by the
expansion of Toxics Release Inventory reporting to new industries will need information on the
content and composition of inputs.
Demand from retail consumers is associated with knowledge of and concern about environmental
issues and is far less predictable. One of the primary limitations in environmental labeling
programs to date has been a lack of awareness on the part of consumers. Increased consumer
awareness about environmental issues and the existence and purpose of environmental labeling
could significantly affect the success of programs. If national and international news events, in
combination with consumer education, increase awareness of environmental issues and labeling
information is found to be credible and useful, retail consumer demand is likely to increase. The
degree of change in retail consumer interest over time is, however, more uncertain. In turn, the
viability of programs dependent upon fees for services and licensing fees are more at risk from
any downturn in demand from customers (throughout the supply chain) than are programs with
other sources of funding (such as governmental subsidies) or those programs with a diverse set of
products/services (such as consulting and testing not directly related to labeling).
Recent Trends and Future Outlook 67
-------
-------
Appendix A:
Overview Table of Environmental Labeling Programs Covered
in this Report
-------
-------
Appendix A: Overview of Environmental Labeling Programs Covered in this Report
Country (Seal
Developed
Programs |
Austria [Austrian Eco-Labei
Canada [Canada's Environmental Choice
China j-
Croatia [Croatia's Environmental Label
Czech Republic [-
Denmark ll^M^LSwan
EU iMyi^pf^iLyiii^n^^l^ML^^^
Finland ll^M^LSwan
France Lt!fi§™E?D!]5in5n!
Germany L§!H!L^QS5!
Germany l^!55EL5??
Iceland ll^M^LSwan
India L§52iM?l!5
Japan L§52D3?!^
Korea L§52D3?!^
Luxembourg iMyi^Pf^ILyili^n^^l^ML^^^
Malaysia ff™durtCertf\cat\on Program
Netherlands L§y5MMMIi5H]^!Ł
New Zealand LlnYil^niO^DM^I^i??
Norway lN??M^SwanJ-abel
Singapore l^!55I!Jr5^5L§i!]9?P2[?
Spain !^§I^5jy!5^!2^n^i5!]!?
Sweden L§|S:N2Łdjc^a/variJ_abel
Sweden IGood Environmental Choice
Category
Type 1
Type 1
Type 1
Type 1
Type 1
Type 1
Type I/Ill
Type 1
Type 1
Type 1
Type 1
Type 1
Type 1
Type 1
Type 1
Type 1
Type 1
Type 1
Type 1
Type 1
Type 1
Type 1
Type 1
Type 1
Mandatory/
Voluntary
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
V
Type of Label
Seal of Approval
Seal of Approval
Seal of Approval
Seal of Approval
Seal of Approval
Seal of Approval
Seal of Approval
Seal of Approval
Seal of Approval
Seal of Approval
Single Attribute
Seal of Approval
Seal of Approval
Seal of Approval
Seal of Approval
Seal of Approval
Seal of Approval
Seal of Approval
Seal of Approval
Seal of Approval
Seal of Approval
Seal of Approval
Seal of Approval
Seal of Approval
Type of Govt/ Non-
Prog ram jGovt
Positive [Govt
Positive [Quasi
Positive iGovt
Positive i Govt
Positive [Gpvt_^
Positive [Qy??!
Positive [Goyt
Positive [Qy??!
Positive iGoyt
Positive [Goyt
Positive lOy??!
Positive [Qy??!
Positive iGoyt
Positive lOy??!
Positive iGoyt
Positive [Goyt
Positive [Goyt
Positive lOy??!
Positive lOy??!
Positive [Qy??!
Positive lG?yt
Positive LM2H^2y!
Positive [Qy??i
Positive 1 Non-Govt
No. of Product
Year Founded (Categories
1991 [35
1988 J49
1994 12
Unknown \33
1994 TiZ^^II
1989 [42
1992 [ij
1989 [42
1992 [6
1977 [88
1990 [7
1989 [42
1991 [16
1989 [69
1992 [36
1992 [IJ
1996 [1
1992 [32
1990 [T7
1989 [42
1992 [21
1993 [3
1989 [42
1990 17
A-1
-------
Appendix A: Overview of Environmental Labeling Programs Covered in this Report
Country (Seal
Taiwan (Green Mark Taiwan
Thailand [The Thai Green Label Scheme
UK 1 European Union Ecolabel Scheme
US Battery Labeling
US (Chlorine Free Products Association
us [ECO-O.K.
US [Ecotel
US [Energy Guide
US [Energy Star
US [Fuel Economy Information Program
US Green Seal
US [ODS- Ozone
US [Office of Pesticide Program (FIFRA)
US [Proposition 65
US [SCS - Claim Certification
US [SCS - Eco-Profile
US [SCS - Forestry
US [SCS - NutriClean
US [Smart Wood Program
us [TSCA
US [Vermont
US [WAVE
US [ Greening the Government
US [ The Green Pages
[US EPA VOC Emission Standards for
US [Architectural Coatings
Programs in [
Development j
Brazil JABNT - Environmental Quality
US [Consumer Labeling Initiative
US [Electric Utility Labeling
US [Small Spark Ignited Engines
Finland [Type III
Indonesia [BAPEDAL
Category
Typel
Typel
Typel
N/A
Typel
Typel
Typel
Type III
Limited Attributes Seal
Type III
Typel
Other
Type ll/various
Type III
Typel
Typel
Typel
Buying Guide
Buying Guide
N/A
Typel
In Progress
In Progress
In Progress
Type III
Typel
Mandatory/
Voluntary
V
V
V
M
V
V
V
M
V
M
V
M
M
M
V
V
V
v
V
M
M
V
N/A
N/A
M
V
In Progress
In Progress
V
V
Type of Label
Seal of Approval
Seal of Approval
Seal of Approval
Information
Disclosure
Seal of Approval
Seal of Approval
Seal of Approval
Report Card
Seal of Approval
Report Card
Seal of Approval
Hazard
Hazard
Hazard
Seal of Approval
Report Card
Seal of Approval
Single attribute
Hazard
Hazard
Seal of Approval
Buying Guide
Buying Guide
Information
Disclosure
Seal of Approval
In Progress
In Progress
Seal of Approval
Report Card
Seal of Approval
Type of Govt/ Non-
Prog ram JGovt
Positive [ Non-Govt
Positive (Quasi
Positive (Govt
Neutral Govt
Positive [ Non-Govt
Positive [ Non-Govt
Positive [ Non-Govt
Neutral [Govt
Positive [Govt
Neutral [Govt
[ Private - non-
Positive 1 profit
Negative [Govt
Negative [Govt
Negative [Govt
Neutral [ Non-Govt
Neutral [ Non-Govt
Positive [ Non-Govt
Positive [ Non-Govt
Negative [Govt
Negative [Govt
Positive [Govt
Neutral [Govt
Neutral [Govt
Negative (Govt
Positive (Quasi
In Progress [In Progress
In Progress [Quasi
Positive [Govt
Neutral [Govt
Positive [Govt
No. of Product
Year Founded (Categories
1992 35
1993 6
1992 11
1996 3
1997 2
1987 [5
1994 [1
1975 [19
1992 [26
1975 [1
1989 88
1990 [Undefined
1947 [
1986 [Undefined
1991 [4
1989 [All
1991 [2
1984 [1
1976 [
1991 [35
1992 [1
1997 [N/A
1993 [N/A
1998 50
1993 2
In Progress [In Progress
In Progress [In Progress
In Progress [In Progress
1995-present? [In Progress
A-2
-------
Appendix A: Overview of Environmental Labeling Programs Covered in this Report
Country Seal
Indonesia | Ministry of Trade
Indonesia (Indonesian Ecolabeling Working Group
Germany [Type III
Hong Kong JEco-label
Not Operational |
Australia | N/A
US JOAQPS labels/CA program
Argentina |-
Chile |-
No Information I
Provided |
Greece |
Italy |
New Zealand | Project 98 - food label
US (Flipper
Sweden [Swedish Type III
Germany (Blue Angel's Green Passport - private
Category
Typel
Typel
Type III
N/A
N/A
Mandatory/
Voluntary
V
V
N/A
N/A
N/A
N/A
Type of Label
Seal of Approval
Seal of Approval
Report Card
N/A
N/A
N/A
N/A
Type of Govt/ Non-
Prog ram [Govt
Positive JGovt
Positive | Non-Govt
Neutral
N/A |N/A
N/A |N/A
N/A |N/A
N/A IN/A
No. of Product
Year Founded (Categories
unknown | In Progress
1994 |1
not yet developed |
not yet developed |
N/A |N/A
N/A |N/A
N/A |N/A
N/A IN/A
A-3
-------
Appendix A: Overview of Environmental Labeling Programs Covered in this Report
Country (Seal
Developed
Programs |
Austria (Austrian Eco-Label
Canada [Canada's Environmental Choice
China j-
Croatia (Croatia's Environmental Label
Czech Republic [-
Denmark [Nordic Swan
EU [European Union Ecolabel Award Scheme
Finland [Nordic Swan
France [NF-Environnement
Germany [Blue Angel
Germany [Green Dot
Iceland [Nordic Swan
India [Eco-Mark
Japan [Ecomark
Korea [Ecomark
Luxembourg [European Union Ecolabel Award Scheme
Malaysia [Product Certification Program
Netherlands [Stichting Milieukeur
New Zealand [Environmental Choice
Norway [Nordic Swan Label
Singapore [Green Label Singapore
Spain [AENOR Medio Ambiente
Sweden [SIS-Nordic Swan Label
Sweden IGood Environmental Choice
No. of Awards
150
126
43
15
198
350
182
350
>300
4135
N/A
350
1
2031
219
182
unknown
86
55
350
702
14
350
1139
Indicated that
Standards Have
Changed
Yes
Yes
unknown
Unknown
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
No
Yes
0
Yes
1
Yes
Yes
No
Yes
Yes
Significant
Program
Changes
No
Yes
No
Unknown
Yes
Yes
Yes
Yes
No
No
Yes
No
Yes
No
Yes
No
Yes
Yes
Yes
No
No
Yes
No
Other Programs/
Actvities
No
Yes
No
Unknown
No
No
No
No
No
No
Yes
No
No
Yes
Unknown
No
No
No
No
No
Unknown
No
No
Unknown
Foreign
Based
Licenses
10
10
0
Unknown
0.41
20%
N/A
20%
0
17%
Unknown
20%
0
Unknown
Unknown
N/A
0
0
20%
Unknown
20%
Unknown
Methodology
LCA
LCA
single-attribute or few factors
LCA
LCA
LCA
LCA
LCA
Simplified LCA
modified LCA - only looks at final impact
Single attribute
LCA
LCA
LCA
modified LCA
LCA
single-attribute
LCA
LCA
LCA
simplified LCA
LCA
LCA
simple multi-attribute
A-4
-------
Appendix A: Overview of Environmental Labeling Programs Covered in this Report
Country
Taiwan
Thailand
UK
US
US
US
US
US
US
US
US
US
US
US
US
US
US
us
us
us
us
us
us
us
us
Programs in
Development
Brazil
US
US
US
Finland
Indonesia
Seal
Green Mark Taiwan
The Thai Green Label Scheme
European Union Ecolabel Scheme
Battery Labeling
Chlorine Free Products Association
ECO-O.K.
Ecotel
Energy Guide
Energy Star
Fuel Economy Information Program
Green Seal
ODS - Ozone
Office of Pesticide Program (FIFRA)
Proposition 65
SCS - Claim Certification
SCS - Eco-Profile
SCS - Forestry
SCS - NutriClean
Smart Wood Program
TSCA
Vermont
WAVE
Greening the Government
The Green Pages
US EPA VOC Emission Standards for
Architectural Coatings
ABNT - Environmental Quality
Consumer Labeling Initiative
Electric Utility Labeling
Small Spark Ignited Engines
Type III
BAPEDAL
No. of Awards
102
0
182
N/A
2
about 100
34
N/A
N/A
300
N/A
N/A
N/A
2000
Unknown
50
400 growers
N/A
750
N/A
N/A
N/A
In Progress
In Progress
In Progress
In Progress
In Progress
Indicated that
Standards Have
Changed
Yes
0
Yes
N/A
0
0
unknown
N/A
Yes
N/A
Yes
N/A
N/A
Yes
Yes
Yes
No
No
0
N/A
N/A
No
In Progress
In Progress
In Progress
In Progress
In Progress
Significant
Program
Changes
Yes
Yes
No
No
No
No
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
No
Yes
No
N/A
N/A
No
In Progress
In Progress
In Progress
In Progress
In Progress
Other Programs/
Actvities
No
Yes
No
No
Yes
Yes
Yes
No
Yes
No
Yes
No
No
No
Yes
Yes
Yes
Yes
No
Yes
Yes
N/A
N/A
No
?
In Progress
In Progress
In Progress
In Progress
Foreign
Based
Licenses
4
No
N/A
N/A
unknown
?
Yes
N/A
0
N/A
5
N/A
No
N/A
Yes
Yes
Yes
Yes
No
N/A
No
N/A
N/A
N/A
In Progress
In Progress
In Progress
In Progress
In Progress
Methodology
LCA
LCA
LCA
N/A
single-attribute
Other
proprietary
N/A
single attribute
N/A
LCA
N/A
N/A
single-attribute
single-attribute
LCSEA
Other
single-attribute
single-attribute
N/A
N/A
N/A
single-attribute
LCA
In Progress
In Progress
In Progress
In Progress
A-5
-------
Appendix A: Overview of Environmental Labeling Programs Covered in this Report
Country
Seal
Indonesia | Ministry of Trade
Indonesia j Indonesian Ecolabeling Working Group
Germany Mype III
Hong Kong |Eco-label
Not Operational j
No. of Awards
In Progress
Indicated that
Standards Have
Changed
In Progress
In Progress | In Progress
Australia N/A | N/A
US OAQPS labels/CA program N/A
Argentina j- JN/A
Chile - JN/A
No Information
Provided
Greece
Italy
New Zealand | Project 98 - food label
US Flipper
Sweden (Swedish Type III
Germany
Blue Angel's Green Passport - private
Significant
Program
Changes
In Progress
In Progress
N/A |N/A
N/A IN/A
N/A |N/A
N/A JN/A
Other Programs/
Actvities
In Progress
unknown
N/A
N/A
N/A
N/A
Foreign
Based
Licenses
In Progress
unknown
Methodology
In Progress
unknown
N/A |N/A
N/A IN/A
N/A IN/A
N/A IN/A
A-6
-------
Appendix A: Overview of Environmental Labeling Programs Covered in this Report
Country^
Seal
Use of Non-
Environmental
Attributes
Developed/
Developing
G7
EU
Stage at Which
There is
Stakeholder
Involvement
Used in Procurement
Used on
Retail
Products
Developed
Programs
Austria
Austrian Eco-Label
No
Developed
No
Yes
criteria devlp
Yes, unpecified
Yes
Canada
Canada's Environmental Choice
No
Developed
[Yes
No
prod/crit
Informal
Yes
China
Croatia
Croatia's Environmental Label
Czech Republic
Denmark
Nordic Swan
EU
European Union Ecolabel Award Scheme
No
No
Yes
No
Finland I Nordic Swan jYes
France NF-Environnement JNo
Germany Blue Angel Yes
Germany Green 9°l
Iceland Nordic Swan
India Eco-Mark _
Japan Ecomark No
Korea Ecomark No
Luxembourg European Union Ecolabel Award Scheme No
Malaysia Product Certification Program No
Netherlands Stichting Mijieukeur No
New Zealand Environmental Choice No
Norway Nordic Swan Label
Singapore Green Label Singapore _
Spain IAENOR Medio Ambiente | No
Sweden
SIS-Nordic Swan Label
Sweden
Good Environmental Choice
Yes
No
Developed^
Developed
I No
JNo
[No
Developed
No
Developed NA
Developed
] Developed
No
,__
Developed
Yes
Developed
Yes
Developed
No
Developing
No
Developed
Yes
Developed
No
Developed
N/A
Developed
No
Developed
No
Developed
No
Developed
No
Developed
No
Developed
No
Developed
No
Developed
I No
No
No
Yes
Yes
product selection,
criteria
development
,criteriajdevlp
criteria deyelp
product cat sel,
j criteria devlp
Yes
Yes
product cat sel,
criteria devlp
product cat sel,
criteria devlp
Yes
I criteria devlp
Yes
product cat sel,
finalizing draft
criteria
Yes
I criteria devlp
Yes
product cat sel,
criteria devlp
No
No
icrit
No
I criteria devlp
Yes
No
product cat sel,
criteria devlp
product selection,
criteria
development
Yes
iprod, crit
No
iprod, crit
Yes
product cat sel,
criteria devlp
No
I product critera
Yes
Yes
Yes
product cat sel,
criteria devlp
prod cat sel,
criteria devlp
unknown
Informal
Formal
^
Yes_
'Yes
Yes
Informal
Yes
Formal
Yes
Informal
Yes
Informal
Yes
Formal
Yes
Formal
Yes
No
Yes
Informal
Yes
unknown
Yes
Informal
Yes
No
Yes
Informal
Yes
No
Yes
Formal
Yes
Yes, unspecified
Yes
No
Yes
Formal
Yes
Informal
Yes
A-7
-------
Appendix A: Overview of Environmental Labeling Programs Covered in this Report
Country
Taiwan
Thailand
UK
US
US
US
US
US
US
US
US
US
US
US
US
US
US
us
us
us '
us '
us '
us
us
us
Programs in
Development
Brazil
US
US
US
Finland
Indonesia
Seal
Green Mark Taiwan
The Thai Green Label Scheme
European Union Ecolabel Scheme
Battery Labeling
Chlorine Free Products Association
ECO-O.K.
Ecotel
Energy Guide
Energy Star
Fuel Economy Information Program
Green Seal
ODS - Ozone
Office of Pesticide Program (FIFRA)
Proposition 65
SCS - Claim Certification
SCS - Eco-Profile
SCS - Forestry
SCS - NutriClean
Smart Wood Program
TSCA
Vermont
WAVE
Greening the Government
The Green Pages
US EPA VOC Emission Standards for
Architectural Coatings
ABNT - Environmental Quality
Consumer Labeling Initiative
Electric Utility Labeling
Small Spark Ignited Engines
Type III
BAPEDAL
Use of Non-
Environmental
Attributes
Yes
No
No
No
No
Yes
Yes
No
No
No
No
No
No
No
Yes
Yes
No
No
N/A
N/A
N/A
No
No
In Progress
In Progress
In Progress
In Progress
Developed/
Developing JG7
Developed | No
Developing |No
Developed N/A
Developed (Yes
Developed (Yes
Developing** | No**
Developed (Yes
Developed (Yes
Developed (Yes
Developed (Yes
Developed (Yes
Developed (Yes
Developed (Yes
Developed (Yes
Developed (Yes
Developed (Yes
Developed (Yes
Developed (Yes
|Yes
Developed (Yes
Developed (Yes
Developed (Yes
Developed (Yes
|Yes
Developed (Yes
Developing |No
In Progress | In Progress
developed (Yes
developed (Yes
[No
developing JNo
EU
No
No
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
In Progress
No
No
No
Stage at Which
There is
Stakeholder
Involvement
product cat sel,
criteria devlp
product cat, crit
product cat sel,
criteria devlp
manufacturers
lobbied for law
membership (it's a
trade association)
Y
N
N
Y
N
throughout
n
prog formation
throughout
throughout
throughout
throughout
unknown
N
N/A
N/A
N/A
product cat sel,
criteria devlp
In Progress
Y
Y
In Progress
Used in Procurement
will be formal in future
Informal
No
unknown
Informal
No
No
Formal
No
Informal
No
No
No
Informal
No
No
No
No
Yes
Yes
No
In Progress
In Progress
No
In Progress
In Progress
Used on
Retail
Products
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
N/A
N/A
Yes
In Progress
In Progress
In Progress
Yes
Yes
Yes
A-8
-------
Appendix A: Overview of Environmental Labeling Programs Covered in this Report
Country
Indonesia
Indonesia
Germany
Hong Kong
Not Operational
Australia
US
Argentina
Chile
No Information
Provided
Greece
Italy
New Zealand
US
Sweden
Germany
Seal
Ministry of Trade
Indonesian Ecolabeling Working Group
Type III
Eco-label
N/A
OAQPS labels/CA program
-
-
Project 98 - food label
Flipper
Swedish Type III
Blue Angel's Green Passport - private
Use of Non-
Environmental
Attributes
In Progress
unknown
N/A
N/A
N/A
N/A
Developed/
Developing G7
developing |No
developing |No
Developed |Yes
No
N/A |N/A
N/A IN/A
N/A IN/A
N/A |N/A
EU
No
No
Yes
No
N/A
N/A
N/A
N/A
Stage at Which
There is
Stakeholder
Involvement
In Progress
In Progress
N/A
N/A
N/A
N/A
Used in Procurement
In Progress
In Progress
N/A
N/A
N/A
N/A
Used on
Retail
Products
Yes
Yes
N/A
N/A
N/A
N/A
A-9
-------
Appendix A: Overview of Environmental Labeling Programs Covered in this Report
Country (Seal
Developed
Programs |
Austria (Austrian Eco-Label
Canada [Canada's Environmental Choice
China |-
Croatia (Croatia's Environmental Label
Czech Republic [-
Denmark [Nordic Swan
EU [European Union Ecolabel Award Scheme
Finland [Nordic Swan
France [NF-Environnement
Germany [Blue Angel
Germany [Green Dot
Iceland [Nordic Swan
India [Eco-Mark
Japan [Ecomark
Korea [Ecomark
Luxembourg [European Union Ecolabel Award Scheme
Malaysia [Product Certification Program
Netherlands [Stichting Milieukeur
New Zealand [Environmental Choice
Norway [Nordic Swan Label
Singapore [Green Label Singapore
Spain [AENOR Medio Ambiente
Sweden [SIS-Nordic Swan Label
Sweden IGood Environmental Choice
Used Within
Industry Sector,
i.e. pre-retail
Unknown
No
No
Unknown
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Participating in ISO
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
N/A
Yes
Yes
Yes
Unknown
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Method of Financing
Fees
Fees
Fees and Govt
Unknown
Fees and Govt
Fees and Govt
Member states and fees
Fees and Govt
Fees
Fees
Fees
Fees and Govt
Fees
Fees
Fees
Member states and fees
Fees and Govt
Fees
Fees
Fees and Govt
Govt
Fees and Govt
Funded by Swedish Society
of Nature Conservation and
3 retailers
Indicated Working
with Another
Country
Yes
Yes
No
Unknown
Yes
Yes
Yes
Yes
Yes
No
No
Yes
No
Yes
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Report Trade
Conflict or Issues
Yes
No
Yes
Unknown
No
Yes
No
Yes
No
Yes
No
Yes
No
Unknown
Yes
Yes
No
No
No
No
No
No
No
A-10
-------
Appendix A: Overview of Environmental Labeling Programs Covered in this Report
Country (Seal
Taiwan (Green Mark Taiwan
Thailand (The Thai Green Label Scheme
UK 1 European Union Ecolabel Scheme
US Battery Labeling
US (Chlorine Free Products Association
Used Within
Industry Sector,
i.e. pre-retail
Yes
No
No
No
Yes
US ECO-O.K. Yes
US Ecotel No
US (Energy Guide JNo
US Energy Star Yes
US | Fuel Economy Information Program |No
US Green Seal
No
US ODS- Ozone Yes
US (Office of Pesticide Program (FIFRA)
US (Proposition 65 JYes
US SCS - Claim Certification Yes
US |SCS - Eco-Profile Yes
US |SCS - Forestry Yes
US |SCS - NutriClean Yes
US (Smart Wood Program
us (TSCA
US Vermont No
US I WAVE No
US | Greening the Government | N/A
US | The Green Pages j N/A
[US EPA VOC Emission Standards for
US (Architectural Coatings
Programs in I
Development j
Brazil (ABNT - Environmental Quality
Yes
In Progress
US (Consumer Labeling Initiative |ln Progress
US Electric Utility Labeling N
US (Small Spark Ignited Engines |N
Finland (Type III
Indonesia (BAPEDAL |ln Progress
Participating in ISO
Yes
Yes
Yes
No
Yes
Method of Financing
Fees and Govt
Funded by govt. industry
and private orgs
Member states and fees
Govt
Inspection fees/Member
dues
Indicated Working
with Another
Country
Yes
Yes
Yes
N/A
No
No 1 Donations 1 N/A
No Fees No
No Govt N/A
No Govt N/A
No Govt N/A
Yes
Fees
Yes
No Govt N/A
Govt
N/A Govt N/A
No Fees No
Yes Fees Yes
No Fees No
No Fees No
Govt
N/A Govt N/A
No Govt N/A
N/A N/A N/A
N/A N/A N/A
N/A
Y
Govt
Govt, Other cert, activities
No
No
In Progress | In Progress [in Progress
In Progress j In Progress N/A
In Progress [in Progress N/A
unknown [in Progress (In Progress
Report Trade
Conflict or Issues
No
Yes
No
No
No
No
No
No
N/A
No
No
N/A
No
No
No
No
N/A
N/A
N/A
N/A
N/A
No
In Progress
N/A
N/A
Yes
A-11
-------
Appendix A: Overview of Environmental Labeling Programs Covered in this Report
Country
Indonesia
Indonesia
Germany
Hong Kong
Not Operational
Australia
US
Argentina
Chile
No Information
Provided
Greece
Italy
New Zealand
US
Sweden
Germany
Seal
Ministry of Trade
Indonesian Ecolabeling Working Group
Type III
Eco-label
N/A
OAQPS labels/CA program
_
_
Project 98 - food label
Flipper
Swedish Type III
Blue Angel's Green Passport - private
Used Within
Industry Sector,
i.e. pre-retail
In Progress
In Progress
N/A
N/A
N/A
N/A
Participating in ISO
unknown
unknown
N/A
N/A
N/A
N/A
Method of Financing
In Progress
In Progress
N/A
N/A
N/A
N/A
Indicated Working
with Another
Country
In Progress
In Progress
N/A
N/A
N/A
N/A
Report Trade
Conflict or Issues
Yes
Yes
N/A
N/A
N/A
N/A
A-12
-------
Appendix B:
Summaries of Environmental Labeling Programs
Covered in this Report1'2
Programs are presented in the same order as they appear in Appendix A, "Overview Table of
Environmental Labeling Programs Covered in this Report."
Exchange rates are based on early 1998 values.
-------
-------
List of Environmental Programs Covered in This Report
Country [Program | Page Number
Developed
Programs
Austria
Canada
China
Croatia
Czech Republic
Denmark
EU
Finland
France
Germany
Germany
Iceland
India
Japan
Korea
Luxembourg
Malaysia
Netherlands
New Zealand
Norway
Singapore
Spain
Sweden
Sweden
Taiwan
Thailand
UK
US
US
US
US
US
US
US
US
US
US
US
Austrian Eco-Label
Canada's Environmental Choice
-
Croatia's Environmental Label
-
Nordic Swan
European Union Ecolabel Award Scheme
Nordic Swan
NF-Environnement
Blue Angel
Green Dot
Nordic Swan
Eco-Mark
Eco mark
Eco mark
European Union Ecolabel Award Scheme
Product Certification Program
Stichting Milieukeur
Environmental Choice
Nordic Swan Label
Green Label Singapore
AENOR Medio Ambiente
SIS-NordicSwan Label
Good Environmental Choice
Green Mark Taiwan
The Thai Green Label Scheme
European Union Ecolabel Scheme
Battery Labeling
Chlorine Free Products Association
Consumer Labeling Initiative
ECO-O.K.
Ecotel
Energy Guide
Energy Star
Fuel Economy Information Program
Pesticide Labeling under the Federal
Insecticide, Fungicide, and Rodenticide Act
(FIFRA)
Green Seal
EPA's Ozone Depleting Substance Warning
Label (ODS)
B-1
B-5
B-1 3
B-1 7
B-21
B-23
B-31
B-23
B-41
B-47
B-55
B-23
B-59
B-65
B-71
B-31
B-75
B-79
B-85
B-23
B-89
B-95
B-23
B-99
B-1 01
B-1 07
B-31
B-1 11
B-1 15
B-1 19
B-1 21
B-1 25
B-1 29
B-1 33
B-1 39
B-1 41
B-1 53
B-1 61
-------
us
us
us
us
us
us
us
us
us
us
us
Proposition 65
Scientific Certification Systems -
Environmental Claims Certification Program
Scientific Certification Systems -
Certified Eco-Profile Labeling System
Scientific Certification Systems - Forest
Conservation Program
Scientific Certification Systems -
NutriClean Food Safety Management Program
Product Labeling under the Toxic Substances
Control Act (TSCA)
Vermont
WAVE
Greening the Government
The Green Pages
US EPA VOC Emission Standards for
Architectural Coatings
B-165
B-169
B-173
B-179
B-185
B-189
B-193
B-197
B-201
B-201
B-203
Programs in Development
Brazil
US
US
US
Indonesia
ABNT - Environmental Quality
Consumer Labeling Initiative
Small Spark-Ignited Engine Labeling
Electric Utility Labeling
Environmental Labeling
B-207
B-119
B-210
B-210
B-210
11
-------
AUSTRIAN ECO-LABEL
Introduction
The Austrian Eco-Label was created in 1991 on the initiative of the Federal Ministry of
Environment, Youth and Family Affairs (BMUJF). The Eco-Label is a voluntary, seal-of-
approval, targeted to both consumers and manufacturers. It is designed to draw consumers'
attention to products and services that are "more environmentally friendly as compared to the very
harmful effects inflicted by other products fulfilling the same function" (Umweltbundesamt,
1994). The program also seeks to motivate producers and traders to "develop and offer less
environmentally-polluting products" (Umweltbundesamt, 1994). In addition to evaluating the
environmental impacts of a product, the Eco-Label also certifies the quality of the product,
ensuring "a high environmental standard without having to fear a loss of quality or safety"
(Umweltbundesamt, 1994).
As of August 1997, product criteria have been developed for 34 product categories under the
Austrian Eco-Label. Since 1996, new product categories include tourism, carpets, papers for
magazines, and office chairs. Currently, there are a total of 150 products that have been awarded
the eco-label, and ten foreign companies that carry the Austrian Eco-Label on their products.
Recent Developments
Austria's ecolabeling scheme operates in conjunction with the European Union's (EU)
ecolabeling program. The EU label, however, is not seen as a substitute for the Austrian label. In
fact, "as long as product-related market shares and technology developments differ strongly within
the large market areas like the EU, we [Austria] are of the firm opinion that it cannot be wise to
reject national schemes" (Jakl, 1997). Although criteria for product groups developed under the
EU ecolabeling scheme may be integrated into national ecolabeling programs, the EU Eco-label is
not be a precondition for receiving the Austrian Eco-Label.
Program Summary
BMUJF, the Federal Environmental Agency (UB A), the Austrian Consumer Association (VKI),
and the Austrian Association for the Promotion of Quality (ARGE) are the four primary
organizations responsible for administering the Austrian Eco-Label program. The ARGE
administers and coordinates with manufacturers wishing to obtain the ecolabel. The other three
organizations are involved with criteria development. In addition, several groups - the Eco-Label
Advisory Board and the "expert groups"(one for each product category) — have been established
to assist in the award process. Members of the Advisory Board and the "expert groups" include
individuals from the four administrating bodies, as well as people from environmental protection
organizations, manufacturing, trade associations, consumer protection organizations, and
individual experts.
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-1
-------
Product categories are proposed to the ARGE by manufacturers, institutions, and other interest
groups. ARGE then prepares a summary of the proposals for BMUJF. Based on assessments of
the proposed product groups' overall environmental impacts, the BMUJF decides which product
categories will be pursued for the Eco-Label. Once product categories have been selected, the
Federal Environmental Agency, the BMUJF, and the Consumer Association jointly develop and
propose product criteria. Chaired by the Austrian Consumer Association (VKI), an expert group
(with representatives from a wide range of stakeholder organizations) is responsible for discussing
proposed criteria and coming to a unanimous decision in passing a draft set of environmental
criteria for each product group.
The Eco-labeling Advisory Group approves the draft, which is then subject to a final examination
by the Federal Environmental Agency, who approves the product criteria. The criteria are then
authorized by the Minister for the Environment and published in the official Federal
Environmental Agency gazette, the Wiener Zeitung. Usually, criteria are valid for three years
unless there has been a major technology revision, in which case criteria may be reviewed before
the three years are over. If no manufacturer applies for an ecolabel in a given product group,
criteria for that product group may be withdrawn or altered prior to the three years.
The Austrian Eco-Label may be awarded to both products and services and is open to both
domestic and foreign producers, who submit applications to ARGE. If the manufacturer is in
compliance with the product criteria, a "label utilization contract" is awarded by BMUJF and
signed by the producer. Each product label may be used for two years, after which it is eligible
for renewal. There is an annual fee for use of the label, which varies depending on the sales of the
product; the fee can range from ATS 2,000 ($160.00 US) to an upper limit of ATS 25,000
($2,000.00 US). If a breach of contract is found, BMUJF has the right to prohibit further use of
the label, either temporarily or permanently.
Program Methodology
Product categories are proposed by manufacturers, institutions, and other interest groups to
ARGE. Product categories are selected through an evaluation of the environmental impacts of the
categories, as well as by stakeholder votes or a legislative body's votes. The program reports,
however, that it does not conduct an environmental impact analysis when selecting product
categories or in establishing product criteria.
When developing product criteria, the Austria Eco-Label program conducts a life-cycle
assessment. In setting its criteria Austria Eco-Label collects information from previous literature
and studies pertaining to the product categories, other programs' LCAs, independent testing and
auditing, and information from the manufacturers themselves. Products are assessed on an "all-
embracing and unified evaluation" of not only the environmental effects of product use but also
on the following factors: relative consumption of raw materials and energy during the production
process, toxicity of the product's contents, wastes generated during manufacturing as well as
disposal, recyclability; quality and safety of the product, usability of the product, and durability
B-2 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
-------
and ease of repair of the product. Additionally, Austria assesses product categories on other
factors such as occupational health, human health impacts, the use of animal testing, and general
compliance with health, safety and environmental regulations in the country. Austria Eco-Label
reports that it does not use SET AC guidelines in its life-cycle assessment.
Other Information
During the past year, Austria Eco-Label has participated in discussions with other European
countries to try to harmonize national ecolabeling programs in Europe. Preliminary pilot projects
have been established to try to develop unified product categories for three pilot product
categories - vacuum cleaners, coffee machines, and furniture. The aims of this pilot project are to
1) identify the critical steps in the criteria development process (which could lead to mutual
recognition among programs); 2) establish what the key elements are in criteria development; and
3) to establish mutually-recognized testing procedures among participating countries.
References
Bundesministerium fiirUmwelt, 1996, Fact Sheet, "CertifiedProducts."
Bundesministerium fur Umwelt, 1996, Fact Sheet, "Approved Criteria for Awarding the Austrian
Eco-Label."
Umweltbundesamt, 1994, The Austrian Eco-Label (Booklet).
Dr. Thomas Jakl, Bundesministerium fur Umwelt, personal communication with Abt Associates,
July/August 1997.
Austrian Federal Ministry for Environment, Youth and Family. Austria's Approach to
Environmental Labeling. Website address:
www.bmu.gv.at/bmu/bmu/fachinfo/wum/UWZEnglish.html.
Product Categories
Final Categories
Refrigerators and freezers
Sanitary paper and tissues made of recycled paper
Varnishes and paints
Recycled paper for writing, copying, and EDP purposes (fine paper)
Filing systems made of recycled paper
Exercise books made from recycled paper
Household washing machines
Wood and wooded materials for indoor building purposes
Wooden furniture
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-3
-------
Water-soluble varnishes for wooden floors
Water-saving toilet flush tanks for non-chlorinated plastic materials
Individual electronic controls for sanitary facilities
Reprocessing of ink media (toner-modules, ribbon cassettes, ink cartridges)
Saw-chain oil and lubricants
Copying machines
Solar collectors
Wall paints
Products made from recycled paper (e.g., envelopes, etc.)
Detergents for dishwashers
Detergents for manual use
Textile detergents
Printing paper for newspapers mainly made of waste paper
Total chlorine free bleached paper, made from virgin fiber, for non-impact printing (e.g..
inkjet and high speed laser printers)
Low pollutant print products (publications)
Wood-based playground equipment for outdoor use
Compostable paper bags for biogenic waste
Tickets for public transport (Go-for-the-Environment Tickets)
Returnable bottles for beverages and liquids
Compostments for cemeteries (e.g., compostable flower arrangements, etc.)
Kitchen rolls, paper towels and cleaning cloths made out of recycled paper
Cleaning agents
Tourism enterprises (e.g., hotels, restaurants, etc.)
Carpets
Paper made from recycled materials for magazines
Office Chairs
Categories Under Consideration
Thermal insulation
Heating systems
Energy supplying systems
B-4 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
-------
CANADA'S ENVIRONMENTAL CHOICEM PROGRAM: THE ECOLOGOM
Introduction
"The mission of the Environmental Choice Program (ECP) is to reduce the stress on the
environment by encouraging the demand for and supply of environmentally responsible products
and services"(Canada's Environmental Choice Program., 1996). ECP was created as a voluntary
ecolabeling program by Environment Canada (the environment department of the Government of
Canada) in 1988. In 1995, TerraChoice Environmental Services Inc., a Canadian private sector
company, assumed management of the ecolabeling program, though Environment Canada still
retains ownership.
ECP has published 50 final guidelines, has generated 39 certification criteria documents through
the Panel Review and Certification Process (see below), and has awarded the EcoLogo to over
1,750 products, services, technologies, and events as an indication of their positive environmental
attributes. It has received a generally favorable response from consumers and industry — a June
1996 survey found that one in five Canadians said that they or someone in their household had
purchased a product carrying the EcoLogo in the past year, and that two in three Canadians said
they had confidence in the EcoLogo as a buying guide. Additionally, in a 1995 survey, 80 percent
of marketing managers said they expected some increase in consumer demand for information on
environmental attributes of products.
Recent Developments
ECP has undergone several significant changes in the past few years. As mentioned above, ECP
management was transferred from the government to TerraChoice, a private consulting company.
ECP has also begun a significant marketing program; they publish newsletters, distribute an
ecobuyer guide, and staff attend numerous trade shows. Not only has their marketing increased,
but it has also shifted targets; whereas retail consumers were the focus in the past, they are now
shifting their aim upstream to, for example, industry groups, school boards, and private
institutions. ECP has also increased use of their Panel Review and Certification Process for
awarding labels. Described in detail in the summary section below, this differs from most other
programs in that it will award a label to a single product that is particularly innovative without
previously creating a product category and establishing award criteria. This methodology is very
different from the conventional supply-side approach of most seal-of-approval programs that
create standards for groups of products at a time.
Program Summary
TerraChoice is responsible for selecting product categories, and does so based on either supply- or
demand-side indicators. The supply-side management approach, one of the most commonly used
by ecolabel programs, selects product categories based on the volume of the particular product in
the marketplace and the potential for environmental improvement. The demand-side approach,
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-5
-------
unique to the ECP program, allows manufacturers to request a label for a particular product (most
other programs will field requests for product categories but not for specific products).
Criteria for the category are developed using a Technical Briefing Note (TEN) characterizing the
lifecycle of a product. A Review Committee, including experts from various fields, then reviews
the draft. Upon completion of the proposed guideline by the Review Committee, there is a four-
to-eight-week public review period. While they are not formally required to reply, TerraChoice
responds to most comments. TerraChoice officials, along with the Review Committee, revise the
draft guidelines based on the public comments received. Upon acceptance by the government, the
final guideline is released.
Manufacturers can then apply for an ecolabel for a product meeting the published criteria for the
relevant product category. Applicants undergo a confidential certification and audit process
conducted by TerraChoice. Applicants are responsible for the cost of verifying that the criteria are
met by their product and that they meet general licensing requirements (e.g., compliance with
applicable environmental, safety, and performance legislation). These costs can be between $750
($542 US) to $2,500 ($1,807 US) Canadian dollars based on the certification criteria and the
requirement for site auditing.
Companies can also apply for certification for a product for which criteria have not been
developed, referred to as the Panel Review and Certification Process. Certification of applicants
with unique or niche products or services for which product category standards have not been
established are recommended. An expert panel reviews each specific product application. While
manufacturers are not charged a higher fee for this process, it tends to be more labor intensive
than the process for technical guidelines; the applicant must present a large amount of technical
and marketing information documenting its environmental excellence. If several similar products
apply for the award through the Panel Review and Certification process, TerraChoice may
develop a set of criteria for the product category as described above in the supply-side approach.
Once a manufacturer has been awarded use of the ecolabel, the company enters into a contract
with TerraChoice. The annual fee is based on gross annual sales, and can be anywhere between
$350 and $10,000 per license. Compliance is ensured through an annual statement submitted by
the manufacturer confirming continued compliance, and through a three-year review of guidelines.
In addition, compliance monitoring is conducted and paid for by TerraChoice, and includes
location visits, product testing, and records verification.
Program Methodology
TerraChoice is responsible for selecting product categories, and does so based on either supply-or
demand-side indicators. The supply-side management approach, one of the most commonly used
by ecolabel programs, selects product categories based on the volume of the particular product in
the marketplace and the potential for environmental improvement. The demand-side approach,
unique to the ECP program, allows manufacturers to request a label for a particular product
B-6 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
-------
without the development of overall labeling criteria. If several manufacturers express interest in
certification of the product, TerraChoice then considers the development of labeling criteria for
the whole class of products. These are known as Technical Guidelines.
Technical Guidelines for the category are developed using a Technical Briefing Note (TEN),
which looks at the environmental impacts of the product throughout its lifecycle, as well as
market, economic, and technical information about the product category. In developing the
Technical Guidelines, information from public sources is gathered and evaluated. The Review
Committee then reviews the Guidelines for scientific validity.
Companies can also apply for certification for a product for which criteria have not been
developed, referred to as the Panel Review and Certification Process. Certification of applicants
with unique or niche products or services for which product category standards have not been
established, and which represent a clear and significant reduction in environmental impacts, are
recommended. An expert panel reviews each specific product application. While manufacturers
are not charged a higher fee for this process, it tends to be more labor intensive than the process
for technical guidelines; the applicant must present a large amount of technical and marketing
information documenting its environmental excellence. If several similar products apply for the
award through the Panel Review and Certification process, TerraChoice may develop a set of
criteria for the product category as described above.
Other Information
ECP is sensitive to the constraints of small and medium-sized businesses. Because its fee is based
on sales, the minimum fee is applied to businesses with smaller sales.
The program is informally connected to several governmental and non-governmental procurement
programs. In part, because the government owns the program, the ecolabel is used for
government procurement; most departments in the government are required to be "green,"
creating a large market for products with the label. Additionally, the Green Procurement Institute
is a Canadian organization set up to encourage green procurement. They work closely with ECP
and provide a wealth of information to retailers and governments interested in green procurement.
The EcoBuyer newsletter, mentioned above, is an ECP creation used to reach retailers and
purchasing departments in private companies to inform them about ECP-labeled products. The
ECP reports that, in addition to specifying labeled products, some retailers rely on the criteria
outlined by the Canadian ecolabel but use their own verification process.
ECP is also active in coordination with other non-Canadian labeling bodies. The program is a
member of the Global Ecolabeling Network (GEN), and participates in International Standards
Organization (ISO) activities. ECP plans to incorporate the ISO 14020 and 14024 standards once
they are final. ECP representatives advocate "consistency, high credibility, and mutual respect
between existing and proposed programs," and are working on mutual recognition with other
programs. To this end, ECP has exchanged information with both the Taiwan program and the
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-7
-------
US Green Seal program. Specifically, they are working toward mutual recognition with Taiwan
through standardization of operations based on ISO standards, mutual recognition of non-product-
related impacts, and cooperation in auditing, verification and testing. While the panel review
process was not specifically designed to address these issues, it is a useful process for recognizing
and awarding labels to products from other countries based on their environmental leadership.
Additionally, TerraChoice, acting as a privately hired consulting company, has contracts with both
India and Mexico. While India already has a program structure set up, they have sought
TerraChoice advice and recommendations regarding potential program revisions. Mexico has
sought TerraChoice assistance in assessing the merit of, and issues relating to, the development of
a Mexican environmental labeling program.
While completely separate from ECP, another labeling program is being formed by TerraChoice
and the Ontario Centre for Environmental Technology Advancement called the Environmental
Technology Verification (ETV) Program. In its pilot stage, this program is being coordinated
with the U.S. Environmental Protection Agency (EPA) National Environmental Technology
Strategy and the California EPA. ECP expects to issue "certificates of authenticity" to
environmental technologies under the new program. The program is voluntary, and will provide a
set of standards across Canada and the US.
References
Canada's Environmental Choice Program, October 1996.
The Environmental Monitor., June 1996.
Insight Canada., February 1995.
Canada's Environmental Choice Program. "Environmental Choice Program, Annual Report."
95/96.
Canada's Environmental Choice Program. "Environmental Technology Verification (ETV)
Program." May, 1997.
Global Ecolabeling Network, GENews, March 1997, Issue No. 2.
Binette, Sherry. TerraChoice Environmental Services Inc. Personal communication with Abt
Associates. Summer 1997.
B-8 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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Polak, John C. TerraChoice Environmental Services Inc. Personal communication with Abt
Associates. Summer 1997.
Bozowsky, Evan. TerraChoice Environmental Services Inc. Personal communication with Abt
Associates. Summer 1997.
Canada's Environmental Choice Program. ECP-57 Industrial and Commercial Cleaners, March
1, 1997.
Product Categories (number of awarded products in parentheses)
Final Categories
Automotive engine oil (8)
Products made from recycled plastic (2)
Specialty batteries (4)
Products made from recycled rubber
Water-borne surface coatings (31)
Fine paper from recycled paper
Miscellaneous products from recycled paper (35)
Newsprint from recycled paper
Solvent-borne paints (7)
Diapers(1)
Composting systems for residential waste (1)
Automotive fuels (6)
Reusable utility bags (5)
Energy-efficient lamps
Water conserving products (5)
Commercial car wash services
Automobile service stations
Autobody, collision repair, and refmishing services
General purpose cleaners (4)
Domestic water heaters
Building materials: acoustical products
Dry cleaning services
Building materials: thermal insulation (5)
Remanufactured printing cartridges (1)
Engine coolant concentrate
Adhesives
Sealants and caulking compounds
Photocopiers (1)
Printing inks
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-9
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Gypsum wallboard
Driveway sealers (1)
Photofmishing services
Industrial and commercial cleaners
Lithographic printing services (1)
Toilet tissue (1)
Kitchen towels
Facial tissue
Table napkins
Hand towels
Rechargeable consumer batteries (2)
Office furniture and panel systems
Recycled water-borne surface coatings
Biodegradable, non-toxic chain and saw lubricants
Polyethylene plastic film products (3)
Demountable partitions
Facsimile machines (1)
Marine inboard
Marine foul release coatings (2)
Business forms and other converted paper products
Envelopes
Guidelines Under Development
Biodegradable non-toxic hydraulic fluids
Industrial and commercial cleaners
Resilient flooring
Coated paper
Categories Under Consideration
Wood shakes and shingles
Carpets
Carpet insulation
Pre-finished hardwood flooring
Asphalt shingles
Steel-based roofing products
Fibreboard
Concrete-based products
Particleboard
Panel Review Criteria
Clothing made from certified organic cotton
Source reduced plastic cheese packaging film
Organic turf management service
B-10 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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Source reduced plastic petri dishes
Fire door kit for retrofit projects
Battery powered lawnmower
Cotton swabs
Pressed firewood logs
Technology for industrial laboratory extractions
Energy efficient tires
LaserJet-desk top printers
Household washing machines
Household dishwashers
Packaging management system
Alternative water well rehabilitation technology
Alternative source electricity generation by utilities
Paint and varnish remover
Outdoor furnishings manufactured from waste-wood
Packaging management system
Synthetic industrial lubricant
Flushable and biodegradable sanitary napkin
Particleboard manufactures from an agricultural fibre
Advanced wastewater treatment system
Re-refined industrial lubricating oil
Pouch packaging system for liquid milk
Biodegradable bicycle chain oil
Alternative source electricity generation from biomass utilities
Residential homes
Resin used in the manufacture of compost bags
Remanufactured mattresses
Outdoor community events
Electronic equipment recovery service
Fishing sinkers
Component pulp
Fibreboard manufactures from recycled resources
Warming cooking gel
Office facilities
Anticorrosion chemical for vehicles
Liquid laundry detergent and fabric softeners
In the near future, the TerraChoice website will include continuously updated information on the
ECP, a listing of all ECP certification criteria documents, and directions on how to order/obtain
ECP documents. The website address is: www.terrachoice.ca.
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-11
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CHINA'S ECOLABELING PROGRAM
Introduction
In May 1994, the Chinese government established the China Certification Committee for
Environmental Labeling Products (CCEL) to administer a third-party certification program under
the direction of the China State Bureau of Technology Supervision (CSBTS) and the National
Environmental Protection Agency (NEPA). The establishment of CCEL was prompted by several
factors, including the 1992 UN Conference on Environment and Development, after which the
Chinese government declared environmental stewardship a high priority. Trade issues also
influenced the government's decision to establish a national environmental labeling program since
some exports, such as refrigerators and wallpaper, had been adversely affected in the international
market by the lack of such a product certification program. In fact, some provinces and domestic
manufacturers had already designed their own labeling programs to address these issues.
The purpose of China's environmental labeling program is to "reduce domestic environmental
stress of products by using market forces as a means to supplement mandatory environmental
laws." In addition, the program strives to increase public awareness of the environmental impact
of consumer products, and to promote the trade of environmentally preferable products.
Program Summary
CCEL, chaired by the Administrator of NEPA, consists of 16 government officials and eight
members from various professional disciplines and stakeholder groups including environmental
science, economics, quality standards organizations, consumer associations, and
environmentalists. Its role is to define and administer the policy, principles, and rules of the
environmental labeling program. CCEL reports to CSBTS and NEPA, and relies on a small
Secretariat, seated in NEPA, to handle the day-to-day activities of the program.
China's environmental certification process begins with proposals for product categories, which
may be submitted to the Secretariat by any interested party. The Secretariat reviews the proposed
product category and submits its recommendations to CCEL, which then accepts or rejects the
proposal. This decision is finalized only after approval by both NEPA and CSBTS.
Once a new product category is approved, the Secretariat delegates the task of drafting the new
product criteria to a private standard-setting organization. This draft is edited by the Secretariat
through a multi-party consultation process involving relevant experts and manufacturers. These
criteria are then submitted to NEPA for approval and release to the public.
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-13
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Manufacturers may then apply for product certification. To be eligible, manufacturers must be
legally registered with the appropriate government agency, meet all applicable product quality
standards, satisfy national and local pollution emission requirements, and must not have been
fined or punished by the national or local environmental protection agency for one year prior to
the application submission.
Eligible manufacturers begin the certification process by submitting an application to their local
Environmental Protection Agency. The agency conducts a preliminary review of the product and
submits its findings along with the original application to CCEL. A CCEL inspection team then
conducts a site visit to examine both the product and production processes. In addition, product
samples are tested at a separate laboratory facility. Reports of the inspection and testing
procedure, along with the application, are submitted to the Secretariat, which reviews the
documents and gives its comments to CCEL. CCEL will either convene a plenary meeting or
distribute the application among members to make the final decision. This decision is then
approved and announced by NEPA and CSBTS.
Award recipients sign a three-year contract with the CCEL Secretariat, which grants them license
to use the CCEL seal of approval, given continued environmental compliance. Compliance is
ensured through annual or biannual inspections performed by the local environmental protection
agency.
There are fees for the application process, site inspection and product testing, and product
approval. In addition, there is an annual license fee for use of the label. This fee is calculated
according to a matrix incorporating product sales, the nature of the product, and manufacturer
size. Such scaling helps make the label accessible to large and small manufacturers alike.
Program Methodology
Selection of product categories is based on several factors that reflect the program's goal of
reducing environmental degradation. The program gives preference to products that have
traditionally had significant environmental impact and for which advances in the manufacturing
process can bring about the reduction of such impact. In addition, products must be closely
related to people's daily lives. This condition exists for two reasons: first, the widespread
exposure of frequently-used products helps to raise consumer awareness of environmental impact;
second, even small reductions in the purchase of widely-used products can result in a large
reduction in environmental impact. Low-toxic, low-emission, and energy-saving products that
themselves stimulate the development of new technology and new products are favored, as well as
products that are covered by foreign environmental labeling programs or contribute to global
environmental protection.
B-14 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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CCEL consults other environmental labeling programs in the setting of its own product criteria.
Product criteria are formulated to reflect four major considerations. First, products must meet all
applicable quality, safety, and hygiene standards, as stated by law. Second, labeled products must
minimize their potential environmental impact. Third, the criteria should reflect both the local
conditions in China. Finally, the criteria should be easily understood by the average consumer.
References
"ECOLABELING: Its Implications for China" [Online report]. URL:
http://iisdl.iisd.ca/trade/cciced/ecochina.htm
Heinke, Gary W. et al., Final Report: Development of an Eco-label Certification Programme for
Hong Kong/RC96-19. Hong Kong: Research Centre of the Hong Kong University of Science and
Technology, June 1996.
Product Categories
Final Categories (as of December 1994)
Domestic freezing appliances
Gas dispersed products
Degradable film
Lead-free automobile petroleum
Water-based paint
Toilet paper
Silks
Mercury-free, cadmium-free, and lead-free rechargeable batteries
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-15
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CROATIA'S ENVIRONMENTAL LABEL
Introduction
Croatia's Environmental Labeling program was established to "stimulate the development of new
technologies, the production and consumption of environmentally friendly products, the reduction
of environmental pollution, and rational resource and energy management." The program is also
intended to provide consumers with a guide to make the "best choice" in terms of environmental
protection. Run by the State Directorate for Environment in Croatia, the program is positive and
voluntary.
To date, Croatia's program has developed criteria for 33 product categories, and the Label has
been awarded to products in 15 of these categories.
Program Summary
Croatia's Environmental Labeling program is administered by the State Directorate for
Environment and is run by an expert institution. An appointed Jury, however, makes all decisions
regarding the Label. The Jury is appointed by the Director of the State Directorate for
Environment, and is composed of five members, including representatives from the State
Directorate for Environment, the State Bureau for Standardization and Metrology, industry, trade
groups, experts in environmental protection, and non-governmental environmental associations.
Each Jury member serves for two years.
The Jury selects product categories that have some adverse effect on the environment.
Manufacturers can propose product categories.
Product criteria are established by the expert institution for each product category. Criteria take
into consideration all stages of the product's life cycle and all possible negative impacts during
every stage of a product's life, from its production to its disposal. In particular, criteria are
developed so that awards can be given to products:
that endanger the environment to a lesser extent than other equivalent products,
that can be reused,
that contain replaceable parts,
that reduce harmful emissions to the environment during their use, and
whose manufacturer uses natural resources reasonably.
The development process involves the participation of experts and public stakeholders. The Jury
makes the final decision on selecting product criteria. The product criteria are valid for a specific
period of time that is determined for each set of criteria. At the end of the period, the Jury reviews
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-17
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the criteria and determines whether the criteria are obsolete, or if they can be extended without
revision.
Manufacturers of consumer goods submit applications to the State Directorate for Environment.
It is the Jury's decision as to whether to forward the application to the expert institution. The
expert institution conducts an audit, before and during which the following are collected or
performed: product quality certificate; list of raw materials; description of the technical process;
description of technological modifications; power supply improvements; choice of raw materials;
comparison between the product and similar products in the Croatian market; water resource
permit and waste water quantitative analysis; analysis of the product's impact on water regarding,
among other things, biodegradability; outcome of examining the working environment and
equipment; description of waste disposal methods; and air quality impact assessment. From the
information collected during the audit, the expert institution then issues an opinion on whether or
not to award the Environmental Label. The Jury evaluates the information collected during the
audit to determine whether or not the product is in line with the product criteria and valid
regulations and standards. The Jury makes the final decision on awarding the Label.
References
Preradovic, Nevenka. State Directorate for Environment, Republic of Croatia. Personal
communication with Abt Associates. Summer 1997.
State Directorate for Environment, Republic of Croatia. Environmental Label of the Republic of
Croatia. Summer 1997.
State Directorate for Environment, Republic of Croatia. List of Product Categories for Which the
Specific Criteria are Available. Summer 1997.
State Directorate for Environment, Republic of Croatia. Specific Criteria for Product Groups for
the Environmental Label of the Republic of Croatia. Summer 1997.
Product Categories
Final Categories
Returnable paper packaging
Returnable glass packaging
Returnable plastic packaging
Returnable plastic containers
Returnable metal packaging
Waste paper collection
Waste glass collection
Waste plastic collection
Waste metal collection
B-18 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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Waste rubber collection
Waste oil collection
Scrap paper products
Scrap glass products
Scrap plastic products
Scrap rubber products
Scrap wood products
Carbon dioxide (CO2) from fermentation waste
Asbestos-free clutch linings
Asbestos-free brake linings
Matches free from toxic substances
Fire lighting material free from hazardous substances
Emulsifiers and dispersers of oil spills on water, free from hazardous substances
Hygienic litter for pets free from hazardous substances
Funeral equipment free from harmful substances
Retreaded tires
Reusable ribbon cassettes
Recovered toner cartridges
Water dispersive polymeric coatings
Water-based adhesives
Lubricating oil for motor saw chains
Linen towel on the rail
Paper products for packaging
Detergents
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-19
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THE CZECH ECOLABEL
Introduction
The Czech Republic environmental labeling program was initiated by the Resolution of the Czech
Republic in 1993 and was started in 1994. It organizes its basic principles around the EU
guidelines. "The primary objective of the Czech Eco-labeling Program is to encourage
environmental protection via the production and utilization of products which have a reduced
environmental impact." The program is voluntary in nature, and supports credibility, transparency
and public participation as primary principles. It also looks to provide equal access for domestic
as well as imported producers. The program, to date, has announced 17 categories of products
and has awarded labels to 198 products from 29 companies.
Program Summary
The program is composed of two primary organizing bodies: the Board of the Czech Eco-labeling
Program and the Czech Ecological Institute Agency. The Board is an advisory body to the
Minister of the Environment and administers the program. It is composed of experts from
government, research, quality testing authorities, and environmental and consumer organizations
as appointed by the Minister. The Board assesses categories and criteria for products and submits
suggestions for revisions of the guidelines. The Minister then awards the right to use the ecolabel
and approves guidelines. The Minister also established and financially supports the Agency. In
conjunction with the testing authorities and the Czech Environmental Inspection Division, the
Agency is responsible for examining applications with regard to compliance to standards.
Draft guidelines for product criteria are prepared by an ad hoc group of experts and submitted to
the Board. Manufacturers are closely involved with the process in order to encourage product
design and development improvements. Criteria are revised every two years.
Applicants may then submit an application to the Agency for their product. An initial registration
fee is collected by the Agency. If a label is awarded, the manufacturer enters into a licensing
agreement with the Agency and pays a flat fee of 20,000 CZK. During this two-year contract, the
Agency ensures that the manufacturer meets the requirements.
Program Methodology
Draft guidelines for product criteria are prepared by an ad hoc group of experts and submitted to
the Board. These environmental criteria are developed using a "cradle-to-grave" assessment.
Manufacturers are closely involved with the process in order to encourage product design and
development improvements.
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-21
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Other Information
The Czech environmental labeling program is part of the EU environmental labeling program and
works toward harmonization with other countries through the EU framework. The Czech
program organized a seminar titled "Eco-labelling in the Czech Republic - Harmonisation with
the European Union." In addition, 41 percent of the companies awarded labels by the program are
foreign-based.
References
Ministry of the Environment of the Czech Republic. Eco-labelling in the Czech Republic.
February 1997.
Product Categories (number of awarded products in parentheses)
Final Categories
Thermal insulation made from used paper (1)
Lubricating oil for the cutting edge of chain saws
Textile detergents
Water dilutable paints (20)
Gas-fueled hot-water boilers with atmospheric burners (11)
Gas-fueled hot-water boilers with compressed air burners (6)
Liquid cleaning agents (1)
Water dilutable adhesives and sealants (3)
Hygienic paper made from recycled paper
Graph paper made from recycled paper
Gas-fueled flow-through hot-water boilers up to an output of 50 kW (5)
Wood-based agglomerated materials and products
Hot-water boilers and local solid-fuel units
Briquettes made from wood waste (1)
Hydraulic fluids
Gas-fueled light and dark infra-red radiators
Surfactant-based washing cosmetics
B-22 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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THE NORDIC COUNCIL'S NORDIC SWAN LABEL
Introduction
In 1989, the Nordic Council of Ministers introduced a voluntary and neutral seal-of-approval
certification program know as the Nordic Swan. Currently, Norway, Sweden, Finland, Iceland,
and Denmark are participating in the program. The program was introduced in an attempt to unify
the emerging ecolabeling programs that were appearing throughout the Nordic countries. The
Nordic program is noteworthy because of its novel administrative structure. The Nordic
Ecolabelling Board acts under the Nordic Council of Ministers and makes final program-related
decisions. The participating national organizations propose new product categories, assist the
Board in establishing award criteria, grant licenses, and market the program.
The Nordic environmental label is an "independent label which guarantees a certain
environmental standard. Only products which satisfy strict environmental requirements on the
basis of objective assessments will be allowed to display the environmental label." The label is
intended to provide consumers with guidance in choosing products least hazardous to the
environment, to stimulate manufacturers to develop products and processes that are better for the
environment, and to use market forces as a complement to environmental legislation.
A self-assessment of the program found that the "Nordic Eco-Labelling system - the 'Swan'
symbol - is a fairly successful one, commanding a high level of respect among consumers and
producers." A consumer survey conducted in December 1996 found that 80 percent of Norwegian
customers knew that the Swan was the official environmental label, and 79 percent said that they
prefer products labeled with the Swan. The widespread use of the Swan label on the most
common cleaning products has contributed to the label's visibility.
As of July 1997, criteria for 42 product categories had been established, proposed criteria had
been sent out for review for four product categories, criteria were under development for eight,
and preliminary studies were being conducted for another four. Licenses have been awarded to
over 350 companies, and over 1,200 products currently carry the Nordic Swan logo. Of the
licenses awarded, roughly 20 percent are from non-Nordic countries. Most of the foreign products
carrying the Swan label are paper products; however, computers and photocopiers also carry the
label. The number of products to which the Nordic Swan has been awarded has steadily increased
over time, although when the paper criteria were made stricter in mid-1997, over 100 product
licenses were withdrawn. Given that the new criteria were available six months prior to the
change, about half the companies had already reapplied and re-qualified for the Swan logo.
Recent Developments
The most important change in the Nordic Swan program is the recent addition of Denmark.
Denmark has been a member of the Nordic Council since its foundation in the 1950s; however,
when the Nordic Council established the Swan program Denmark was the only Nordic member of
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-23
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the EU. Rather than adopting the Swan program, it chose to act as an observer and joined the
newly formed EU ecolabel program instead. Because the development of the EU ecolabel
program has not progressed as was anticipated, the Danish parliament decided to join the Nordic
Swan program in 1997.
Another recent development is the thorough evaluation of the ecolabeling system ordered by the
Nordic Council of Ministers in 1994. The results of the evaluation pointed out several inherent
conflicts within the Nordic Council's system, and proposed specific changes with which to make
improvements. These proposed changes included: 1) defining environmental objectives more
clearly, 2) reinforcing activities at the Nordic level, and 3) improving the ability of central
management to control the program's objectives.
Program Summary
The Nordic Swan program is administered in Norway, Sweden, Finland, Iceland, and Denmark by
national boards, coordinated by the Nordic Ecolabelling Board, which in turn acts under the
authority of the Nordic Council of Ministers. The program's agency in Norway is administered as
a foundation, while the Swedish, Finnish, and Danish agencies are incorporated into their national
standardization organizations. The program in Iceland is housed in the Ministry of Environment.
The five programs are very similar to ensure smooth operation and mutual recognition of
activities among participating countries. Fees, structures, and processes are quite similar among
the programs.
The national Nordic ecolabeling organizations propose product groups, and, according to the
General Agreement for Nordic Eco-labelling, a pilot study is conducted to assess "the 1)
qualitative and quantitative environmental problems associated with the product, 2) scope
available for environmental improvements, 3) information needed by consumers, 4) requirements
of commerce and industry for ecolabelling in the field, 5) expected costs of the development of
criteria, and 6) product and market analyses for the Nordic market." The Nordic Ecolabelling
Board makes the final decision on the selection of product groups, and determines which country
will take the lead in developing the criteria.
The Ecolabelling Board usually appoints an expert group to work in an advisory capacity with the
national organizations to develop the product criteria. The expert group is made up of
representatives from the particular industry and consumer and environmental organizations and
includes representatives from each of the Nordic countries. Once developed into a draft, the
criteria are sent out for review in the Nordic countries. According to "Guidelines for Nordic
Ecolabelling," "Information concerning criteria established, ... the composition of expert groups,
and the state of progress of current work shall be open to the public.... The widest possible circle
of interested parties should be heard in connection with all draft criteria." The criteria are to take
into account environmental factors throughout the product's life, although the program considers
it impossible to evaluate the total influence of a product on the environment. In addition to
environmental criteria, the Swan also has a general regulation stating that manufacturers must
B-24 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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comply with domestic labor regulations, as well as quality and performance requirements.
The environmental protection requirements are set such that the market share of products that
meet the criteria should not exceed one third of the total Nordic market. In the past, however,
there have been situations that made this goal difficult to reach. At one point, the trade
association of tissue paper manufacturers boycotted the Swan, and none of their members
companies applied for it, even though they marketed their products' environmental qualities.
Little was done on the part of the Swan program to negotiate, although the story of the boycott
was in the press, and after about a year, the boycott was broken by one of the member companies.
The final set of criteria is either accepted or rejected by the Ecolabelling Board, and all decisions
must be unanimous. Approved criteria are widely available in English, and are available
electronically on the countries' Web sites. Once approved by the Board, a product category and
its criteria are valid in all of the Nordic Council countries. Product criteria are usually valid for
three years, at which point they are reviewed, taking into consideration changes in production
technology and new knowledge about material inputs. The Board has the ability to cancel or
modify the criteria during this period if new information is discovered.
To receive the Nordic Swan, manufacturers from within a Nordic Council country send an
application to the program agency in his/her own country. Foreign manufacturers seeking an
award apply to the country that developed the product category. Claims made by manufacturers
are tested in independent laboratories, and manufacturers are required to perform and report the
results of tests to ensure that all other requirements in the criteria are met for all labeled products.
It is uncommon for products to fail because manufacturers have access to the criteria before they
submit their application. Once an award has been made to a product by one country, the license to
use the label is valid in any of the other participating countries, although manufacturers must pay
an additional fee in each country to register their product. Follow-up inspections of products and
processes are conducted to verify compliance with the award criteria. All documents submitted
by the manufacturer are confidential.
Applicants for the Nordic Swan are required to pay a one-time application fee, between
approximately US$375-!,500, depending on the country. If the application is granted, licensees
also must pay an annual fee in each country where the label is used. The annual fee is .04 percent
of the applicant's annual sales in each country where the product is registered, with a minimum of
approximately US$750-1,400, and a maximum of approximately US$5,500-45,000. The Nordic
Swan's sliding fee scale is designed to be accessible to small and medium-sized businesses;
several companies participating have five or fewer employees. Approximately half of the
program's funding comes from these fees, and approximately half comes from the participants'
federal governments.
Products bearing the Swan logo are also purchased at both the corporate and government level.
Many companies and national and local governments have a purchasing policy requiring that
products they purchase are labeled with the Swan or its equivalent.
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-25
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Program Methodology
For each set of labeling criteria, a report is produced that contains a discussion of the significant
environmental impacts throughout the product life cycle and a discussion of the criteria
themselves. The lead country for the labeling criteria may contract the evaluation of the
environmental impacts to a consultant or academic expert. As a result of the evaluation of the
Nordic program and the recommendations by the Nordic Council of Ministers, there is now more
effort to include each of the participating countries in the development of criteria. There is also
more effort, such as through the use of written product category environmental evaluations and
draft criteria, to increase transparency and participation by other stakeholders in the process.
For example, for the criteria for furniture, the report discussed each of the major components of
furniture (wood, fiberboard, metal, plastic, glazing), the manufacturing of furniture, including the
use of adhesives and coatings, and the associated environmental impacts of each life cycle stage.
Following are the types of criteria for labeling of furniture products that were developed to
address the significant environmental impacts:
Wood: The criteria require the applicant to state the type of wood used and its place of origin.
This requirement will lead to criteria for sustainable forestry, which will be developed in the
future.
Fiberboard: Wood-based board must satisfy the Nordic criteria for environmental labeling of
fiberboard panels, which primarily deal with formaldehyde emissions.
Plastic: Additives to plastic materials shall not be based on cadmium, lead, mercury or other
materials on a restricted list.
Metals: Halogenated organic solvents shall not be used in the processing or surface treatment
of metals. Metals, with the exception of smaller parts as screws, hinges and mountings, shall
not be plated with cadmium, nickel, chrome, and their compounds. Metal paint shall not
contain pigments and additives based on certain heavy metals or contain high solvent content.
Glass: Lead glazing is not permitted.
Adhesives/coatings: The criteria prohibit adhesives or coatings that require health warnings in any
Nordic country because they are classified as allergenic, toxic, carcinogenic, mutagenic or
damaging to reproduction. There are also restrictions on free formaldehyde content and on other
listed hazardous substances.
B-26 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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Other Information
The Nordic Ecolabelling Board is a member of GEN and most of the Nordic countries are
participating with the development of ISO draft standards. Through its work with GEN and ISO,
the Board hopes to increase the coordination with other ecolabeling programs.
The Board is also working with the EU to further develop the EU ecolabel scheme. According to
Norway's information officer, it is Norway's official policy that they will "give up the Swan label
if and when the EU ecolabel is able to replace it." The EU ecolabel will be considered a success
when 80 percent of the public prefer EU labeled products over Swan labeled products; products in
"central" categories like paper and detergents carry the EU ecolabel; and manufacturers apply for
the EU ecolabel more than for the Swan. Norway's information officer does not foresee a
difficult transition from the Swan to the EU if it is based on the aforementioned market pressures.
The information officer also reports that the EU also believes that national and regional labels
should be phased out over the next five years. This non-market based transition could be more
problematic, especially depending on the relative strength of the EU ecolabel program at that time.
References
About the Swan label (Norway). [Online: Web]. Cited 8 September 1997. URL:
http://www.interface.no/ecolabel/english/index.htm
Backman, Mikael. Lund University, International Institute for Industrial Environmental
Economics. Personal communication with Gary Davis. November 1997.
Danish Environmental Protection Agency (Denmark). [Online: Web]. Updated 1996, cited 5
September 1997. URL: http://www.mst.dk/depa/index.htm
Finnish Standards Association (Finland). [Online: Web]. Updated 4 September 1997, cited 8
September 1997. URL: http://www.sfs.fi/summary.htm
Global Ecolabel Network. GENews. March 1997.
Konsument verket - KO. The Consumer and the Environment; Results of a survey into awareness
of the environment amongst Swedish consumers. Konsumentverket & Eurika Research AB.
Sweden. 1996.
Kankaanpaa, Anne. SFS-ECOLABELLING, Finland. Personal communication with Abt
Associates. Summer 1997.
Nordic Council of Ministers. The Nordic Swan; Your environmental choice.
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-27
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Nordic Council of Ministers. General Agreement for Nordic Eco-labelling. 5 October 1994.
Nordic Council of Ministers. Guidelines for Nordic Eco-labelling. 24 January 1996.
Nordic Council of Ministers. Nordic Eco-labelling; Scheme and Evaluation. 1996.
Nordic Ecolabelling Board. Environmental strategy. 2 February 1997.
Nordic Ecolabelling Program. Nordic Ecolabelling of Wooden Furniture. 31/1.2 19 September,
1996.
Nordic Ecolabelling; The Swan (Sweden). [Online: Web]. Updated 7 April 1997, cited 8
September 1997. URL: http://www.sis.se/Miljo/ecolabel.htm
Nordic Environmental Label (Norway, Sweden, Finland & Iceland). [Online: Web]. Updated 26
March 1997, cited 8 September 1997. URL: http://www.interchg.ubc.ca/ecolabel/nordic.html
Organization for Economic Co-operation and Development, Case Study on Eco-Labelling
Schemes. Paris. 30 December 1997.
SFS-ECOLABELLING. The Environment Deserves an Award; Nordic Environmental Label.
1997.
SFS-ECOLABELLING. Nordic Environmental Labelling; Status of Licenses and Criteria
Development. June 1997.
Stokke, Jan Erik. Information Officer, Ecolabeling Norway. Personal communication with Abt
Associates. Summer 1997.
Product Categories (number of awarded products in parentheses)
Final Categories
Adhesives (3)
All purpose cleaners (24)
Automatic dishwashing detergents (10)
Building materials: chipboard fibre board and gypsum board (8)
Batteries, Primary (5)
Batteries, Rechargeable (6)
Car care products (57)
Chain lubricants (1)
Chemical deicers
Closed toilet systems (1)
Coffee filters
B-28 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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Composters (12)
Copying machines (3)
Correction fluids
Detergents for sanitary facilities (12)
Diapers/nappies (6)
Diapers Textile
Dishwashing machines
Dust binding agents
Female sanitary products
Flooring materials (7)
Floor care products
Graphic products
Grease proof paper
Hand dishwashing detergents (4)
Tissue paper (2)
Lawnmowers (9)
Light sources
Marine engines
Newsprint paper
Oil burners & oilburner/boiler combinations (5)
Paper envelopes (12)
Personal computers (2)
Printed papers (50)
Printing papers (46)
Printers & Telefaxes
Refrigerators, freezers
Shampoo & Soap (2)
System for towels in dispensers (1)
Textile detergents (33)
Textiles (4)
Tissue paper (2)
Toner cartridges (14)
Wallcoverings
Washing machines (1)
Wooden furniture and fitments (6)
Writing instruments (1)
Criteria Under Review
Dustbining agents for roads
Folders and ring binders (Fin)
Packaging paper (Sw)
Windows (Fin)
Forestry, sawmill products (Sw)
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-29
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Criteria Under Development
Audiovisual equipment
Boats (Fin)
Boat care products
Concrete (Sw)
Industrial degreasing (Sw)
Heating systems for solid fuels (Sw)
Refrigerating and heat pump plants (Sw)
Tires (Fin)
Water and sewage pipes (Sw)
Water taps with fittings
Wood fired furnaces (Sw)
Preliminary Studies
Sealing agents
Services (Sw)
Telephones (Fin)
B-30 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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EUROPEAN UNION ECO-LABEL PROGRAMME
Introduction
On March 23, 1992, the Council of Ministers of the European Community (EC) adopted a
regulation that created a European Union (EU) "eco-label award scheme." The EU Eco-label
program is intended to "promote the design, production, marketing and use of products which
have a reduced environmental impact during their entire life cycle, and to provide consumers with
better information on the environmental impact of products." (Commission of the European
Communities, 1996.) The program is an element of a broader EU strategy to "promote
sustainable production and consumption."
The EU Eco-label is run by the European Commission and administered at the national level by
Competent Bodies, which are representative organizations chosen within EU member states.
Currently there are Competent Bodies in 17 countries.3 Eight of the member states participate in
their own environmental labeling program, while other national programs rely strictly on the EU
Eco-label.4 Currently, the EU program is being revised (the revision process is explained below).
The proposal for the revision envisions full complementarity between the EU Eco-label and the
national labels with regard to those products for which there are EU criteria.
To date, criteria have been published for 11 product groups and 12 others are in the development
process. The Eco-label has been awarded to 182 products, which corresponds to 40 licences
awarded to 22 manufacturers and one importer. The EU Eco-label program considers it too early
to assess the market effects of the Eco-label, given that it is still developing and has yet to gain
visibility.
Recent Developments
The EU Eco-label program is currently undergoing a major revision of Regulation 880/92. While
the program has evolved considerably since it was created in 1992, it is apparent to the European
Commission that there is a need to "streamline and improve the approach, methodologies, and
working procedures in order to increase its effectiveness, efficiency and transparency." (EC
Newsletter on the EU Eco-label, 1/97) According to the Eco-label Revision, COM (96) 603 final,
SUMMARY, the current program needs to be revised because:
3 Austria, Belgium, Denmark, Finland, France, Germany, Greece, Iceland, Ireland, Italy, Luxembourg,
Netherlands, Portugal, Spain, Sweden, United Kingdom, and Norway. Norway and Iceland have Competent Bodies
but cannot vote because they are not EU members, but members of European Economic Area (EEA).
4 Austria, France, Germany, Netherlands, and Spain have their own ecolabeling programs. Denmark,
Finland, and Sweden participate in the Nordic Swan. Iceland and Norway participate in the Swan as well, but are
not member states.
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-31
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1. the present Eco-label program is considered to be too bureaucratic;
2. the program needs to be clarified, streamlined, and simplified in order to achieve greater
market penetration;
3. there is international pressure to better incorporate trade principals such as transparency,
non-discrimination, and use of internationally recognized standards; and
4. the proliferation of national ecolabel programs needs to be to curbed, since it can lead to
internal market distortions and consumer confusion.
The following are among some of the changes that the Commission proposed in the revision:
1. establishment of an independent European Eco-label Organization to develop criteria, thus
taking the political process out of the eco-label scheme;
2. introduction of a graduated label with one "flower" representing the achievement of a
baseline standard, and two or three representing an improvement;
3. introduction of substantive provisions for ensuring compatibility with international trade
principals;
4. increased "complementarity" between the EU and the national programs in the EU, and
introduction of a ceiling for the annual fee and a reduced fee for small and medium-sized
businesses;
5. ability of non-European producers to apply directly to the scheme; and
6. ability of retailers to apply for products under their own brand name.
Before being adopted, the proposal must be approved by both Parliament and the Council of
Ministers. The approval process is iterative, and will require compromises and negotiations. The
European Parliament is currently preparing comments on the proposal, at which point the proposal
and comments will be sent to the Council of Ministers for comments. A representative from the
EU Eco-label program reported that the proposed changes could be adopted by the end of 1998;
however, there is no schedule. The representative pointed out that the revision process is quite
slow, due to the numerous institutions, industry representatives, and government bodies that are
involved, as well as to the wide range of views about the EU Eco-label that must be considered.
One of the aims of the EU revisions is to create conditions favorable to ultimately establishing a
single ecolabel in the European Community. According to the EU Eco-label program, it is not
likely that the EU Eco-label without programmatic revisions will "supersede national schemes in
the long run," unless "positive action" is taken to stop the proliferation of national programs.
Even though national programs have contributed to environmental improvements, they limit the
market value of the EU Eco-label; the co-existence of national ecolabels, private ecolabels, and
the EU Eco-label is causing confusion in the marketplace. The EU Eco-label program is
proposing that over the next five years, national programs phase out the separate labeling of
product categories that are covered by the EU Eco-label program. The EU representative noted
that the full transition to a single European ecolabel would take much more time.
B-32 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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Program Summary
Several bodies are currently involved in the development to the EU Eco-label program. The
proposed changes would greatly simplify this process. Under a revised Regulation, the European
Commission will be responsible for the adoption of the Eco-label product groups through
Commission's Decisions published in the EC OfficialJournal. The Commission facilitates the
program operations and seeks guidance from and consensus among all the other parties.
Competent Bodies (representative organizations within each EU member state) are designated in
Member States to administer the program at the national level. The Committee of Competent
Bodies meets every two to three months and before decisions are made. Interest groups
participate in these meetings. The Consultation Forum provides stakeholder input, and is
composed of Community-level representatives of five interest groups: industry, commerce,
consumer organizations, environmental organizations, and trade unions. There are 14 members in
the Forum. The Regulatory Committee, chaired by a non-voting representative of the
Commission, has final approval of criteria for product categories and settles any objections made
during the award process.
Proposals for new product categories are accepted from any interested party. The selection of
product categories is usually initiated by the Commission. The Commission conducts a feasibility
study to assess the suitability of the proposed product group, which is evaluated by the ad hoc
working group. The ad hoc working group meets at key stages of the process, and is composed of
representatives from Competent Bodies, interest groups, and the Consultation Forum.
To develop product criteria, the Commission conducts a market survey to understand the market,
and takes an inventory of the impacts of the product on the environment. The impacts are
quantified objectively on a "cradle-to-grave" or life-cycle basis using the indicative assessment
matrix shown below. These impacts are then evaluated in an environmental impact assessment,
which involves a life-cycle assessment (LCA). (The European Commission has issued guidelines
for applying LCA.) Based on this analysis, product criteria are proposed. EU's goal is that the
product criteria are strict enough so that ecolabeled products represent only 5 to 30 percent market
share. The proposed criteria are presented to the Consultation Forum and voted upon by the
Regulatory Committee, although the Commission makes the final decision on adopting the
criteria. Criteria are valid for three years, at which point they are re-evaluated.
Competent Bodies accept applications from manufacturers of products that are produced or first
marketed in their country, and from foreign manufacturers who first import into the EU through
their country. Results of independent testing must be submitted with the application, and testing
fees are to be paid by the applicant. Awards given to products must be approved by all Competent
Bodies, via the Commission. Competent Bodies award the ecolabels within their country, and
they must monitor that the ecolabels are properly used.
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-33
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An application fee of 500 ECUs (-US$550) is required to cover administration costs, and, if the
product receives the award, an annual licensing fee is calculated as 0.15 percent of the annual
volume of sales within the EC. These are guideline figures; Competent Bodies have the discretion
to set actual fees at levels 20 percent greater or smaller than the guideline figures.
Program Methodology
To promote consistency in the use of LCA in the Eco-label scheme, the European Commission
has issued Guidelines for the Application of Life Cycle Assessment in the EU Eco-Label Award
Scheme, prepared by the so-called "Groupe des Sages," a group of European LCA experts. First,
the guidelines make it clear that "LCA does not replace, or eliminate the need for other
considerations and processes within the decision-making procedure aimed at setting eco-label
criteria." LCA, according to the guidelines, is "used to identify key environmental aspects for the
product group considered and provide quantified data on the range of such impacts." Other
assessments are also necessary to determine the criteria, including the market share of the product,
the technical and economic feasibility of meeting the criteria, and the ability of the criteria to
achieve maximum overall environmental improvement.
The proposed approach for criteria development has not yet resulted in any product criteria, but
the following examples illustrate the manner in which the studies and criteria development are
proceeding under the new guidelines.
Example: Converted Paper Products
The contract to develop the draft criteria for labeling converted paper products was awarded in
late 1995 to a Danish consulting firm. Converted paper products include envelopes, stationary,
notebooks, and account registers as the principal product categories. The consultants prepared a
market and feasibility survey in early 1996, which was reviewed in April 1996 by the ad hoc
working group of experts that had been assembled by the EC. The ad hoc working group decided
that an extended market survey should be prepared in order to define as many product
subcategories for the labeling criteria as possible in order to widen the environmental benefits of
the label. This extended market survey was completed in October 1996 and identified ten product
subcategories within the overall category of converted paper products.
From this market study a goal and scope were defined for a life-cycle inventory that was
completed in October 1996. It was difficult defining a functional unit that would serve as the
basis for LCA of several diverse subcategories of products. The functional unit recommended
was 1 kg of paper used for the further manufacturing of the products. The LCA performed
stopped at this boundary and did not develop quantitative data on production processes beyond the
production of paper.
The EC and the consultants originally intended to gather primary data from the product
B-34 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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manufacturers, but these manufacturers and their trade associations were unable or unwilling to
provide the data for such a diverse range of product subcategories. Instead, the consultants relied
upon publicly available databases for data on the significant manufacturing processes involved in
the life-cycle of paper. The LCA report issued in October 1996 was more of a compilation of
these process data than an actual LCA, because it did not combine the processes and process data
into the production of a functional unit of 1 kg of paper.
The ad hoc working group met again in the fall of 1996 and could not come to consensus on the
functional unit that would apply to all of the product subcategories. There was a concern that the
proposed functional unit would focus more on the process of paper making than on the finished
products. As a result of the lack of consensus, one product subcategory was chosen, envelopes,
for further study and development of labeling criteria. Envelopes were chosen because they are a
well-defined product subcategory and are produced and consumed in greater quantities than any of
the other subcategories. While it was suggested by the ad hoc working group that plastic
envelopes should be considered in the product category, it was not feasible to develop a market
study and it was not feasible to develop a functional unit for evaluation. The LCA study did
include some data concerning plastic envelopes to allow for comparison to paper envelopes.
Once the product category was narrowed to paper envelopes, the functional unit was defined as
standard-sized envelopes with a clear plastic window. The consultants defined the goal of the
LCA as "semi-quantitative," because it was not possible within the time and resources available to
compile data for all the products and substances involved in the production of envelopes and it
was impossible to define certain inputs during the manufacturing stage (e.g., the amount of ink
used to print on the envelope) in terms of the functional unit of the envelope. The quantitative
data were mostly related to the pulp and paper process, whereas the qualitative information was
mostly related to the chemicals used when converting paper to envelopes and to the specific
properties of substances that can affect the recycling of paper envelopes. Recycled paper as an
input and recycling as an end-of-life management method were included in the LCA study.
Meetings were held with five envelope producers during the LCA phase to gain a clear
understanding of the process of manufacturing and to collect some specific data. A meeting was
also held with Greenpeace International, and written comments from the American Forest and
Paper Association were also taken into account.
Although life-cycle data on some of the materials used in envelopes, such as glues, were not
gathered, it was still necessary and possible to address these materials in the development of
criteria. Glues, for instance, can contain toxic substances and can also significantly affect
recyclability of envelopes. Lists of substances contained in these glues were made as part of the
study.
The LCA report discussed in detail each stage of the life cycle of envelopes and identified the key
environmental features for each. Then an impact assessment was performed by categorizing key
inputs and outputs into impact categories and identifying impacts as local, regional or global. The
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-35
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impact categories addressed were: energy consumption (e.g., purchased electricity, feedstock
energy in raw material); consumption of raw materials (e.g.,water, wood, recycled paper, fossil
fuels); eutrophication and pollution of streams and lakes with organic matter (e.g., Chemical
Oxygen Demand - COD); toxicity of halogenated organic discharges to water (e.g., Adsorbable
Organically bound Halogens - AOX); global warming-emissions of CO2, etc.; acid
rain—emissions of SO2, Nox; and substances affecting recycling of paper products.
Labeling criteria were proposed to address these life-cycle impacts, which included the following:
requirement to use recycled paper or wood from sustainably managed forests as raw material;
substances used for surface coatings, sizing, and glueing should be re-pulpable when the paper is
recycled; restrictions on substances used for glues, coatings and inks due to toxicity; the envelope
should be de-inkable; plastic films should not be used as coatings; plastic windows should be
either re-pulpable or filterable when the paper is recycled; limits on releases of COD and AOX to
water from the pulp and paper production; limits on emissions of CO2, SO2, and NO2 to air for
pulp and paper production; limit on percentage waste from cutting of envelopes; limit on energy
consumption in pulp and paper production.
Example: Shampoos
The EC contracted with the consulting firm to perform the feasibility and market study and LCA
for shampoos in late 1995. The feasibility report, delivered in April 1996, was based on a review
of the industry and consumer literature, interviews with company representatives and trade
association representatives, and a review of available life-cycle data for major ingredients of
shampoos (surfactants). The report recommended proceeding with development of labeling
criteria for liquid shampoos, excluding professional shampoos, dry or mousse shampoos, and
shampoos sold only by prescription. Because the amount of shampoo per use varies so much with
the user, the consulting firm recommended that the functional unit be based upon the main
characteristic of shampoos, their detergent power.
The feasibility study and recommendations were discussed in the ad hoc working group in the
spring of 1996. Because there was no reliable test available to develop a functional unit based
upon the detergent power of shampoos, the ad hoc working group decided to base the functional
unit on the dry organic content of shampoos per average dose, which was defined as 3 grams of
dry organic matter. The consultants then prepared an LCA study based on this functional unit to
be used to develop the labeling criteria.
The data collection for the LCA study was made difficult by lack of industry participation. The
industry's lack of participation stemmed, at least in part, from a disagreement with the EC over
whether a practical functional unit could be established for the development of criteria for labeling.
As a result, the consultants focused the life-cycle inventory on the major ingredients of shampoos,
surfactants, and on the packaging, and relied upon existing LCA data for the study. Not
surprisingly, the use stage predominated for energy consumption and air emissions, especially
when the consultants took into account the use of hot water for washing and rinsing and the use of
B-36 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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a hair dryer for drying the hair. Based upon the available surfactant life-cycle inventory data, the
consultants concluded that differences in surfactant production impacts were dwarfed by the use
stage impacts. The firm also concluded that packaging type was significant principally in the
end-of-life stage when incineration was included as a waste management method for certain
plastics.
Applying life-cycle impact assessment to the inventory results, the consultants recommended that
criteria for labeling be set to address the following impacts: energy and water consumed during
use—consumer guidance on the bottle could recommend lowering water temperature, for example,
or the use of water conserving devices; packaging waste generation—decrease primary packaging
through refills or by increasing recycled content of bottle; water pollution during use-criteria to
address biodegradability, bioaccumulation, and nitrogen content; and dangerous
ingredients-criteria to restrict certain toxic substances.
Other Information
The EU Eco-labeling program is actively participating in ISO draft standards negotiations. The
proposed changes to the EU program are designed in part to ensure compatibility with the ISO
standards for environmental labeling. When ISO standards are finalized, the EU program will
incorporate them into their standards. In addition, steps have been taken to ensure full access, non
discrimination (EU and non-EU parties will be "treated on an equal footing"), and transparency for
foreign interests (largely late in the process). No mention is made of possible conflicts between a
life-cycle-based product evaluation and GATT's prohibition of trade restrictions based on
processing and production methods (PPMs). The EU is not a member of GEN, but may request to
become a member shortly. Several of the member countries are members of GEN.
In an effort to make the EU Eco-label program transparent and to increase its visibility, the
following information is published in the OfficialJournal of the European Communities:
Commission decisions on product groups, product criteria, a list of products for which the Eco-
label has been awarded, the names of the licensees, and the names and addresses of the Competent
Bodies. It addition, a quarterly newspaper is published by the Commission that provides "an
update of the work in progress for each product group," as well as the names of the Competent
Bodies and the members of the Consultation Forum (OECD, 14).
The EU Eco-label program does not currently have a program for small and medium-sized
businesses; however, it is accessible to them via a sliding fee scale. As mentioned above, the
proposed revision would include provisions to reduce the annual fee for small and medium-sized
businesses.
In addition to the Eco-label program, the EU is going to introduce a directive for end-of-life
electronic equipment. Initially it will address the electronics industry. It has not been decided,
however, if the directive will follow the published draft directive for end-of-life vehicles. The
planning group will begin working on the draft in fall of 1997 and hopes to present the draft to the
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-37
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Member States and industry later in the fall.
References
Aksel Bagh, John, dk-Teknik. Personal communication with Gary Davis. 23 April 1997.
Butzkamm, Rainer. European Commission, Brussels. Personal communication with Abt
Associates. Summer 1997.
Butzkamm, Ranier, and Olivier Luansi. European Commission, DGXI. Personal communication
with Gary Davis. April 24, 1997.
Ecobilan. European Ecolabellingfor Shampoos: Feasibility Study. April 1996.
Ecobilan. European Ecolabelling for Shampoos: Inventory, Environmental Impact Assessment.
Feb. 1997.
Etienne, Roger. Ecobilan. Personal communication with Gary Davis. 25 April 1997.
Eco-label (EU). [Online: Web]. Cited 16 January 1997. URL: http://www.ns.ec.gc.ca/g7/eco-
eur.html
European Commission. Commission Information on Eco-Labelling: Procedural Guidelines for
the establishment of product groups and ecological criteria, Issue No. 6. June 1994.
European Communities, Commission of the, Eco-label Revision; COM (96) 603 final;
SUMMARY.
European Communities, Commission of the, EU Eco-label Awards. 14 May 1997.
European Communities, Commission of the, Proposal for a COUNCIL REGULATION (EC) on a
revised Community eco-label award scheme; COM (96) 603 final. Brussels: 11 December 1996.
European Commission, prepared by the Groupe des Sages. Guidelines for the Application of Life
Cycle Assessment in the EU Eco-label Award Scheme. 1991.
European Commission, Environment, Nuclear Safety & Civil Protection. Several pages on eco-
label. [Online: Web]. Cited 2 July 1997. URL: http://europa.eu.int/en/comm/dgll/dgllhome.html
Global Ecolabel Network. GENews. March 1997.
B-38 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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H.A. Udo de Haes, et al. Guidelines for the Application of Life-Cycle Assessment in the EU
Ecolabelling Programme, Leiden, The Netherlands. May 1994.
Heinke, Gary W. et al., Final Report: Development of an Eco-label Certification Programme for
Hong Kong/RC96-19. Hong Kong: Research Centre of the Hong Kong University of Science and
Technology, June 1996.
Jones, Michael R. UK Ecolabelling Board. Personal communication with Abt Associates.
January 1997.
Organization for Economic Co-operation and Development, Case Study on Eco-Labelling
Schemes. Paris. 30 December 1997.
Pulp & Paper. "EU's new 'eco-label' called trade barrier." October 1996: 19-20.
UK Ecolabelling Board. UK Ecolabelling Board Newsletter: Ecolabel Criteria. No. 10. August
1996.
UK Ecolabelling Board. UK Ecolabelling Board Newsletter. No. 11. April 1997.
Wheeler, David. "EC Ecolabelling myths." Chemistry and Industry. 5 April 1993.
Product Categories
Final Categories
Washing machines
Soil improvers
Toilet paper
Paper kitchen rolls
Laundry detergents
Single-ended light bulbs
Indoor paints and varnishes
Bed-linen and T-shirts
Double-ended light bulbs
Copying paper
Refrigerators
Criteria Under Review
Dishwashers (being revised)
Footwear
Cat-litter
Study Underway
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-39
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Bed mattresses
Batteries for consumer goods
Floor-cleaning products
Detergents for dishwashers
Shampoos
Rubbish bags
Converted paper products
Study Temporarily Suspended
Growing media
Insulation materials
Hair sprays
Preliminary Phase of Study
Personal computers
Textile products
B-40 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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FRANCE'S NF-ENVIRONNEMENT MARK
Introduction
France's national, voluntary ecolabeling program, the NF-Environnement Mark (Norme Fran9aise
Environnement), has two functions: first, to fulfill the need for reliable information on the
environmental attributes of a product, and second, to recognize and reward companies that take
environmental attributes into consideration when making a product. The NF-Environnement Mark
is a seal-of-approval program aimed at certifying products that have a reduced negative impact on
the environment. Development of the label began in 1989. However, because of initial opposition
from industry, the program was not fully operational until 1992. The main administrative body for
the NF-Environnement Mark is the AFNOR (Association Fran9aise de Normalisation,) the
standards institute of France.
As a relatively new program, there have been only a few product categories for which product
criteria have been established. Currently, the NF-Environnement Mark can be awarded to products
in six product categories. There are over 300 products that carry the NF-Environnement Mark with
the majority of these in the paints and varnishes (160) and garbage bag categories (100), because
these were two of the first categories established. The number of eco-certified products in the
paints and varnishes category is expected to drop once criteria for this category are revised.
Despite being a relatively new program, the awareness of ecolabeling in France is growing. In
1996, AFNOR asked CREDOC, one of France's largest national polling agencies, to survey 2,000
French households (representative of the population in France). The purpose of the survey was to
characterize consumers' opinions on ecolabeling and environmental products. According to the
survey, 63 percent of the respondents said that there is a lack of quantitative and qualitative
information about "green" products and 92 percent of those surveyed said that they preferred
products with less packaging. Of those surveyed, 54 percent said that they would be willing to pay
up to 10 percent more for ecological products. The program hopes that "consumer leaders," those
who are aware of the NF-Environnement Mark and ecolabeling in general, will spread the word to
others about ecolabeled products (Boeglin, 1997).
Recent Developments
On June 24, 1992, work on NF-Environnement Mark was suspended by the AFNOR pending a re-
evaluation of its methodology. Originally, the NF-Environnement Mark planned to use a multi-
criteria matrix similar to Blue Angel and the EU Eco-label. Products were assessed using a
systematic life-cycle assessment (LCA), which looked at products from "cradle-to-grave" (i.e.,
amount and types of raw materials used, production, transportation, effects of consumption, and
disposal), to evaluate their overall environmental impacts at each of these stages. However,
because of the time-consuming nature and costs associated with LCA, AFNOR decided upon a
modified life-cycle analysis approach, called the "New Simplified Procedure," to develop criteria
and to evaluate products to receive the label (Boeglin, 1997). This new procedure uses a semi-
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-41
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qualitative life-cycle assessment for the product, and identifies the "key stages" in the product's
life cycle that have the most significant environmental impacts. This new process is iterative based
on both qualitative and quantitative data. The "New Simplified Procedure" was adopted to make
the NF-Environnement Mark less expensive and more available to small and medium-sized
businesses and industries.
NF-Environnement Mark plans to coordinate its efforts with other European programs, "both
through the process of harmonization of standards and through its participation in European
reciprocal recognition agreements" (General Rules, 1992). As a result of this coordination of
efforts, the product criteria for paints and varnishes were approved on June 3, 1992, based on a
study originally conducted for the EU Eco-label. NF-Environnement Mark is currently not a
member of the Global Ecolabelling Network (GEN) for financial and logistical reasons. However,
AFNOR is considering becoming a member soon to take advantage of the information exchanged
through GEN membership. AFNOR participates regularly in meetings and exchanges with other
ecolabeling programs on trade issues, standards development, and program implementation.
Program Summary
Four groups are involved in the NF-Environnement Mark program: the NF Environmental Label
Committee (Comite de la Marque), composed of 18 representatives from various stakeholders,
including industry, manufacturers, wholesalers, consumer and environmental protection
associations, and the French Ministry for the Environment; the ADEME (French Energy
Management and Environment Agency); the AFNOR (the French Institute for Standards); and
other stakeholders particularly interested in the product category.
The NF-Environnement Mark can be awarded to consumer goods and intermediate products.
Theoretically, anyone can propose new product categories. In practice, however, industry
representatives or environmental authorities such as ADEME, typically propose products that they
feel may be suitable for the ecolabel. These proposals are collected by AFNOR and submitted to
the Label Committee, who then chooses the product categories for the ecolabel. Based on
environmental evaluations using the "New Simplified Approach," the Label Committee, decides if
the overall product group(s) in which the proposed product(s) belong, would be good candidates
for the NF-Environnement Mark.
Draft product criteria, or as they are known, the "Reglement Technique" (Technical Rule), include
all the specific guidelines (environmental, product performance, advertising, etc.) which
manufacturers must meet to be awarded the NF-Environnement Mark. Once finalized by the
Committee and approved by the General Director of AFNOR, the criteria are published in the
Journal Officiel (France's equivalent of the United States Federal Register), and applications for
the NF-Environnement Mark are accepted. Product criteria are usually re-evaluated every three
B-42 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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years, but may be evaluated sooner if there are new breakthroughs in technology relating to the
product category. Only the garbage bag and paints and varnishes product categories have reached
their three-year revision periods — the other four product categories have been so recently
established that they still have another one to two years before their product criteria are re-
considered.
Applications for the NF-Environnement Mark are sent to the General Director of AFNOR. The
manufacturer must pay a flat-rate registration fee of 420 Francs (approximately $2,500 US) to
cover the costs of processing the application. In addition, the manufacturer must repay the costs of
verifying that the product conforms to the Technical Rules, as well as pay a site visit fee, an
administration fee, and compliance test fees. In addition, an annual royalty payment (0.1 percent of
the product sales) is payable for the right to use the NF-Environnement logo. If a manufacturer is
found to be mis-using the NF-Environnement Mark, AFNOR may apply sanctions on the product
and/or may withdraw the manufacturer's right to use the ecolabel.
Program Methodology
Once proposals for products categories are made and collected by AFNOR, environmental
evaluations based on the "New Simplified Approach" are made by the Label Committee, who
decides if the overall product group(s) in which the proposed product(s) belong, would be good
candidates for the NF-Environnement Mark. Though a full LCA is not conducted, information
from other programs' LCAs, where available, and information from producers are used in
evaluating a product's suitability for the label. In addition, the program follows SET AC guidelines
in its evaluations.
When developing product-specific criteria, products are assessed to determine their environmental
impacts, based on multiple ecological factors, (e.g., the impact of the products' wastes on the
environment — to air, water, and soil). Once identified, these impacts are quantified for setting
threshold levels (e.g.,, limits on toxicity of chemicals, VOC content, hazardous materials content,
etc.). Products are also assessed on the following: energy use, raw material extraction and use,
emissions during production, product uses, potential for recycling, disposal, product ingredients,
type of wastes generated, environmental and health and safety hazards, and durability as well as
real duration of use. Additionally, the NF-Environnement Mark conducts a generic environmental
impact analysis when developing product criteria.
The NF-Environnement scheme invites stakeholders from various organizations to participate in all
stages of criteria development. For example, a working group composed of representatives from
industry, retailers, environment, and consumer NGOs, AFNOR, and if needed, experts from the
concerned product sector, are involved in drafting the Technical Rule. Foreign companies are also
invited to participate in the draft criteria development but must first express their interest in
participating in the process. They may then be given the option of participating in the criteria
development process and will at least be told what the draft criteria are and be invited to provided
their comments. For example, several foreign garbage bag and vacuum cleaner manufacturers
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-43
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were involved in the criteria development for these categories.
Other information
Although possession of the NF-Environnement Mark is not an official requirement for
procurement, some distributors of paints and varnishes, and/or retail stores, require that their
suppliers provide at least one line of product that carries the NF-Environnement Mark.
Additionally, certain municipalities and local authorities have specified that the garbage bags they
purchase must bear the NF-Environnement Mark.
Because the NF-Environnement Mark is a relatively new program, there have been no studies to
determine overall trade and market effects. The NF-Environnement Mark has not yet developed
product criteria for products imported from developing countries. The only foreign products that
have been awarded the French ecolabel have been products manufactured by European companies.
Because the NF-Environnement Mark is a relatively new program, it has not yet gained
international recognition, and information about the program has not been available internationally
— in fact it is still in the early stages of recognition domestically.
References
Boeglin, Nadia, AFNOR, personal communication with Abt Associates, May 1997.
Organization for Economic Co-operation and Development, Case Study on Eco-Labelling
Schemes. Paris. 30 December 1997.
Association Fran9aise de Normalisation (AFNOR), 1997, Fact sheet: La Preuvepar NF-
Environnement.
Association Fran9aise de Normalisation (AFNOR), February, 1997, Information File on the NF-
Environnement Mark.
Association Fran9aise de Normalisation (AFNOR), April, 1997, La Marque NF-Environnement.
ADEME (French Energy Management and Environment Agency), Background information and
statistics from the CREDOC survey (1996).
Association Fran9aise de Normalisation (AFNOR), 1992, General Rules Applicable to the NF-
Environnement Label.
Davis, G.A., The Use of Life Cycle Analysis in Environmental Labeling, US Environmental
Protection Agency, Office of Pollution Prevention and Toxics, EPA/742-R-93-003, September,
B-44 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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1993.
Proia, Patricia, AFNOR. Personal Communication with Abt Associates (Gary Davis). April,
1997.
AFNOR. Information File on: The NF-Environnement Mark, February 1997.
Etienne, Roger, Ecobilan. Personal communication with Abt Associates (Gary Davis). April,
1997.
AFNOR. Marque NF-Environnement "Aspirateures Traineaux " Reglement Technique. AFNOR
207, March, 1996.
Product Categories (number of awarded products in parentheses)
Final Categories
Paints and varnishes (160)
Garbage bags (100)
Carpet glues
Vacuum cleaners
Soap-saving washing machine balls
Garbage compressors
Categories Under Review
Furniture
Scouring solvents/powders
Containers
Photography developing equipment
Categories Under Consideration
Pharmaceuticals
Agro-foods
Services
Automotive sectors
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-45
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GERMANY'S BLUE ANGEL
Introduction
Germany introduced the Blue Angel program in 1977, making it the first country to implement a
national ecolabeling program. The Blue Angel was launched by the Federal Minister of the
Interior and the Ministers for Environmental Protection of the Federal States. The German
government views its ecolabeling program as a "soft instrument" of environmental policy, since
the program cannot establish binding requirements or bans, and because participation in the
program is completely voluntary. The Blue Angel is a seal-of-approval program, and relies on
information, motivation, and a commitment to the environment from both manufacturers and
consumers.
The primary goals of the Blue Angel program are 1) guiding the consumer in purchasing quality
products with fewer adverse environmental impacts, 2) encouraging manufacturers to "develop and
supply environmentally sound products," and 3) using the ecolabel as a "market-oriented
instrument of environmental policy" (Umweltbundesamt, 1990). As the oldest ecolabeling
program, the Blue Angel program has served as a model for many other ecolabeling programs in
existence around the world today.
The Federal Minister for the Environment attributes the success of the Blue Angel to "the growth
of environmental awareness on the part of consumers and producers" (Umweltbundesamt, 1990).
In a 1988 survey of 7,500 German households, 79 percent were at least familiar with the ecolabel,
and 68 percent correctly linked the ecolabel with the concept of environmental protection. Similar
opinion polls have been performed on a regular basis, showing that the Blue Angel is perceived as
a reliable ecolabel.
The Blue Angel program has been and continues to be popular among manufacturers and
consumers. Compared to current levels, the program grew slowly at first, issuing only 500
ecolabels in 33 product categories as of 1984. By mid-1993, however, the ecolabel appeared on
3,503 different products in 75 categories. As of April 1997, 921 manufacturers (or importers) have
been awarded the Blue Angel for 4,135 products in 88 product categories. Approximately 17
percent of these awards were given to non-German companies.
Recent Developments
Since the program's inception, criteria development has become increasingly more complex. As
technological innovations and ideas about environmental protection and pollution prevention have
progressed, criteria have been modified in order to incorporate these changes. Whereas previously
only one or two factors may have been considered when developing criteria, multiple
environmental attributes (e.g., hazardous substances, emissions, pollution prevention and safety)
are now addressed. The overall process by which criteria are developed, however, has not
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-47
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changed significantly since 1993 (Breier, 1997).
Pilot projects and preliminary research are currently underway to develop product criteria for
numerous product groups (e.g., electrical appliances and products, products for do-it-yourself and
handicrafts, household chemicals and alternatives, heating technology, consumer and industrial
products). Interestingly, the pilot project for the furniture made from rattan and jute product
category is being conducted in cooperation with developing countries like Bangladesh and India.
Once developed, criteria for this product group will be unique in that they are for imported
products.
Germany does not foresee making major revisions to the Blue Angel program to make it more
innovative. Part of the success of the Blue Angel program is based on its history and tradition and
manufacturers' familiarity with the program. For these reasons, major revisions to the program are
not planned (Breier, 1997). Germany has recently joined the Global Ecolabelling Network (GEN),
however, as a way to improve harmonization and to obtain and exchange information about other
ecolabeling around the world.
Program Summary
The Blue Angel program is administered by three organizations: the Jury Umweltzeichen
(Environmental Label Jury), the German Institute for Quality Assurance and Labeling (RAL), and
the Federal Environmental Agency (Umweltbundesamt). The Environmental Label Jury is made
up of representatives from industry, the scientific and business communities, environmental
organizations, consumer organizations, trade unions, and churches. The RAL is a non-profit
standards organization that acts as the administrative body for the Blue Angel program.
The process of developing and awarding the Blue Angel ecolabel has three steps. First, product
categories are proposed (typically by manufacturers). From these proposals, the Federal
Environmental Agency and the Jury choose suitable product categories for the Blue Angel. Each
year an average of 150 product categories is proposed; typically, only six are selected as suitable
product categories for the ecolabel.
Once product categories are selected, the Federal Environmental Agency drafts criteria for each
product group. It takes between six months and one year to draft the basic product criteria.
Criteria are typically revised every three years. If there are major technology or innovative
breakthroughs in the product category, criteria may be re-assessed prior to the end of the three-year
period.
Draft criteria are forwarded to RAL, which organizes "expert hearings" to address technical
questions regarding the draft criteria. Representatives from industry, manufacturing, consumer and
environmental organizations, and, occasionally, scientists and representatives from testing
institutes, are invited to ask questions and make comments on the draft criteria. Representatives
from foreign companies are also welcome to make suggestions and comments at the hearing.
B-48 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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Comments from the expert hearing are taken into consideration when the Federal Environmental
Agency revises and the Label Jury finalizes the criteria. The results are published in press reports
of the Federal Minister for the Environment, Nature Conservation, and Nuclear Safety. RAL
published the final basic criteria.
In the last step, manufacturers submit applications to become certified to use the ecolabel on
particular products. Compliance with criteria is verified by statements from the manufacturer,
testing by independent facilities, and data and product information sheets. If everything is in
compliance with the basic product criteria, RAL forwards the application to the Federal
Environmental Agency and the federal state in which the manufacturer is located. A contract is
signed for the use of the ecolabel, for a duration of four years. If during these four years, the Jury
revises product criteria, then manufacturers must re-apply for the contract for those products.
Applicants must pay an initial application fee of DM 300 ($170.00 US), and an annual fee based
on estimated annual sales of the labeled product. In addition, users of Blue Angel must also
contribute to an advertising fund for the program. All fees are paid to RAL.
Program Methodology
Producers come forward to the Blue Angel program and make product proposals. However, unlike
many other ecolabeling programs, the Blue Angel does not conduct an impact analysis when
choosing product categories. Characteristics of the manufacturing process used to produce the
product are of less importance for Blue Angel certification. The program's reasoning for excluding
earlier stages of the product life cycle is that Germany's environmental protection laws and
regulations address the reduction and avoidance of environmental damage during the production
stages. Instead, when choosing product categories, the Blue Angel considers the following:
transportation and distribution costs, product uses, potential for the product to be reused,
maintenance costs, recyclability, final disposal, and the product's ingredients and materials
restrictions.
When developing draft award criteria, the Blue Angel considers previous literature and studies
relating to the product category as well as other programs' life-cycle assessments of the category.
Additionally, the program may also conduct its own independent tests and studies and often
obtains information from participating producers themselves about the product category. Draft
criteria are based on the potential environmental damage the products may have during usage and
disposal. A series of environmental and other factors is assessed. This series includes: the amount
of toxic and/or hazardous substance in the product; the emissions to air, water, and soil; noise
pollution; waste prevention, waste reduction and/or recycling opportunities at each stage; amount
of natural resources used; the safety of the product; and, finally, the minimum requirements for the
product's performance. The Blue Angel follows SET AC guidelines when developing its award
criteria.
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-49
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Other Information
Recently, the Blue Angel has served as a way to identify environmentally preferable products in
Germany. Many public procurement guidelines in local states and municipalities suggest buying
Blue Angel-certified products, or at least to consider the criteria developed for product categories
when making procurement decisions.
It has been suggested that ecolabeling programs can act as a barrier to trade for imported goods,
when product criteria relate to production stages. Because Germany's Blue Angel program does
not include product!onprocess-related criteria, but instead concentrates on the final environmental
impact of the product, this aspect of the program is viewed as avoiding a potential trade barrier.
Many of Germany's award criteria do have minimum recycled content requirements, however,
which are difficult to meet for many exporters to Germany. In this respect, many foreign countries
(e.g., Brazil, who is faced with these minimum requirements for their paper packaging) see these
requirements as trade barriers. Any manufacturer, domestic or foreign, may apply for the Blue
Angel ecolabel as long as they meet the specified product criteria.
References
Breier, Nicola, Federal Ministry for the Environment, Nature Conservation and Nuclear Safety
(Bundesministerium fur Umwelt), personal communication with Abt Associates, 1997.
Federal Environment Agency (Umweltbundesamt), April 1997, Information Sheet on the
"Environmental Label": Current Facts and Figures.
German Institute of Quality Assurance and Labeling (RAL), (Deutsches Institut fur
Giitesicherung), and the Federal Environment Agency (Umweltbundesamt), November 1996, The
Environmental Label Introduces Itself.
German Institute of Quality Assurance and Labeling (RAL), (Deutsches Institut fur
Giitesicherung), and the Federal Environment Agency (Umweltbundesamt), June 1997,
Umweltzeichen, Environmental Label, German "Blue Angel": Product Requirements.
Federal Environment Agency (Umweltbundesamt), 1994, Das Stellt Umweltzeichen Sich Vor.
Federal Environment Agency (Umweltbundesamt), 1990, Twenty Arguments Against the
Environment Label... [20 Argumente gegen das Umweltzeichen...und was man davon zu halten
hat].
Organization for Economic Co-operation and Development, Case Study on Eco-Labelling
Schemes. Paris. 30 December 1997.
B-50 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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Product Categories (number of awarded products in parentheses)
Final Categories
Retreaded tires (4)
Returnable bottles (90)
Low waste hair sprays, deodorants, and shaving foams
Sanitary paper made from recycled paper (182)
Low-emission oil burners (84)
Low-pollutant paints (1,345)
Powder paints
Salt-free blunting spreading material (46)
Recycled paper (315)
Zinc-air batteries (16)
Potting containers and similar mould parts made from recycled material (6)
Sound-proofed glass collection bins for noise-sensitive areas (16)
Waste water-poor car-washing plants (17)
Environmentally sound pipe cleaners (14)
Reusable packing for food production (1)
Reusable packing for transportation (19)
Products made from recycled plastics (68)
Products made from waste rubber (14)
Water-saving flushing cisterns (46)
Electronically operated shower facilities (7)
Products free from insecticides for indoor pest control and prevention (24)
Wall paper and ingrain wall covering made from recycled paper (109)
Wall paper covering paper and plastic materials
Building materials made from recycled paper (5)
Halogen-free cooling and insulating liquids for electrical equipment (4)
Low-formaldehyde products from wooden materials (for indoor use) (105)
Low-emission gas burners (86)
Combination boilers and circulating water boilers for gaseous fuels (34)
Combined burner/boiler units with gas blast burner (14)
Low-noise mopeds (2)
Water-saving flow restrictors (31)
Water-saving flushing valves (4)
Soil meliorators and soil adjuvants made from compost (43)
Combined oil burner/boiler units (62)
Solar-energy products and mechanical watches (34)
Rapidly biodegradable chain lubricants for power saws (94)
Building materials predominantly made of waste glass (3)
Lithium batteries free of mercury and cadmium
Environment ticket in public transport (17)
Highly heat-insulating multi-layer window glass (15)
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-51
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Low-noise construction machines (191)
Low-noise compost choppers (32)
Reusable ribbon cassettes and refillable toner cartridges (38)
Photoconductor drums for laser printers (1)
Recycled cardboard (368)
Thermal techniques (hot air) for pest control of ligniperdous insects (7)
Low-noise and low-soot municipal vehicles with diesel drive (18)
Low-noise and low-soot municipal vehicles with gas drive (1)
Building materials and gypsum made from recycled materials
Low-emission and energy-saving gas fired condensing boilers (59)
Low-emission and waste reducing copiers (135)
Rapidly biodegradable lubricants and forming oils (45)
Unbleached hot-filter paper (18)
Low-pollutant fire extinguishers
Lead-free seals (2)
Cadmium-free hard-solder (7)
Low-waste, resource-saving text marker (5)
Component-system detergents (1)
Independent burning gas heaters and flued-bed built-in appliances with atmospheric burners
(18)
Newspaper printing paper (consisting predominantly of recycled paper and bleached paper
without chlorine (30)
Solar collectors (17)
Low-pollutant nail varnishes
CFC-free and energy saving refrigerators and freezers
Low-emission chipboard (3)
Low-waste and low-water pollutant towels in dispensers (21)
Computers (73)
Rapidly biodegradable hydraulic fluids (27)
Low-emission gas burners (14)
Electronic ballasts for fluorescent lamps (5)
Tooth brush with exchangeable heads (6)
Low-noise and low-emission chain saws (5)
Sewage plant-compatible sanitary additives (8)
Printers
Recyclable video and audio cassettes (1)
Electrical appliances for hand drying (3)
Mercury-free medical temperature sensors
B-52 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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Categories Under Consideration
Household appliances (including combi-appliances)
Rechargeable consumer batteries
Halogen-free electric cables and wires
Cadmium-free infrared lamps
Television sets
Coffee machines
Mobile sound-reproduction sets with headphones (walkmen)
Commercial refrigerators and freezers
Appliances of office communications
Gas stove and electric cookers
Low-noise and low-emission motor-lawnmower
Electric-equipment
Low-solvents special coatings
Dispersion paints in returnable containers
Graffiti cleaners
Construction materials made of recycled material for use in building construction
Low-emission paint-spraying guns
Heat-insulation materials made of renewable resources
Biological pest control agents
Disinfectants
Technical devices as an alternative to sanitary additives
Biodegradable motor oil for two stroke engines
Electronically controlled circulating pumps
Heat cost distributer/heat quantity meter
Products made from jute
Products made from rattan
Tabular Plastic containers for non-beverage uses
Satchels
Flame retardants
Easy de-inkable and dyes for printing containing less harmful substances
Retrofitable and low-waste mug oil filters for cars
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-53
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GERMANY'S GREEN DOT PROGRAM
Introduction
In 1991, Germany established the Ordinance on the Avoidance of Packaging Waste (Packaging
Ordinance). According to the Packaging Ordinance, domestic and foreign manufacturers and
distributors are required to take back all transport packaging such as crates, drums, pallets, and
styrofoam containers (i.e., primary packaging) and recycle or reuse these materials. In 1992, these
regulations were expanded to include all secondary packaging. Accordingly, manufacturers,
distributors, and retailers are now required to take back and recycle secondary packaging (e.g.,
cardboard boxes, blister packs, and other product packaging such as that used to prevent theft, for
protection, and for promotional purposes) from consumers. Since 1993, however, the Ordinance
was further expanded to included all types of consumer packaging used to contain and transport
goods from the point of sale to consumption. The most recent regulations created an option that
exempts manufacturers from these regulations.
Specifically, the Packaging Ordinance states that manufacturers, retailers, and distributors (both
domestic and foreign) may be exempt from taking back packaging if they participate in an
established national waste management program. Such a program had been in existence in
Germany since 1990, under the Duales System Deutschland GmbH (Dual System of Germany).
The Duales System is a non-profit organization set up to collect, sort, and recycle post-consumer
packaging from both households and small businesses throughout the country. By participating in
the Duales System program, manufacturers may label their products with the Green Dot. A Green
Dot indicates to the consumer that the manufacturer of the product participates in the program, and
that instead of returning the packaging to the manufacturer or distributor, the packaging should be
collected, sorted, and recycled through the Duales System program.
The new packaging laws in Germany have been successful in reducing packaging and encouraging
the use of recycled and re-fillable packaging. Foreign companies have expressed concern,
however, that these laws are a possible trade barrier. The claim has also been made that Germany
is developing and implementing these packaging laws without consultation from or concern for the
European Community and its goal for a Single European Market.
Recent Developments
The program reports that there have been no major changes in the methodology by which the
Green Dot is granted since 1995.
Program Summary
Although the Green Dot operates as a response by industry and trade associations to avoid
individual take-back regulations, its overall goal is the prevention of excess, unnecessary waste. In
this regard the Green Dot fee structure acts as an incentive for manufacturers to reduce the amount
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-55
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of packaging they use for their products in the design of products and packaging. Manufacturers
wishing to obtain the Green Dot must pay a license fee to the Duales System. Fees are based on
the type and weight of the packaging materials. In general, the heavier and more difficult it is to
recycle the packaging, the higher the license fees. Fees vary according to the packaging materials,
with plastics having the highest fees and natural materials and glass having the lowest fees.
License fees range from about DM 3.00/kg to DM 0.15/kg ($1.70 US to $0.08 US).
The Duales System collects glass, paper, cardboard, and lightweight materials such as polystyrene,
plastic, beverage containers, composites made of a mixture of materials, aluminum, and tin-plate.
The Duales System has established two types of collection systems, which can be modified to
accommodate existing local and regional collection systems. The first, and most widespread, is the
curbside system where consumers collect Green Dot packages (except glass, paper, and cardboard)
in the yellow bags or bins provided to their households. The bags/bins are placed on the curbside
to be collected during the regular garbage pick-up. Glass, paper, and cardboard are collected
separately in special bins/containers set up in the neighborhood — glass is often separated
according to color. In the curbside system, the consumer does the basic initial sorting of the
packaging. The alternate system is the "bring" system where consumers bring all their waste
packaging to central collection stations. Under the "bring" system all packaging is sorted by
Duales System employees into different bins, which are set up for the different packaging
materials.
Once collected, the materials are sorted by waste management companies under contract to the
Duales System. Once the materials have been sorted, they are ready to be shipped to recycling
facilities. According to the Duales System Deutschland GmbH, the recycling goals set by the
Packaging Ordinance have been met since the Green Dot program began. Since 1992, one year
after the Packaging Ordinance went into effect, the weight of packaging consumed (i.e., not for
recycling) in Germany has steadily declined. Because of the take-back requirements set by the
Ordinance, and the license fee structure, manufacturers have been motivated to reduce the weight
of their packaging in order to reduce their eventual recycling costs.
Program Methodology
The Duales System collects glass, paper, cardboard, and lightweight materials such as polystyrene,
plastic, beverage containers, composites made of a mixture of materials, aluminum, and tin-plate.
These product categories were chosen based on evaluations of their environmental impacts, as well
as their potential for reuse and recyclability. The Duales System establishes criteria for these
product categories, which manufacturers must adhere to for their packaging materials in order to be
part of the program. That is, packaging made with paper products must meet certain standards set
by the program in order for that packaging to be awarded the Green Dot, and therefore be accepted
for recycling through the program. Product criteria are based on previous studies conducted for
B-56 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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these product categories, as well as information from other programs' life-cycle assessments for the
categories, independent testing, and information from producers themselves. Criteria are peer-
reviewed, and peer-reviewed critiques and Duales System's responses to them are available to the
public.
Other Information
Unless companies participate in the Green Dot program, they are required to take back their
packaging according to the Packaging Ordinance. This take-back burden is far greater for
companies that ship their products long distances to Germany — they conceivably pay the
transportation costs of shipping the packaging back to the country of origin. Many exporting
countries, particularly developing countries, may not have the infrastructure or the technical ability
to meet all the packaging standards set by Germany. One alternative that foreign companies may
opt for is hiring a German company to overcome the cost burden or to meet the standards. For
example, the German company would be responsible for packaging the imported good(s) in
Germany so that they comply with local requirements. In addition, the company would take back
the returned packaging.
Although foreign products are not required to carry the Green Dot, many manufacturers exporting
to Germany claim that the domestic demand for the Green Dot label places imported goods at a
market disadvantage. (European Union based importers can also apply for the Green Dot.)
Additionally, distributors and retailers may shy away from foreign products without the Green Dot
because otherwise the responsibility of recycling the packaging falls on the distributors/retailers.
References
Federal Government of Germany, 1991, Ordinance on the Avoidance of Packaging Waste
(Packaging Ordinance - Verpackungsverordnung - VerpackVO) of 12 June, 1991.
Duales System Deutschland GmbH, March 1996, Recycling Data - Techniques and Trends.
Duales System Deutschland GmbH, May 1996, Changes and Developments - Plastics Recycling
Today.
Duales System Deutschland GmbH, December 1996, Info-Grafik: Green Dot License Fees.
Duales System Deutschland GmbH, April, 1997, Press Information: Green Dot Presents 1996
Materials Mass Flow Verification.
Duales System Deutschland GmbH, January, 1996, Life-Cycle Analysis on Recycling and Recovery
of Post-Consumer Plastics.
Bernhardt, K., 1992, Germany's New Packaging Laws: The "Green Dot" Arrives, Business
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-57
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America, vol. 113, no. 4, pp. 36-37.
Cotter, M. J., Henley, J. A. Jr., 1995, Germany's "New" International Strategic Weapon:
Environmentalism, Multinational Business Review, vol. 3, no. 1, pp. 93-97.
B-58 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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INDIA'S ECOMARK
Introduction
As part of an effort to improve environmental quality and to increase environmental awareness
among industries and consumers, the Indian Parliament initiated a voluntary ecolabeling program
known as the Ecomark in February 1991. The Ecomark is a government operated seal-of-approval
program for environmentally-preferable consumer products. The Ministry of Environment of
Forests (MoEF), with the technical advice of the Central Pollution Control Board (CPCB),
manages the program. Unlike many other international ecolabeling programs that are independent,
India's Ecomark is tied with the BIS's product quality standards. In order to be Ecomark certified,
products must meet these product quality standards, as well as product-specific environmental
criteria set by the Ecomark program. In meeting Ecomark requirements, manufacturers will also
have both the BIS's quality standards label on their products.
The objectives of the Ecomark program are fivefold: 1) to provide manufacturers and importers an
incentive to reduce the adverse environmental impacts of their products, 2) to reward genuine
initiatives by companies to reduce the adverse environmental impacts of their products, 3) to assist
consumers in becoming environmentally responsible in their daily lives by providing them with
information on environmental impacts that they can incorporate in their purchasing decisions, 4) to
encourage citizens to purchase products that have fewer environmental impacts, and 5) to
ultimately improve the quality of the environment and encourage sustainable management of
resources.
The Ecomark label is seen as a "movement of consumers" and is therefore given exclusively to
consumer products. Interestingly, even though (as of January 1997) sixteen product categories had
been selected for the Ecomark, only one product, in the detergent product category, has been
awarded the Ecomark. So far, however, there are no products available on the market with the
ecolabel; the manufacturer of the detergent product that had been awarded the Ecomark did not
market the product with the ecolabel. According to Dr. Sudhir K. Ghosh, Member Secretary of the
Ecomark Technical Committee, "Indian industries are not coming forward to get eco-certification
of their products, though they are involved in the process of criteria development." Some attribute
this to the costs involved in applying for the Ecomark and the numerous regulatory requirements
manufacturers must meet before being awarded the ecolabel. Other reasons may include
industries' concerns about the Ecomark program, which are outlined below.
Recent Developments
The program reports that there have been no significant changes in the methodology for
determining award criteria since the beginning of the program. Due to the lack of response from
manufactures (and consumers) regarding ecolabeling, however, the Ministry of Environments and
Forests has recently (August 1997) launched a market survey for ecolabeled products.
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Program Summary
There are three committees involved with product category selection, criteria development, and
award of the Ecomark. First, an inter-ministerial Steering Committee in the Ministry of
Environment & Forests determines the product categories to which an Ecomark may be granted.
The Committee is also in charge of promoting of the labeling scheme to manufacturers and
consumers. Once the Steering Committee has made proposals for product categories, a Technical
Committee in the Central Pollution Control Board determines the specific product to be included
under the Ecomark scheme.
The Technical Committee is the central committee for the Ecomark scheme and constitutes sub-
committees for the development of Ecomark criteria for each proposed product category. The
Technical Committee provides technical assistance and recommendations to the Steering
Committee for finalizing product categories, and is also in charge of developing product specific
criteria, based on life-cycle assessments, wherever possible. Once criteria are finalized, the Bureau
of Indian Standards and/or the Directorate of Marketing translates the product criteria into Indian
Standards, assesses and certifies the products, and coordinates (via testing and contractual
arrangements) with manufacturers wishing to use the Ecomark label on their products.
Manufacturers wishing to obtain the license to use the Ecomark label on their products submit
applications to the Bureau of Indian Standards and deposit a non-refundable fee approximately Rs.
500 ($14.00 US) for each product. The applicant is responsible for any testing and inspection
costs, if required. In addition there is a usage fee, based on the annual production of the product,
which is determined by the BIS. If the manufacturer is found to be in compliance with the award
criteria, the BIS draws up a contract for use of the Ecomark. The label is initially granted for one
year, but there is the option to renew the license for the Ecomark label for a fee of Rs. 300 ($8.30
US). If a manufacturer illegally uses the Ecomark, without BIS certification, they are subject to
punishment as per provision of the Bureau of Indian Standards Act of 1986.
Program Methodology
Once specific products are selected for the Ecomark, product criteria are developed. In general,
previous literature and other programs' life-cycle assessments are used in conducting a simplified
life-cycle assessment that examines products in terms of their main environmental impacts. These
include: the product's potential for generating less pollution than other comparable products;
whether the product is recycled, recyclable, or made from recycled materials or whether it is
biodegradable; and whether it makes significant contributions to saving non-renewable resources.
Products are assessed specifically on their use, potential for reuse and recyclability, environmental
impact during final disposal, and their ingredients or their materials restrictions. India, however,
does not follow SETAC guidelines in its LCA. The Ecomark Technical Committee may also plan
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to incorporate the International Standards Organization (ISO) 14020 guidelines and general
principles once these are finalized. Draft criteria are peer-reviewed and peer-review critiques are
available to the public.
Furthermore, certain general requirements have to be met in order to grant the Ecomark label.
First, products must meet the Bureau of Indian Standard's product quality, safety, and performance
standards. Second, manufacturers of the product must provide evidence that they are in
compliance with India's Water, Air, and Environmental Protection Acts and, if applicable, with the
Prevention of Food Adulteration Act of 1954 and the Drugs and Cosmetics Act of 1940. Third, the
product must display a list of all the critical ingredients in descending order of quantity present.
Fourth, the manufacturer may opt to display (on the packaging) the criteria upon which the
Ecomark label is based. Fifth, instructions on the product's proper use, performance, and disposal
may be shown on the product's packaging as well.
Other Information
The overall response to the Ecomark program within India itself has been quite limited and
manufacturers are hesitant to apply for the Ecomark label. Several factors are seen as possible
causes for this hesitation. First, the Ecomark scheme is a self-financing program, requiring
manufacturers to pay for the application, testing, licensing fee, and renewal costs involved in
certification. Some estimates indicate that these costs can amount to a 10 percent increase in a
manufacturer's production costs — which are not guaranteed to be returned in increased profits.
Second, products have to comply to BIS's quality standards before being able to apply for the
Ecomark. The BIS standards add another layer of regulation and approvals for manufacturers,
which are perceived as a burden with few immediate benefits.
Additionally, industry has complained that India's Ecomark has not done enough to involve it in
product criteria development. Industry feels the Indian Government has "rushed through" with the
Ecomark. Industry feels that the labeling program will not help environmental improvement if
criteria concentrate on single issues, or if they are based on other programs that do not take the
local situation into account. Industry also says that the labeling program inhibits innovation that
comes with consumer goods production and can, therefore, be a hindrance to environmental
improvements. Finally, industry feels that because of the lack of consumer awareness of
environmentally preferable products, the Ecomark program may send consumers the "wrong"
message by indicating to consumers that non-Ecomark labeled products are not environmentally
safe.
Indian exporters feel that many of the product categories chosen for Ecomark, with the exception
of textiles and certain food items, do not reflect India's major export products for which an
Ecomark might be of value. Several manufacturers have, in fact, adopted the ecolabeling standards
of their importing customers' countries in order to operate in those markets. The textile and leather
products sectors (two of India's largest exports) have made efforts to conform to ecolabeling
standards in EU countries such as Denmark and Germany. Such conformance has been possible
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through bilateral support from these foreign governments. In response, the Indian Government is
now in the process of developing award criteria for the leather and leather products categories.
With regard to trade, the Indian Ecomark program does recognize the increasing popularity of
ecolabeling schemes around the world, and the Ecomark Steering Committee recognizes that,
"whilst there is a need for greater transparency, voluntary ecolabeling schemes should not be
brought under the scope of the technical barriers to trade agreements." As a result, the Indian
Government stresses that the Ecomark program is a "purely voluntary scheme open to all
manufacturers, both domestic and foreign." According to the Ecomark Technical Committee, in
order to make the scheme more globally transparent, much of the information on the Ecomark can
be found on the World Wide Web (http://www.nic.in/envfor/cpcb/cpcb.html). The site was created
by the Central Pollution Control Board in collaboration with the National Information Centre in
India.
The Indian government has already prohibited the handling of 70 "azo" dyes, in response to new
regulations by Germany and the EU in place as of early 1996. About 70 percent of dyes
manufactured and used in textiles in India contain 'azo' dyes, and about 25 percent (190) of these
have been banned in Germany and the EU. Germany and the EU are two of India's largest markets
for garments and textiles (10 percent of India's textiles and textile goods exports go to Germany
and 50 percent are sold to the EU as a whole). These new regulations are likely to affect India's
exports in these sectors.
To help exporters understand these new regulations, the Indian Government has set up committees
in charge of information dissemination to trade and industry, legal measures, research and
development, and identification of substitutes. The committees have asked trade and research
associations, export promotion councils, state governments, and other textiles-related
organizations, to produce outreach materials (e.g., pamphlets, leaflets, publications, videos,
advertisements in daily publications, workshops, and seminars), in both English and local
languages, to provide manufacturers with information regarding the regulations.
India's Ministry of Environment and Forests has issued restrictions on manufacturing of the 190
banned dyes, as well as placing these dyes on a list of restricted imports under India's Export-
Import policy. In addition, a provision in the Textiles (Development and Regulations) Order of
1993 will be included specifying which toxic or harmful dyes and chemicals should not be used in
the manufacturing of textiles. In addition, a list of the banned dyes, a list of safe substitutes,
product related eco-standards, and a list of guidelines for manufacturing environmentally
preferable textiles have been distributed.
The Department of Chemical Technology at the University of Bombay, the Technology Institute of
Textiles and Sciences, and other research institutions are requested to identify toxic chemicals and
dyes to be phased out from textile manufacturing. Additionally, numerous laboratories have been
set up throughout textile centers in the country to perform tests on the banned dyes and to find
possible alternatives.
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Finally, in an effort to achieve harmonization and mutual recognition with other ecolabeling
programs, the Indian Ministry of Commerce presented a paper at the "Seminar on Trade Effects of
Eco-labelling" in Bangkok, Thailand, in early 1997. The Ministry suggested forming an
organization, called the Asian Environmental Network (AEN), similar to the Global Ecolabelling
Network (GEN) but specifically for the Asia Pacific region. They proposed that AEN could be set
up for better exchange and dissemination of information about ecolabeling, and to work toward
greater harmonization among ecolabeling programs in Asia. The Ministry of Commerce suggested
that AEN could set up generic ecolabeling standards for the Asia Pacific Region, as well as provide
technical assistance to countries trying to further develop or who are trying to set-up ecolabeling
programs. Also, information on mutual recognition, equivalency, new technologies, new products,
and regional protocols could be disseminated via a newsletter or on the Internet. AEN is still in the
development stages, however, and has not yet been formally established.
References
Dr. Sudhir Ghosh, Additional Director and Member Secretary, Ecomark Technical Committee.
Personal communication with Abt Associates. November, 1997.
Bhat, A. N., Ecomark Issues and Role of Indian Industry, National Seminar on Green Purchasing
and Ecolabeling.
Ministry of Commerce, January/February, 1997, Seminar on Trade Effects of Eco-Labelling -
India: National Experience on Eco-Labelling, Bangkok, Thailand.
Central Pollution Control Board, 1997, Ecomark: A Scheme on Labelling of Environmentally
Friendly Products.
Central Pollution Control Board, Ecomark Scheme of India, Ecomark Homepage,
http://www.nic.in/envfor/cpcb/cpcb.html.
Singh, Y.P., and Phalgumani, G.R., 1995, MeetingEco-requirements for Export: Example of
Indian Textiles, International Trade Forum, no.3, pp. 12-15.
Ministry of Environment and Forests, Department of Environment, Forests and Wildlife, 1991,
Resolution, published in The Gazette of India, no. 71, part II, section 3, sub-section i, New Delhi,
Thursday, February 21.
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-63
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Product Categories
Final Categories
Soaps and detergents
Paper
Food items
Lubricating oils
Packaging materials/packages
Architectural paints and powder coatings
Batteries
Electrical/electronic goods
Food Additives
Wood substitutes
Cosmetics
Aerosols Propellants
Plastic Products
Textiles
Categories Under Development
Leather and Leather products
Fire extinguishers
Household pesticides
B-64 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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JAPAN'S ECOMARK
Introduction
The EcoMark program, the second oldest ecolabeling program after Blue Angel, was started in
February 1989 as a positive seal-of-approval program to "disseminate information on the
environmental aspects of products and to encourage consumers to choose environmentally sound
products." The program is implemented by the Japan Environment Association (JEA), a non-
governmental organization, under the guidance of the Environment Agency. As of June 1997, the
program has issued 2,031 awards in 69 product categories.
Two studies have been conducted to evaluate the influence of the EcoMark. Both indicate that the
EcoMark is becoming well known. The first was a survey of local governments, distributors and
companies with EcoMark-approved products, conducted by the JEA in the Spring of 1991. More
than half of the companies who had acquired the logo did so to improve their corporate image,
citing also "requests from customers and increased sales." Almost all local governments were
aware of the program, compared to only 40 percent of distributors. The other study, a 1990 public
opinion poll conducted by the Prime Minister's Office, found that 22.3 percent of the respondents
said that they were familiar with the EcoMark. By 1993, this rate had jumped to 53 percent.
Recent Developments
The EcoMark program has undergone several changes in the past few years. First, the number of
awards has actually decreased. Two product categories have been eliminated: spray containers not
containing CFCs, abolished December 1993; and cans with stay-on tabs, abolished June 1995. In
addition, consolidation of the pulp and paper industries has resulted in a decrease in the number of
paper brands receiving awards (decreasing number of paper companies leads to decreases in the
number of paper brands). The program has recently added two product categories, printing ink and
recycled suitcases, to its list. Because the program seeks to label a small percentage of products
within a product category, categories can either become more stringent or be abolished altogether if
the labeled product market share is too large. The EcoMark program is in the process of revising
16 product category criteria to become more stringent based on new manufacturing procedures. It
is expected that more currently labeled products reapplying for the label will fail, limiting the
market share of awarded labels to only those products meeting the very highest environmental
standards.
The program has also revised its methodology for selecting product categories and awarding labels.
Originally, the EcoMark program based selection on the finished products' attributes, and did not
incorporate the manufacturing processes of individual products within a category. In this way the
logo was used more to call attention to products that were part of "an ecological lifestyle," than to
weigh the relative impacts of consumer products throughout the life cycle. The process was also
generally not open for comment from the public. These procedures were revised in March 1996 to
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-65
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conform to the draft ISO 14024 standards. The program now employs the use of life-cycle
analysis, consults with related parties, and provides for public review of draft criteria.
Program Summary
The EcoMark Secretariat is located within the Japan Environment Association, as are the two
committees (the Promotion Committee and the Expert Committee) responsible for administering
the program. The Secretariat sets up a working group of experts and concerned persons for each
product category under consideration. This group then establishes draft criteria using life-cycle
analysis, which are publicized in EcoMark News for 60 days for public comment. The draft
criteria are submitted, with the incorporated suggestions, to the Promotion Committee (composed
of specialists in environmental conservation, administrative agencies, consumer groups, and
relevant enterprises), which then approves or rejects the criteria.
Once award criteria have been set, confidential product applications are accepted. Manufacturers
must supply relevant information to the Expert Committee (composed of experts in environmental
impact assessment), but the Committee may request further testing by a third party. If a product is
awarded a label, a two-year contract is signed with the JEA. While JEA does not directly monitor
for misuse, it relies on other manufacturers, administrative organizations, and consumer
organizations to inform it of possible instances of misuse.
Unlike most environmental certification programs, the fee charged for use of the award is based on
the retail price of the product, not the number of units sold or the market share. The annual license
fee is between 40,000 (348 USD) and 100,000 yen (870 USD). Additionally, the Japanese
program is unusual in that there is no application or advertising fee.
Program Methodology
As mentioned above, the Japanese EcoMark program recently changed its methodology to
incorporate life-cycle assessments, specifically a life-cycle matrix, which considers the
environmental impacts within each stage of the product life cycle. This change was made as a
response to draft labeling standards being developed by the International Organization for
Standardization (ISO). In assessing products, the EcoMark utilizes literature and other programs'
life-cycle assessments, as well as independent testing and studies and information from
participating producers. Additionally, information about product criteria from other programs may
also be adopted by the Japanese EcoMark program, where applicable. Japan does not follow
SETAC guidelines in their life-cycle-analysis.
Once product selection by the EcoMark office and the Expert Committee is completed, the
EcoMark office sets up ad hoc working groups for each product group to develop labeling criteria.
Product selection is based on proposals from manufacturers as well as the use of a political process
in consideration with the environmental impacts of the product. Product criteria, based on the life-
cycle matrix approach and at each stage of the product's life cycle, considers the following factors:
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extraction and processing of raw materials; manufacturing, transportation, and distribution of the
product; the product uses; potential for reuse; potential for recycling; and emission of wastes, toxic
substances, and harmful pollutants.
Other Information
The program is open to participation by small and medium sized businesses; more than 75 percent
of the manufacturers awarded are small or medium in size.
JEA is a member of GEN, which it finds very useful, not only for information exchange but also
for assisting ecolabeling programs worldwide with program information and for the removal of
unnecessary trade barriers. When criteria are being developed and revised, JEA collects data on all
criteria in similar product categories via the GEN database and uses these to guide its development.
In accordance with the draft ISO 14024 standards, existing criteria are revised within three years
(16 of the 69 current award criteria are in the revision stage).
EcoMark has a strong relationship with procurement programs. For example, the central
government is in the process of establishing guidelines for green procurement and references the
EcoMark as one possible source of information. Some of the more progressive local governments
have already established green procurement guidelines and also reference the EcoMark.
According to JEA, the program has not been involved in any critical trade conflicts to date. In fact,
JEA has shown initiative in addressing trade issues before a conflict can arise. For example, in
1996, JEA made a concerted effort to get input from the US on the trade implications of
developing product categories for personal computers and copy machines. By including the US in
its process, it hoped to avoid any trade conflicts.
Similar to the ecolabeling program, the Green Purchasing Network (GPN) was created in February
1996. The GPN is sponsored by the Environment Agency of Japan, and consists of organizations
committed to reducing stress on the environment by promoting green purchasing. Thus far, 425
companies, 107 local governments and government agencies, and 97 non-profit organizations are
members. The GPN establishes purchasing guidelines in product categories, publishes annual
guidebooks concerning the environmental impact of products, publishes a quarterly newsletter, and
conducts meetings. Although the GPN program and the EcoMark are independent of each other,
the GPN has a significant influence on the EcoMark.
References
US Environmental Protection Agency. Correspondence with Japan Environment Association.
November 1996.
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-67
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Hashizume, Shigeyuki, The EcoMark System, Converted! Japan, 1994.
Hashizume, Shigeyuki, Japan Environment Association. Personal communication with Abt
Associates. Summer 1997.
Hashizume, Shigeyuki, Japan Environment Association. Presentation of the Japanese EcoMark.
Global Environmental Labelling Network Annual Meeting. September, 1997.
Japan Environment Association. Green Purchasing Network background documents. August 1997.
Japan Environment Association. The Eco Mark Program.
Japan Environment Association. The Eco Mark System. September 1991.
Japan Environment Association. Certification Criteria for Eco Mark Products.
Japan Environment Office. EcoMark Office. Offset Printing Ink. Product Category No. 102 for
the EcoMark Program. July 1997.
Product Categories (number of awarded products in parentheses)
Final Categories
Spray products not containing CFC's (abolished)
Triangle strainers for kitchen sinks (16)
Strainers for kitchen sinks (28)
Filter bags for kitchen disposal (155)
Absorbents for used cooking oil (34)
Composting containers (30)
Magazines and books on environmental problems (20)
Toilet paper using 100 percent recycled paper (85)
Returnable containers (11)
Containers for collecting used bottles (0)
Soap made from used cooking oil (47)
Products made from used lumber (25)
Products made from used plastic (211)
Cans with stay on tabs (abolished)
Recycled paper for office use (102)
Recycled paper for printing (237)
Recycled paper for stationary (137)
Recycled paper for packaging (184)
Hot water supply systems using solar energy (3)
Cellulose sponges (39)
Cloth diapers for infants (44)
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Products made from used tires (33)
Thermal insulation for buildings (3)
Tissue paper using recycled paper (11)
Biodegradable engine oil for two-cycle engines (7)
Products using solar battery modules (2)
Straw matting (9)
Flow-reducing valves and water-saving faucets (13)
Soundproof and vibration proof mats (3)
Blast furnace and fine powder slag and blast furnace cement (7)
Refillable containers (60)
Unbleached coffee filters (10)
Paint containing no aromatic hydrocarbon compounds (87)
Filters for cooking oil (6)
Boards made from waste wood (51)
Waste can collectors (7)
Drainage fixtures for rainwater dissipation (7)
Storage tanks for rainwater (0)
Packing materials made from recycled pulp (35)
Wallpaper, fusuma paper and shoji paper made from recycled pulp (36)
Filter bags of recycled paper for vacuum cleaners (7)
Tiles and blocks made from waste material (12)
Household gloves of natural rubber (22)
Unbleached clothes, bed linen, and towels (32)
CFC recovery systems for air conditioners (2)
Biodegradable hydraulic oil (10)
Biodegradable lubricant oil (18)
Cloth shopping bags (20)
Multi-pass thermal transfer ribbons (1)
Wooden products made of culled logs and small-diameter logs (13)
Textiles made of waste fibers (15)
Briquettes made of waste (2)
Low-waste printers for business machines (5)
Replaceable ink cartridges and ribbon cassettes (3)
Resource conserving containers for edible oils (12)
Recycled paving materials (4)
Fancy sound-absorption panels of iron-slag mineral wool (5)
Laminated fiberboard of recycled pulp (7)
Combustion apparatus using waste cooking oil (0)
Buffer materials made of culled logs and used timber (0)
Vegetation supporting concrete paving blocks (1)
Energy saving gas leak detectors (2)
Load-stabilizing devices for energy conservation (4)
Products made from recycled cullet (14)
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Building materials of fly ash (1)
Clothing made of used PET resin (10)
Inert-gas smothering systems and apparatuses using no ozone-layer depleting gases (3)
Easily repairable office chairs (7)
Low-benzene gasoline for vehicles (2)
Agricultural mulch sheeting of recycled pulp (1)
Solar-powered clock or watch (1)
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SOUTH KOREA'S ECO-MARK
Introduction
According to the South Korean Ministry of the Environment (MOE or Ministry), rapid
industrialization and urbanization during the last three decades and South Korea's rapid economy
growth may have contributed in deteriorating the country's environmental conditions. As a result,
the Korean government established "Harmony between Environment and Development" as a main
policy goal of the country, with emphasis on pollution prevention and resource management. To
realize this policy, the Korean Ministry of the Environment launched its ecolabeling certification
program, known as "Eco-Mark," on June 1, 1992. Eco-Mark is a voluntary program that awards a
seal of approval to environmentally preferable products. It is primarily intended to encourage
companies to promote the design, production, marketing, and use of products that have reduced
environmental impact, as well as to provide consumers with information to make environmentally
sound purchasing decisions.
Between 1993 and 1994, the number of Eco-Mark product categories increased from 12 to 36, and
within those categories the number of products awarded the Eco-Mark label increased from 96 to
219.
Recent Developments
Korea recently (as of June 1997) became one of the newest members of the Global Ecolabelling
Network (GEN).
Program Summary
The Korean Eco-Mark program is administered by the Korean Ministry of Environment. New
product category suggestions are directed to the Ministry's Technology Development Division.
This Division makes the final decision as to which product categories are suitable for the Eco-
Mark. The Ministry then drafts the award criteria with technical assistance from the Korean
Academy of Industrial Technology (KAITECH). The draft criteria are released to the public for
comments during public hearings. Based on the comments received, criteria are revised and
finalized.
Once criteria are finalized and released to the public, manufacturers wishing to obtain the Eco-
Mark can apply to be eco-certified. A "practical committee" within the Korean Environmental
Labelling Association (KELA), (who handles manufacturers' applications) is in charge of awarding
the label to companies wishing to obtain eco-certification for their products that meet the
prescribed award criteria.
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Once the product fulfills the criteria, it is eligible to receive the Eco-Mark. In addition to the initial
application fee of 30,000 won ($33 US), the user of the Eco-Mark must pay an annual fee ranging
from 300,000 won to 1,000,000 won ($330 US - $1,090 US), based on the product's annual sales
(more expensive goods command a higher fee). This fee, collected by the KELA, is used to
maintain the Eco-Mark program as well as to increase public awareness of environmental issues.
Program Methodology
The Eco-Mark program has found that, in practice, the significant data requirements of the life-
cycle assessment approach typical for determining award criteria are difficult to meet. The Korean
Eco-Mark's approach to product certification is therefore based on defining the single most
important environmental impact for each product category.
References
United Nations Council on Trade and Development (UNCTAD), International Trade Division,
Trade and Environment Section, 1993. Eco-labelling and International Trade: Preliminary
Information from Seven Systems (Draft), Geneva, Switzerland, May 19.
Korean Environmental Labelling Association (KELA), The Eco-Labelling Program in Korea — Its
administrative structures and procedures, Eco-Mark Homepage,
http ://www. gcc. go. kr/ehome/ecomark. html.
Product Categories
Final Categories
Products made from recycled paper
Toilet paper
Products made from recycled plastic
Cloth diapers for babies
Non-asbestos brake lining and clutch facing
Filters for kitchen sinks
Non-bleached and non-dyed towels
Valves for adjusting flow and water saving-type faucets (including water saving tops)
Packaging materials using wastes
Soap made from waste edible oils
Bricks made from waste lime
Construction materials made from waste glass
Products made from used tires
Bulb-type fluorescent lamps
Cloth shopping bags
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Construction materials made from waste stone powder
Biodegradable engine oil for two-cycle engines
Biodegradable hydraulic oil
Bricks made with inorganic sludge
Palette made with waste wood
Water-economizing toilet stool
Low sulfur petroleum
Building materials using remnants from burning
Blast furnace cement
Returnable can collectors
Refillable containers
Water-economizing fittings for toilets stools
Biodegradable sponges
Machines for recycling used antifreeze
Gravel made of waste materials
Oil filters
Electricity saving low mercury fluorescent bulbs
Plastic containers with same material log attached
Solar water heaters
Low pollution ferro-concrete pipe
Energy efficient refrigerator with no CFCs
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MALAYSIA'S PRODUCT CERTIFICATION PROGRAM
Introduction
The Product Certification Program, Malaysia's national environmental labeling program, was
launched in 1996 by the Standards and Industrial Research Institute of Malaysia (SIRIM). It is a
single-attribute, seal-of-approval product certification program. As of March 1997, SIRIM's
certification activities were delegated to a fully-owned subsidiary, SIRIM Quality Assurance
Services (SIRIM QAS). This delegation was undertaken to avoid any conflicts of interest with
SIRIM's other activities, namely testing, research, standards development, and measurement
services. SIRIM consults regularly with the Ministry of Environment, which is in charge of
Malaysia's overall environmental policy. Although SIRIM is not directly under the auspices of the
Ministry of Environment, SIRIM strives to coordinate its programs with Malaysia's official
environmental policy in this way.
SIRIM plans to develop (by 1998) certification criteria for lighting and appliance energy-
efficiency, as well as detergent biodegradability. To date, however, its only fully-developed
product criteria, published in July of 1996, are for CFC-free refrigerators. The impetus for
developing these criteria was the Montreal Protocol, which called for the phasing out of CFC usage
worldwide. The Malaysian government responded by imposing a deadline of 1999 for the
complete phaseout of CFC use. However, Malaysian refrigerator manufacturers that had
developed CFC-free refrigerators before the deadline found themselves suffering from market
share declines attributable to the higher prices they had to charge for the more expensive CFC-free
technology. These manufacturers sought the certification to help consumers differentiate among
manufacturers' environmental performance and to encourage consumers to support the CFC-free
technology despite the higher prices. One large domestic manufacturer has had its entire product
line certified. SIRIM is currently working to certify a second manufacturer's refrigerators.
Because of the 1999 phaseout, however, it is expected that the CFC-free certification will become
obsolete and will eventually be phased out as well.
Program Summary
Selection of product categories begins when a request for a product category is submitted by the
public. Though anyone can request product categories, manufacturers wishing to promote their
own products are usually the ones submitting requests. Certification requests may be prompted by
demand in either the domestic or export market. Most Malaysian refrigerators, for example, are
bought and sold domestically. However, the requests for detergent biodegradability labeling and
lighting and appliance energy-efficiency labeling were driven by Malaysia's large export market.
SIRIM then selects product categories based on market presence and potential benefit, determined
through discussions with both consumers and manufacturers.
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Product criteria are established by an internal committee of SIRIM professionals who consult
foreign certification programs for information on similar products. These criteria are then
presented to a government-appointed advisory board composed of various stakeholders including
the government, professional bodies, and trade associations. Through a consensus-based decision-
making process, the criteria are revised and released, officially launching the certification program.
After their release, the criteria can be revised again at any time by the advisory board, which meets
at least three times each year.
Participation in the program is completely voluntary and open to both domestic and foreign-made
products (although, to date, no submissions have been made from foreign producers). SIRIM
evaluations require an at-cost fee, and include both product testing at SIREVI's in-house lab, and
site visits to assess the manufacturing process.
Upon certification, manufacturers receive a certificate listing the manufacturer's name, the certified
product's brand and model, and details of its main components. The certificate also specifies the
type of certification issued. The certificate allows holders to print the certification category (e.g.,
"CFC-Free") on product labels. Certificate holders are subject to continued surveillance through
annual inspections by SIRIM, to ensure that certified products continue to satisfy the requirements
of the certification program.
Program Methodology
SIREVI's product certification program is a single-attribute, seal-of-approval program. Product
categories are submitted by the public (including manufacturers) and chosen based on market
demand for product certification, as assessed through periodic discussions held with consumers
and manufacturers. Product criteria are based on a single environmental attribute, such as being
CFC-free, energy-efficient, or biodegradable. The certification process involves both on-site
inspections and product testing by SIRIM employees.
Other Information
In a separate environmental management system (EMS) certification program, SIRIM has made
reciprocal arrangements with two foreign certification programs in the interest of companies who
export to or from Malaysia. One arrangement is with the Japanese Audit and Certification
Organization for Environment (JACO), with whom SIRIM conducts joint facility inspections for
EMS certification. Since many Japanese companies have Malaysian branches, this arrangement
reduces the expenses for Japanese and Malaysian inspectors conducting EMS certification. SIRIM
has another arrangement with the Canadian Standards Association (CSA) in which Malaysian
companies, inspected by SIRIM according to CSA standards, are granted the CSA's EMS
certification. This arrangement is highly beneficial to Malaysian manufacturers because of the
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large volume of Malaysian exports to North America. This system makes it possible for Malaysian
companies to obtain EMS certification that is more widely recognized in North America where
they conduct the bulk of their business, without the expense of flying CSA inspectors from Canada
to Malaysia.
Malaysia has had significant involvement in ISO activities, having been a member of ISO
Technical Committee 207 since 1994 and also a member of each of the three sub-committees, of
which SC3 deals with environmental labeling. The Malaysian ISO delegation consists of a 16-
member committee, including one SIRHVI representative.
A number of industries, namely textiles, timber, dyeing, rubber, and electronics, have developed
private industry-specific environmental management certification programs. The private
Malaysian Timber Industry Board has also proposed a timber certification program and conducted
a limited pilot program. National labeling standards for such products may be developed by
SIRIM in the future, though there are no concrete plans to do so as of yet.
References
Heinke, Gary W. et al., Final Report: Development of an Eco-label Certification Programme for
Hong Kong/RC96-19. Hong Kong: Research Centre of the Hong Kong University of Science and
Technology, June 1996.
Raj, Rajinder, General Manager of SIRIM QAS. Personal communication with Abt Associates,
Summer 1997.
SIRIM. Certification of CFC-Free Freezers and Refrigerators. August 1997.
Product Categories
Final Categories
Refrigerators
Under Development
Detergents
Appliances
Lighting fixtures
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THE NETHERLANDS' STICHTING MILIEUKEUR
Introduction
The growing interest in environmental issues throughout the 1980s in the Netherlands encouraged
the Ministry of Housing, Physical Planning and Environment, and the Ministry of Economic
Affairs to create the "Stichting Milieukeur," an independent foundation for voluntary
environmental labeling, in 1992. Prior to the creation of the Dutch ecolabel, the government had
established the Environmental Advertising Code to discourage the use of false environmental
advertising claims. The Stichting Milieukeur (the Environmental Review Foundation) built upon
the public policies that are the basis of the Environmental Advertising Code by creating a seal-of-
approval program.
The Stichting Milieukeur is made up of representatives from government, consumers,
manufacturers, and retail, trade, and environmental organizations. Although the EU, of which the
Netherlands is a member, has an ecolabel program, the Dutch government proceeded with its own
program to better accommodate goods and services unique to the Dutch market. It retains ties to
the EU program, however, as a Competent Body. As of October 1997, the Stichting Milieukeur
has set and published award criteria for 50 product groups, and has awarded the Milieukeur to 16
of these groups. The Milieukeur has also been awarded to foreign companies in the copy paper and
chairs product categories.
Recent Developments
The Stichting Milieukeur has not changed much since its inception. The primary change has been
an increase in reliance on market trends. More emphasis is being given to products categories that
have a strong market presence where competition for an award can have the greatest environmental
gain, for example, paper hand dryers, cotton hand dryers, and toner cartridges.
Program Summary
Although the program was founded and is supported by the Dutch government, the Stichting
Milieukeur operates the environmental labeling program independently. The Milieukeur Board,
assigned the essential role in selecting product categories and establishing award criteria, is
composed of representatives from the government and manufacturers, consumers, retail trade, and
environmental organizations that founded the Milieukeur. In addition to the Board, a certifying
institution, recognized by the Board and requested by the manufacturer submitting the product for
evaluation, is responsible for testing potential products based on a life-cycle assessment and
assessing whether or not a product meets the defined standards.
The first phase in the award process is coordinated by the Stichting Milieukeur. Manufacturers,
consumer groups, trade associations, or any other interested party can submit a request for the
creation of a new product category to the Stichting Milieukeur. The board may then approve or
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reject this application based on a screening study, which may be contracted to an outside company,
that determines the expected environmental gain associated with the product category. Criteria are
developed only for product groups in which there are clear differences in environmental quality
among products in the same category. If the product category is judged to have the potential for
environmental gain, a certifying institution uses a "cradle-to-grave" approach to establish the
environmental burden of products in the product group. If this study suggests that the
environmental gain will be significant, proposed award criteria for the product groups are
discussed in a hearing with involved parties. The Stichting Milieukeur then decides whether to
adopt the product category and its associated criteria. Product categories are reviewed every one to
three years, and have been updated based on new technologies and changes in manufacturing
processes.
Once the criteria for the product category are approved and published, individual manufacturers
and importers may submit a product for individual certification to a certifying institution. If a
product meets specifications, the certifying institution awards the applicant the use of the logo and
signs a contract. All of these processes are confidential. An initial fee of 1,000 guilders ($505 US)
is collected, and then an annual fee of 1.5 percent of sales of the product is required for use of the
certification. Products are audited every 12 months by the certifying institution to ensure
compliance.
Program Methodology
As mentioned above, manufacturers, consumer groups, trade associations, or any other interested
party can submit a request for the creation of a new product category to the Stichting Milieukeur.
Product categories are evaluated on their potential environmental impacts. Once product
categories are chosen, product criteria are developed using a life-cycle-analysis approach. The
Stichting Milieukeur does follow SETAC guidelines in its life-cycle assessment.
When selecting product categories and developing criteria, the Stichting Milieukeur takes into
account information from literature and studies relating to the product category , as well as other
programs' previous life-cycle-analysis findings. The Stichting Milieukeur also may conduct its
own independent testing and studies, and will also obtain information pertaining to the product
category from participating producers. In developing its award criteria, the entire "cradle-to-grave"
of a product's life cycle is taken into account and the product is assessed in terms of: the impacts of
raw material extraction and processing, the manufacturing of the product, transportation and
distribution of the product, the product uses as well as its potential for re-use, recyclability, wastes
during disposal, the product ingredients, and, finally, the environmental performance during the
production process.
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Other Information
One of the more unique aspects of the Stichting Milieukeur is that it established award criteria for
several food categories, including fruits, meats, dairy products, vegetables, and grains. To date, the
Stichting Milieukeur is the only environmental labeling program that has established criteria for
food as well as non-food categories. They made this decision based on the results of a study that
indicated a need for labels on food products.
Although the government uses environmentally-labeled products for procurement on an informal
basis, the Stichting Milieukeur is not involved in any formal arrangements with government or
retailer procurement programs. Retailers do not preferentially select environmentally-labeled
products, but do respond to consumer demand.
The Stichting Milieukeur is a Competent Body in the EU environmental labeling program. They
are aware of and employ ISO standards, though these standards do not now play a strong role in the
program's activities. They are not a member of GEN.
The Stichting Milieukeur reports that it actively works toward transparency and harmonization. It
has a formal arrangement with Scandinavia's Nordic Swan and Germany's Blue Angel, two of the
more developed programs. The three programs share ideas and jointly develop criteria for products
(for example, toner cartridges and chain oils), allowing for more efficient criteria development and
operation.
References
Brenninkmeijer, Helga. Stichting Milieukeur. Personal communication with Abt Associates.
Summer 1997.
Luykx, Elvira. Stichting Milieukeur. Personal communication with Abt Associates. Summer
1997.
Stichting Milieukeur, The Dutch Ecolabel: Added Value for Products and the Environment.
Stichting Milieukeur, Background Documents, 1996.
Product Categories (number of awarded products in parentheses)
Final Product Categories
Adhesive label
Automatic car-wash
Board and card games
Bottom organic household waste bin
Car care products
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Cat litter (18)
Central heating systems
Chain forms
Chairs (1)
Cleaning and product recycling of industrial gloves
Clothes
Coffee filters
Coffee makers
Copying paper (6)
(Concrete) Pavement tiles
Envelopes
(Smooth) floor covering
Footwear
Furniture (with the exception of chairs and other seating)
"Green Funds"
Hand dryers (paper)
Hand dryers (cotton)
Handshowers
Offset cleaning agents
Offset paper
Paints
Personal computers
Ring binders/organizers (5)
(Other) seatings with exception of chairs
Refrigerators
Television sets
Toilet paper (2)
Toilet chemicals
Toner cartidges
Window products (curtains, etc.)
Writing materials (1)
Writing paper (17)
Apple/pear (1)
Barley^eer
Bread (3)
Flowers and pot-plants
Mushrooms
Onions
Pepper (1)
Porcmeat
Potatoes (30)
Sprouts, leek, broccoli, cauliflower, headed cabbage, carrot, strawberry
Sugarbeet
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Tomato, cucumber, courgette, aubergine, melon
Wheat (1)
Categories Under Development
Duvets/pillows
Carpets
Chain oil
Other concrete paving products
Paint cleaners
Dairy products
Meat
Sugar
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NEW ZEALAND'S ENVIRONMENTAL CHOICE
Introduction
New Zealand officially started Environmental Choice New Zealand, a voluntary seal-of-approval
program, on July 10, 1990. The stated objectives of the program are: to provide an incentive for
manufacturers and importers to reduce the environmental impacts of products sold in New
Zealand; to recognize the genuine actions by companies to reduce the adverse environmental
impacts of their products; to provide a clear, credible and independent guide to consumers wishing
to take account of environmental factors in their purchase decisions; to encourage consumers to
purchase goods that have lower environmental impacts; and, ultimately, to improve the quality of
the environment and to encourage the sustainable management of resources. Product category
criteria have been published for 18 product categories. They are all currently under review.
Revised criteria are expected to be published toward the end of 1997.
Recent Changes
There has been a significant change in the organizational structure of New Zealand's
environmental labeling program. On July 1, 1997, Telarc (the Testing Laboratory Registration
Council, or the Council) New Zealand, the organizational body administering the environmental
labeling program, was restructured. A new separate company with its own Board of Directors,
Telarc Limited, was established to provide all certification services. The accreditation activities
are now operating under a new trading name, International Accreditation New Zealand.
Program Summary
Environmental Choice New Zealand is administered by the Testing Laboratory Registration
Council (the Council) under a formal memorandum of agreement with the Minister for the
Environment. The Council's operational unit, International Accreditation New Zealand, is the
New Zealand accreditation authority for laboratories and inspection bodies, and manages
Environmental Choice New Zealand. The Council is a statutory body which operates
independently on a user-paid, non-profit basis.
The Environmental Choice Management Advisory Committee (ECMAC) is an independent
committee appointed to advise the Council on the operation of the program. ECMAC includes
individuals appointed to provide broad representation from manufacturing, retailing, packaging,
environmental, academic, and consumer interests. ECMAC also includes a representative from the
Ministry for the Environment.
ECMAC is responsible for choosing suitable product categories for Environmental Choice New
Zealand. Once ECMAC has decided upon a product category, it sets up a Task Group specific to
that product category to develop criteria. After the Task Group has completed a draft of the criteria
specifications, ECMAC releases the document for public comment. The public comment period
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lasts for at least 60 days. The Task Group's responses to these comments are not made available to
the public; only the background papers on product specification developments are made accessible
to the public. The Task Group then takes these comments and revises the Specification, after
which the document is referred to ECMAC. ECMAC, in turn, recommends the requirements to the
Council. The Council then decides whether to approve the specification for publication.
Product suppliers, which may include manufacturers, importers, wholesalers, and retailers, may
apply for a license to use the Environmental Choice New Zealand label as soon as a product
category specification has been published. A life-cycle approach is used to analyze whether the
product satisfies the criteria. Environmental Choice New Zealand may require product testing
performed by an accredited laboratory, and/or examination of the relevant manufacturing records to
verify that a product meets the product category specification. If the Environmental Choice
assessor is satisfied that a particular product complies with the requirements, the applicant is
granted a license to use the program's label. Applicants pay an application fee ($1000), and, if a
product is accepted, an annual licensing fee as well. Licensing fees are calculated on a sliding
scale depending on the sales volume for that product, and run between $1,000 and $5,000.
License holders are subject to payment of fees and continued compliance, which is monitored by
Environmental Choice New Zealand throughout the period. Licenses are renewed annually.
Environmental Choice New Zealand gives license holders notice before revising product category
specifications and 12 months, if necessary, to adjust to new requirements. As of January 1997,
three companies have been granted licences. These licenses cover over 50 separate paint and
carpet products.
Program Methodology
ECMAC is responsible for choosing suitable product categories for Environmental Choice New
Zealand. A Task Group is then set up by ECMAC for each product category to develop criteria. In
choosing product categories, the environmental impacts of the potential categories, stakeholder
votes and advice from ECMAC, and suggestions from producers are all taken into account. A life
cycle approach is used to analyze whether the product satisfies the criteria, which takes into
account every stage of the product's life cycle, from "cradle-to-grave." Factors such as raw
material use, product uses, recyclability, potential for reuse, product ingredients, and environmental
performance of the production process are all taken into consideration. Similar to other
environmental labeling programs, Environmental Choice New Zealand also uses literature, other
programs' LCAs, independent testing and studies, and participating producer's suggestions when
developing their product criteria. Finally, Environmental Choice New Zealand uses generic
environmental impact assessments in developing its criteria. It does not, however, follow SETAC
guidelines in its LCA.
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Other Information
Because Environmental Choice New Zealand uses a sliding scale of licensing fees, it is able to
accommodate the needs of small and medium sized businesses.
In setting up Environmental Choice New Zealand, the government wanted to ensure that the
program be credible, practical, independent, nonpartisan, and comparable to other programs such
as Canada's Environmental Choice Program. To harmonize and coordinate with other programs,
Environmental Choice New Zealand has aligned its procedures with the requirements of: the ISO
14020 and ISO 14024 guidelines; the Global Ecolabeling Network guidelines; and the World
Trade Organization, Technical Barriers to Trade Agreement, Code of Practice. Product criteria
developed by other programs are considered when Environmental Choice New Zealand product
specification documents are prepared. Additionally, Environmental Choice New Zealand is in the
process of exploring specific opportunities to recognize local conditions, such as regulatory
requirements, affecting other labeling programs as well as products manufactured outside New
Zealand.
Environmental Choice New Zealand reports that it has not had any trade conflicts to date.
References
Environmental Choice New Zealand. Published Specifications. July 1997.
Environmental Choice New Zealand. Schedule of Fees - 1997/8.
Heinke, Gary W. et. al. Final Report: Development of an Eco-label Certification Programme for
Hong Kong/RC96-19. Hong Kong: Research Centre of the Hong Kong University of Science and
Technology, June 1996.
Russ, Marje. International Accreditation New Zealand. Personal Communication with Abt
Associates. September 1997.
Product Categories (number of awarded products in parentheses)
Final Categories
Zinc air batteries
Carbon zinc batteries
Lead acid batteries
Recycled plastic products
Laundry detergents
Machine dishwashing detergents
Hand dishwashing detergents
Re-refined lubricating oil
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Paints (41)
Fine papers
Newsprint and derived products
Sanitary paper products
Moulded paper products from recycled paper
Macerated paper products from recycled paper
Recycled papers
Wool pile carpets (14)
Wool-rich pile carpets
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SINGAPORE'S GREENLABEL
Introduction
The Ministry of the Environment (ENV) in Singapore launched its ecolabeling program, the
"GreenLabel," in May 1992 to "promote green consumerism" among Singapore's citizens. The
GreenLabel was formed as part of Singapore's "Green Plan," which is the country's overall
environmental management plan. The GreenLabel is a voluntary seal-of-approval program and is
open to both Singaporean and foreign companies that meet the specified product criteria.
According to the Ministry of the Environment, the GreenLabel is designed to raise consumer
awareness of products that exert comparatively fewer impacts on the environment, and to raise
environmental awareness in general. In addition, the GreenLabel is designed to provide an
incentive for "manufacturers to account for the environmental impact of their products, and to
design and supply environmentally benign products" (Ong, 1997).
Singapore's GreenLabel program cites several measures as evidence of its success in increasing
environmental awareness among consumers. In a 1994 survey of 1,600 households, 50 percent of
respondents said that they recognized the GreenLabel. Of these, 78 percent recognized the
GreenLabel as a signature of environmentally preferable products. A significant number of those
surveyed said that they would pay up to 10 percent more for environmentally preferable products.
Thirty percent of those surveyed said that they consider a product's environmental attributes as part
of their purchasing decision process.
When the GreenLabel program began in 1992, award criteria were released for only five product
categories. As of June 1997, the program covered 26 product categories broadly classified into ten
product groups. As of March 1997, 702 products carry the GreenLabel. These products are
produced by 137 different manufacturers.
Recent Developments
The GreenLabel program reports that since the program's inception in 1992, it has adopted the
methodology for determining award criteria as outlined below. The program reports that there
have been no significant changes in this methodology since the program began.
Program Summary
The GreenLabel program is administered by the Environmental Health Department under the
Ministry of the Environment. The ENV Secretariat receives proposals for new product categories
from the public and industry. In addition, it is the Secretariat that receives and processes
applications for the GreenLabel from manufacturers, collects fees, responds to inquiries about the
program from the public and applicants, produces newsletters on the GreenLabel program, and
provides information about the program to the media.
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Draft product criteria are developed by separate Technical Workgroups (one for each product
category) consisting of experts with knowledge of the manufacture, distribution, usage, and
disposal of products in the category under consideration. Once draft product criteria have been
developed by the Technical Workgroup, an Advisory Committee, consisting of representatives
from industry, academia, statutory organizations, and environmental groups, assists the Secretariat
in endorsing the most appropriate product criteria for the GreenLabel. These draft criteria are
released to the public and industry for comment.
As well as being peer reviewed, the public and industry have a 30-day period in which to provide
comments on the draft product criteria. The Secretariat collects these comments and forwards
them to the Advisory Committee for review and consideration. The finalized criteria are forwarded
to the Approving Board (consisting of senior staff members from the Ministry of the Environment)
for final approval. Although the public comments and the Advisory Committee's responses are not
published, once approved, the Secretariat publishes the final criteria and manufacturers are then
allowed to apply for the GreenLabel.
Manufacturers with products that meet the specified product criteria are equally eligible to apply
for the GreenLabel. Applicants are given application kits that lay out the terms and conditions for
product approval and for the use of the GreenLabel. Compliance with the final criteria are verified
through quality control and production record checks, as well as testing of sample products in
accredited laboratories. An approved product is granted a license to carry the GreenLabel logo for
three years. Product criteria are reviewed every three years in order to keep up with the latest
technological developments associated with the product category. If major revisions to the product
criteria are made at this time, manufacturers may be required to have their products re-tested to
ensure that they comply with the revised criteria.
The GreenLabel is open to both domestic and foreign manufacturers wishing to become eco-
certified in Singapore. This is especially important for Singapore, since the majority of products
available in Singapore are manufactured overseas. As a result, it is important for ENV to
encourage and convince foreign manufacturers to apply for and use the GreenLabel on their
products before shipping them to Singapore. Foreign companies often employ agents or
distributors in Singapore to work with them to apply for the GreenLabel. The Ministry of the
Environment has made suggestions that an international and/or regional body should be set up to
initiate information exchange and to promote methods of mutual recognition; however, a formal
proposal of this nature has not been made.
ENV bears all the administrative costs of the program so fees are kept low in an effort to encourage
as many manufacturers as possible to apply for the GreenLabel. If a company applies for
certification of a product within one year of the date of release of the final criteria for that product
category, it does not pay any fees for the first five years. If the application is made a year or more
B-90 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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after the release of the final criteria, fees are waived for a period of only three years. Other than the
certification fees, most of which are waived, the manufacturer is required to pay for product
testing.
Program Methodology
When the ENV Secretariat receives proposals for product categories, it determines their suitability
for the GreenLabel by evaluating the environmental impacts of the categories. Once product
categories are selected, award criteria are drafted. Award criteria are based on a simplified life-
cycle assessment, which assesses the environmental impacts of the "few most important
parameters" for each product category. Instead of examining every impact that a product exerts on
the environment, from cradle-to-grave, the Singapore program isolates and studies the most
important environmental concerns for the country. For example, products may be assessed on their
potential impact on water and energy resources, since Singapore is not self-sufficient in either of
these areas. Or the assessment may be based on solid waste disposal impacts, since Singapore has
very limited solid waste disposal capacity. Award criteria may also based on literature and
environmental studies on the product categories' impacts on the environment, other programs
studies and award criteria, previous life-cycle assessments that may have been conducted by other
programs, and participating producers' input and knowledge about the product categories.
Additionally, the product use, its ability to be recycled, and its ingredients are considered when
developing award criteria.
Other Information
Singapore's Ministry of the Environment intends to review the GreenLabel criteria once the
International Standards Organization's (ISO) 14020 standards for ecolabeling are finalized.
However, the Ministry, does not believe that the GreenLabel scheme will undergo major
restructuring based on its review of the current ISO 14020 draft documents.
The GreenLabel program is non-revenue-generating; therefore, media promotion of the program is
done on a relatively limited basis. The major form of promotion for the program is actually
through the manufacturers themselves. Manufacturers who apply for the ecolabel are required to
use it on their certified products. Licensees' advertisements are the main vehicle for spreading the
word about the GreenLabel. Advertising promotes the manufacturer's products as being
environmentally preferable, adding value to the products, and is of benefit for the program. ENV
also publishes The Resource Conservation Bulletin, which provides regular updates on the
program. The GreenLabel is also promoted during Singapore's annual "Clean and Green Week"
held in schools and youth fairs.
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References
Dr. Peck Thian Guan, Deputy Director, Environmental Technology Centre, Singapore Productivity
and Standards Board. Personal communication with Abt Associates. July, 1997.
Mr. Alvin Ong, Ministry of the Environment. Personal communication with Abt Associates.
August, 1997.
Ministry of the Environment, "Make the GreenLabel Your Choice: A Guide to the Singapore
Green Labelling Scheme.
Ministry of the Environment, Resource Conservation Bulletin, July, 1996.
Dr. Peck Thian Guan and Mr. Tan Choon Seng, The Singapore Eco-Labelling Scheme,
January/February, 1997
Product Categories
Final Categories
Stationary Paper
Hygiene Paper
Printing Paper
Office Automation Paper
Carbon-zinc battery
Alkaline battery
Compact fluorescent lamp (integral)
Compact fluorescent lamp (modular)
Standard laundry powder detergent
Concentrated laundry powder detergent
Laundry liquid detergent
Dishwashing detergent
Floor cleaner
Washing machine
Correction fluids/tapes
Hair-spray/gel/mousse
Deodorant sticks/rollers/spray
Shaving foams and creams
Computer system unit
Computer monitor
Computer system with 'built-in' monitor
Precast concrete products ()
Bricks (made from waste or recycled materials)
Tiles/Ceramics (made from waste or recycled materials)
B-92 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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Solar cell powered calculators
Solar cell powered watches
Categories Under Consideration
Air conditioners
Refrigerators
Freezers
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-93
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SPAIN'S AENOR - MEDIO AMBIENTE
Introduction
The Medio-Ambiente ecolabeling program in Spain was developed in 1993 by the Spanish
Association of Standardization and Certification (AENOR). AENOR, a privately-run organization,
acts as the Competent Body for awarding the European Union ecolabel in Spain (as part of the EU
scheme). AENOR is a member of the Global Ecolabeling Network (GEN) and participates in the
development of the International Standards Organization (ISO) ecolabeling standards. The
program is voluntary, and aims to promote the production of environmentally preferable products
and to provide information about the environmental impacts of available products. To date,
criteria have been set for three product categories: paints and varnishes, polyethylene bags for
waste, and polyethylene bags for the supermarket. In total, 14 labels have been awarded for
positive environmental attributes.
Recent Developments
Spain's ecolabeling program has changed little in its first three years of operation. Its rates of
product category definition and award criteria development are, however, increasing. Product
groups for which criteria development is very close to being completed include: paper products,
solar plates for solar lighting, photocopy machines, and cleaning products for cars. Additionally,
AENOR is working on criteria for vacuum cleaners, TVs, glass materials, tiles, and wood/metal
transporting materials.
AENOR notes increased retailer interest. With the growing interest of retailers in Spain's ecolabel,
this area could develop in the near future. Because the program is fairly new, however, associations
with procurement programs, either formal or informal, have not been developed.
Program Summary
Product groups and criteria are suggested by manufacturers and consumers and are selected by
AENOR based on market studies. They are then forwarded to the AENOR Environmental
Certification Technical Committee. This committee is composed of members of interested parties,
including manufacturer associations, consumer associations, ecological groups, test laboratories,
and control and inspection bodies. The criteria are then developed and approved by the
Committee. Criteria are reviewed every three years. AENOR reported that any interested party
may participate throughout the entire process.
Once award criteria are established, applicants may submit an application to the AENOR
environmental division. AENOR audits the applicant and sets up testing by an accredited
laboratory (selected by the Spanish Accreditation Body). If the review is favorable, the application
is passed on to the Environmental Certification Technical Committee. If there are no objections,
the Committee approves the application and awards the label. All application information is kept
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-95
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confidential until an award is given, when applicant information becomes public. The applicant is
responsible for an initial fee of about $700, which includes all testing and audit fees. Once
awarded use of the label, the applicant then pays 0.1 percent of its annual sales to AENOR, as well
as the fees for an annual compliance audit (the cost of this audit depends on the size of the
producer's facilities).
Program Methodology
A life-cycle analysis is conducted for each potential product group, taking account of impacts from
raw materials selection to product disposal.
Other Information
AENOR is sensitive to small and medium sized businesses, as reflected in its percentage-based fee
system, which allows companies with smaller sales to incur smaller ecolabeling costs. In fact, the
majority of products currently labeled in Spain are manufactured by small companies.
As mentioned above, AENOR is a member of ISO and GEN, and is the Competent Body for the
EU. AENOR bases its criteria on ISO standards and is a participating member in continuing
standard development. It believes that GEN is a very good organizing body, especially for
increasing the role of mutual recognition in ecolabeling. With GEN offices in Sweden, Japan, and
the US, AENOR feels that GEN has strength in an international forum. In an effort to increase
coordination among programs, AENOR is participating in a study conducted by the Danish
Environmental Protection Agency about European ecolabels.
According to AENOR, the organization has not encountered any trade issues or conflicts.
References
AENOR, AENOR-Medio Ambiente Eco-Label.
Tejera Oliver, Jose Luis, AENOR. Personal communication with Abt Associates. Summer 1997.
Product Categories
Final Categories
Paints and varnishes
Polyethylene bags for waste
Polyethylene bags for supermarkets
B-96 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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Under Development
Paper products, including envelopes and folders
Solar plates for solar light
Photocopy machines
Cleaning products for cars
Vacuum cleaners
Televisions
Glass materials
Tiles
Wood/metal palates for transporting materials
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-97
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SWEDEN'S GOOD ENVIRONMENTAL CHOICE
Introduction
Sweden's Good Environmental Choice program was founded in 1990 by the Swedish Society for
the Conservation of Nature (SSNC), Sweden's largest environmental organization. The
environmental certification program is private, positive, and voluntary, and has evolved into a
product and shelf labeling program from what was originally a guide to environmentally sound
shopping published by the Society in 1988. In 1989, the Swedish Cooperative Federation (KF),
one of Sweden's largest retailers, initiated a shelf labeling program that encouraged the purchase of
goods recommended by the Society's guide. By the end of 1989, the two other largest Swedish
retailers, 1C A and Dagab, joined with KF in sponsoring an ecolabeling scheme that became the
Good Environmental Choice Program.
Good Environmental Choice has criteria for 17 product categories and has approved 1,139
products to date.
Program Summary
The Society for the Conservation of Nature administers the Good Environmental Choice program,
although some of the program functions are performed by the Board of the program. The Board is
composed of three representatives from the Society for the Conservation of Nature (one of whom is
the chairman with a casting vote), as well as three trade representatives (one from each of the
sponsoring retailers).
The Board is responsible for selecting the product categories.
The Society for the Conservation of Nature develops criteria for each product category. Criteria
are based on single attributes. The Society does not attempt to perform a life cycle analysis (LCA)
to determine product criteria because it believes that unequivocal judgments, upon which LCA is
based, are not possible, even given "unlimited time and resources." For this reason, the program
has decided to concentrate its efforts on "things that can be changed now." The criteria are
written and approved independently of the Board, although in this process the Society may consult
universities, public authorities, and occasionally private businesses.
To have a product approved by the Good Environmental Choice program, manufacturers must
declare the ingredients of their products to the Society. In certain cases, more information is
required, such as the emissions of a product during production. Instructions of the required
information are available from the Society. Approved products are included in the register of
Good Environmental Choice products that is published by the Society, and are also identified by
program shelf labels in supermarkets of the three retailer sponsors. Because costs are borne by the
Society and the participating retailers, manufacturers are not required to pay a fee to have their
products listed in the register or displayed on the Good Environmental Choice shelves. A
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manufacturer may also choose to print the Good Environmental Choice falcon logo on their
product, in which case they must apply for a licence from the Society and pay a fee of SEK 5000
(US$664) for the first product, and SEK 1500 (US$200) for any additional products.
Program Methodology
The Good Environmental Choice program selects product categories and qualifying criteria. After
analyzing a resource impact matrix for a particular product category, the most important aspect
(e.g., bleaching for paper products) is identified as the basis of the criteria. The program does not
attempt to perform a life-cycle assessment (LCA).
Other Information
The Swedish Society for Nature Conservation began working in 1992 with the Swedish
Confederation of Professional Employees (TCO), the National Board for Industrial and Technical
Development in Sweden, and SEMKO (a tester and certifier of electrical products), to develop
environmental labels for personal computers. The goal of the labeling program is to influence
technical developments in the field of information technology, as well as make it easier for
companies to choose good equipment from the environmental standpoint. The first stage of the
program development created TCO'92, a label for computer monitors. The more recent program,
TCO'95, provides a label for complete personal computers (monitors, system unit, and keyboards).
The label for used for TCO'95 shows the falcon emblem from the Swedish Society for Nature
Conservation.
References
Swedish Society for Nature Conservation. BraMiljoval; Products approved as Good
Environmental Choice. 18 June 1996.
Swedish Society for Nature Conservation. Good Environmental Choice; Environmental Criteria.
24 May 1996.
Swedish Society for Nature Conservation. Good Environmental Choice; Environmental Criteria
for [variousproduct categories]. 1995.
TCO, Swedish Confederation of Professional Employees. TCO '95 Certification; Requirements for
environmental labelling of personal computers. Second Edition. Stockholm, Sweden. 12 April
1995.
B-100 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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TAIWAN'S GREEN MARK PROGRAM
Introduction
The Green Mark Program was launched in 1992 by Taiwan's Environmental Protection
Administration as a voluntary and positive ecolabeling program. The mission of the Green Mark is
to "promote the concept of recycling, pollution reduction, and resource conservation." The
program is currently administered by the Environment and Development Foundation (EDF), a
private institution.
The objectives of the Green Mark are to guide consumers in purchasing "green" products, and to
encourage manufacturers to design and produce them. The Green Mark expects to meet these
goals through the following steps: selecting "environmentally benign" products to meet domestic
demands; developing criteria; encouraging the public to consume Green Mark products, which will
in turn stimulate their production; and participating in international activities such as ISO and
GEN.
As of September 1997, The Green Mark Program had developed criteria for 41 product categories
(two more are nearly complete) and had certified 451 products. Of the current 102 licensees
(companies with one or more certified product), four are foreign-based — two from the United
States, one from Indonesia, and one from Singapore. These foreign-based licenses are for mercury-
free batteries, detergent, and water-saving cisterns.
Recent Developments
Until recently, the Industrial Technology Research Institute (ITRI) acted as the Implementation
Body of the Green Mark program; however, it was replaced by the Environment and Development
Foundation (EDF). EDF was created for the following reasons. First, because ITRI provides
consulting services for both the Environmental Protection Administration (EPA) and the Ministry
of Economic Affairs (MOEA) and is considered their "technical arm," it is viewed by the public as
a government-funded private organization. In contrast, it is hoped that EDF will be viewed as a
more impartial, private organization. Second, the EPA hopes to gradually decrease its control and
funding of the Green Mark program; it is anticipated that independent operation will help the
program to become self-sufficient over the next five years. Third, because EDF is independent, it
can be more flexible than ITRI in international cooperation activities. In the future, ITRI will give
both technical and administrative assistance to EDF.
The effectiveness of the Green Mark Logo in the marketplace is unclear. The Logo is reported to
be well known within the industrial sector, and many manufacturers are enthusiastic about
applying for it. They would like to see the program expand the number of product categories.
Among licensees surveyed, nearly 80 percent reported that the Logo is helpful for their company
image, and 72 percent said it is helpful for promoting business. Despite these positive veiws,
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several non-profit environmental groups are unsatisfied with the Green Mark Logo's low visibility
among consumers. A 1996 ITRI survey shows that only 40 percent of the general public recognize
the Logo, and only 30 percent of them report having bought labeled products.
Program Summary
The Green Mark is overseen by Taiwan's EPA and managed by EDF. The program is reviewed by
the Review Committee, which has representation from the government, non-governmental
organizations, academia, and other stakeholders. Other groups involved in the process are the
manufacturers who receive the Green Mark Logo, and stakeholders such as manufacturers
associations and consumer and environmental groups.
As the managers of the Green Mark Program, EDF is responsible for selecting product categories.
To do so, it performs an annual survey of experts, industrial associations, and NGOs. EDF also
collects information on product criteria, criteria scope, the major environmental concerns, and
sometimes test methods, from foreign ecolabeling programs. Among the attributes considered
during the review of proposed product categories are: threat to environmental quality; cannot be
replaced by an existing "environmentally benign" product category (e.g. mercury-containing
batteries can be replaced by mercury-free batteries); have less environmental impact than similar
products; and cannot have any adverse effects on health and safety of humans. In addition, there
must be a sizable number of domestic and foreign manufacturers. Proposed categories must be
approved by the Review Committee.
EDF is also responsible for developing product criteria. The development process follows three
guiding principals:
1. Product criteria should take into consideration Taiwan's local environmental conditions by
accounting for such problems as insufficient water and electricity supply, and a landfill
shortage, by including Green Mark criteria for low water and/or electricity use, or products
that produce less pollution.
2. Between twenty and thirty percent of manufacturers must be able to meet the criteria with
"reasonable" process modifications.
3. Criteria are compared with criteria from other ecolabeling programs.
Non-environmental attributes are addressed generally; it is the responsibility of manufacturers to be
in compliance with environmental and "other related regulations," such as quality, safety, and
industrial hygiene. As an example, the criteria for "Compost" cites the Council of Agriculture's
specific regulation on compost regarding functional characteristics, among other things. Proposed
criteria are submitted to a technical group convened for each product category. Criteria are
announced at public hearings with manufacturers, government agencies, and experts. Finally, the
proposed criteria are approved by the Review Committee. EDF usually develops six product
criteria every year.
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EDF is currently in the process of redesigning the product criteria review process. The Review
Committee consists of 21 members with very diverse opinions, and decision-making has become
difficult. Furthermore, the group meets only once every two months to review the product criteria.
A smaller committee is under consideration to ease meeting logistics and to reach consensus
decisions more quickly.
To be considered for the Green Mark Logo, manufacturers must provide documentation about both
the company in general, as well as the specific product. Importers can apply for the Green Mark
Logo if they can certify that they have had no significant environmental performance problems
during the year prior to the application date. Documentation must include test reports completed
by accredited laboratories on all quantifiable and measurable requirements in the criteria.
Applicants must also submit signed statements regarding other qualitative or nonmeasurable
requirements, for example, certification that a particular chemical was not used in the product's
formulation. EDF reviews the submitted documents from manufacturers, conducts an audit,
samples and inspects the product, makes a recommendation for award, and monitors the use of the
Green Mark Logo.5 The Review Committee is responsible for awarding the Logo. The award is
valid for two years, and the licensee may re-apply, following all requirements set forth in the
guidelines. No licensee has ever failed to qualify upon renewal.
Although it is the responsibility of the licensee to ensure that they remain in compliance with Logo
requirements, EDF conducts a follow-up site test with a random 20 percent of the licensees. EDF
also performs on-site investigations when EPA notifies them of a possible label misuse. Another
way that the Green Mark Program ensures that the label is used correctly is through market
sampling on the part of non-governmental organizations, as well as EDF and ITRI staff. EDF
reports that most instances of misused labels have been in advertising.
Currently, EDF collects only an application fee from applicants, although it plans to begin
collecting annual fees next year. The application fee is approximately US$715 for new
applications, and approximately US$535 for renewals. The Green Mark program's funding is
mainly from the EPA. Its budget increased from $70,000 in the initial years to $363,000 in the past
four years, and is expected to be $500,000 in fiscal year 1997.
The number of products approved for the Green Mark Logo has increased over the years, with the
exception of a significant drop in 1996 when the category "products using CFC substitutes" was
discontinued. This category was no longer necessary when all products in it, such as refrigerators
and air conditioners, changed to CFC substitutes. Products bearing the Logo are not only
purchased by retail consumers, but by industry as well. Industrial products include cement,
insulation material, and bricks. According to the Program Director, Taiwan should have a
5 EDF can invite experts and scholars to assist with product inspections.
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"Government Procurement Policy" within the next few years, which would require government
agencies to buy Green Mark products or products with equivalent environmental attributes.
Taiwan will give a "price preference" of 10 percent for such products, meaning that the
government will pay up 10 percent more for a product with specific environmental attributes.
Program Methodology
The Green Mark program is beginning to incorporate the concept of life-cycle assessment (LCA)
into its product criteria development. Taiwan adopted LCA because ISO 14204 requires that Type
I ecolabeling programs use "Life Cycle Consideration" when developing product criteria. This
approach differs from the early stages of Green Mark's product criteria development, when criteria
were often simple and based on one attribute, such as a preference for cloth diapers because they
reduced inputs into the solid waste stream. Because of the complexity of LCA, however, the Green
Mark program uses only simplified LCA techniques, using the matrix in ISO 14024 to make
qualitative judgments regarding the environmental attributes associated with each product. As an
example of the simplified LCA approach, when the criteria were developed for compact
fluorescent lamps, the following attributes were considered: the amount of mercury discharged
upon disposal, the level of electricity conserved, the volume of waste lamps disposed, and the
nature and quantity of toxic materials used in the manufacturing process.
When selecting product categories, EDF evaluates environmental impacts of potential categories,
uses a political process of voting, and selects categories when producers come forward voluntarily.
The following have been considered in the development of product criteria: extracting and
processing raw materials, manufacturing, transportation and distribution, product uses, reuse,
recycling, final disposal, and ingredient or materials restrictions. The development process
includes collecting information from literature, other programs, and participating producers.
Proposed criteria are peer reviewed, but the critiques are not available to the public. The Green
Mark Program does not conduct an impact assessment, but does follow SET AC guidelines.
Other Information
The program is accessible to all small and medium sized businesses, and although the Program
does not have a program to encourage their participation, half of the licensees are small or medium
sized.
Taiwan is an active member of GEN and is working closely with other ecolabeling programs on
ISO draft standards. In addition, Taiwan has finalized a mutual recognition agreement with
TerraChoice in Canada. One problem encountered during the negotiations was that Green Mark
requires recycled content tissue paper to be 100 percent domestically recycled. To facilitate the
agreement, "domestically" was deleted from the standard. Taiwan is also working with
TerraChoice on establishing a mutual recognition framework and process. The goal is to establish
a system that "enables reciprocal acceptance of tests, inspections, conformity assessment,
administrative procedures, and, where appropriate, environmental criteria." According to the
B-104 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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March 97 issue ofGENews, such a system would include a set of guiding principals incorporating
international trade agreements and ISO standards, and would deal with transparency and open
access, as well as mutual confidence and respect; flexibility to deal with "different ecosystem
sensitivities, products, values, priorities and marketplaces in different countries;" and cooperation
mechanisms.
In an effort to expand the awareness of the Green Mark Program, the program participated in the
five-day National Environmental Protection Week held in January 1997. The Green Mark booth
exhibited products bearing the Green Mark Logo. It received over 200,000 visitors during the
exhibition. On a more regular basis, the Program educates the public about new product criteria by
way of announcing them in the newspaper, distributing a quarterly journal to over 3,000 industrial
and governmental sector recipients, and posting updates on its Internet Web site
(http://www.greenmark.itri.org.tw).
References
Yu, Ning, Ph.D. Environment and Development Foundation, Taiwan, ROC. Personal
communication with Abt Associates. Summer 1997.
Global Ecolabel Network. GENews. March 1997.
Green Mark Program, Taiwan, ROC. [Online: Web]. Updated 26 March 1997, cited 10
September 1997. URL: http://www.interchg.ubc.ca/ecolabel/taiwan.html
Industrial Technology Research Institute. Green Mark; The Environmental Labelling Program in
Taiwan, Republic of China. January 1996.
Industrial Technology Research Institute. List of Green Mark Product Categories. 30 June 1997.
Green Mark Program, Taiwan, ROC. [Online: Web]. Cited 10 September 1997. URL:
http.//www.greenmark.itri. org.tw
Product Categories (number of awarded products in parentheses)
Final Categories
Products made from recycled plastic or waste rubber (15)
Office use papers from recycled paper (2)
Toilet papers from recycled paper (1)
Stationery papers from recycled paper (33)
Packaging papers from recycled paper (41)
Portland blast furnace cement (3)
Thermal insulation materials for building (5)
Mercury-free batteries (15)
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-105
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Products using solar energy battery
Cloth diapers (1)
Water-based paints (13)
Products made from recycled wood (6)
Products using substitute for CFCs [dropped] (82)
Beverage cans with stay-on tab (39)
Refilling pouch (4)
Single flush cisterns (96)
Personal computers (2)
Monitors (16)
Printers
Reusable shopping bags (2)
Electric motorcycles
Compact fluorescent lamps
Washing machines (29)
Laundry detergents (1)
Dish-washing detergents for handwash
Non-bleached towels
Dual-flush water saving cisterns (2)
Household refrigerators and freezers (30)
Household air conditioners (13)
Compost (1)
Building Material Made from Recovered Wastes (1)
Agricultural-use products from degradable plastics (new)
Packaging-use products from degradable plastics (new)
Sanitary products from degradable plastics (new)
Consumer products from degradable plastics (new)
Non-asbestos friction material (new)
Tooth Brushes with Replaceable Heads (new)
Glow Starter for Fluorescent Lamps (new)
Water-saving Faucets/Devices (new)
Water Conserving Dual-flush Cistern Retrofit Devices (new)
Guidelines Under Development
Shower heads
Stabilizers
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THAILAND'S GREEN LABEL SCHEME
Introduction
The Thai Green Label Scheme was initiated by the Thailand Business Council for Sustainable
Development in October 1993. It was formally launched by the Thailand Environmental Institute
(TEI) in association with the Ministry of Industry in August 1994. The scheme awards as seal of
approval to products meeting its criteria, and is voluntary in nature.
The program was developed with three objectives in mind: to provide reliable information and
guide customers in their product choices; to create an opportunity for consumers to make
environmentally conscious decisions and thus create a market incentive for manufacturers to
supply environmentally sound products; and to reduce environmental impacts that occur during
manufacture, use, consumption and disposal of products. To date, the program has developed
product criteria for nine product groups. The Green Label has been awarded to 41 products to date
in seven of the nine product categories.
Recent Developments
The program reports that it has not undergone any significant changes since its inception.
Program Summary
The Thai Green Label is composed of several committees. The Thai Green Label Board is the
overarching entity responsible for making all major decisions, including deciding on basic
strategies, selecting product groups for consideration, deciding on criteria, deciding on the
structures and levels of fees, and deciding on supporting activities. Its members are appointed by
the Minister of the Ministry of Industry.
The Board is supported by two groups: the Technical Subcommittee and the Secretariat (TEI and
The Thai Industrial Standards Institute-TISI). The Technical Subcommittee develops proposals
including product criteria, test methods, and the requirements for applicants. A new subcommittee
is established for each product category, composed of experts from relevant institutes, industry,
and environmental groups. The Secretariat organizes meetings and prepares materials to be
discussed by the Board.
The general public presents proposals for product groups to the Secretariat, which are then
submitted to the Board. Once the Board decides on the product categories, it sets up a technical
subcommittee to work on the criteria. The Secretariat is then responsible for submitting the final
proposal to the Board, which decides on the criteria and announces the decision to the public. The
criteria are developed on the basis of a life-cycle review and are reviewed every two years. The
draft criteria are made available to the general public upon request. The public can provide
comments on the draft criteria. Responses and critiques to these comments are not published.
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Once award criteria have been set, product applications are accepted. TEI examines applications to
make sure that all criteria are met, and then passes them along to TISI for further investigation.
Once criteria fulfillment has been determined, TEI registers the application and enters into a
contract with the manufacturer. An application fee of 1,000 Baht ($29 US) is collected from the
applicant, and then another fee of 5,000 Baht ($144 US) is collected once the product has been
awarded the label. TEI is responsible to ensure that the label is not misused.
Program Methodology
When choosing product categories, the Green Label uses "life-cycle-considerations" which
evaluate products based on their environmental impacts at each stage of the product's life-cycle.
Additionally, a political process and stakeholder and legislative body votes are used to chose
product categories. When product categories are selected, the product criteria are drafted.
Information for draft criteria are obtained from independent studies and testing, participating
producers, and other programs' previous LCAs. In fact, the Green Label maintains contact with
ecolabeling programs in Singapore, the EU, and Japan, and have adopted some of these programs'
criteria in establishing its criteria. Criteria take into account product uses, potential for reuse,
potential for recycling, ingredients, resource use, and wastes generated during final disposal.
Other Information
The Thai Green Label program is accessible to both small and medium sized business. The
Thailand Industrial Standards Institute is a member of ISO, and a representative attends ISO
meeting on a regular basis. The Green Label program maintains contact with the German,
Singapore, EU and Japan ecolabeling programs. Germany has, in fact, helped them to form their
program. The program does not report any trade conflicts to date, with regard to the Green Label.
Thailand is not a member of GEN.
References
Green Label Thailand. Product Category Summary. July 1997.
Green Label Thailand. A Guide to the Thai Green Label Scheme. August 1997.
Heinke, Gary W. et. al. Final Report: Development of an Eco-label Certification Programme for
Hong Kong/RC96-19. Hong Kong: Research Centre of the Hong Kong University of Science and
Technology, June 1996.
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Product Categories
Final Categories
Products made from recycled plastics
Energy-saving fluorescent lamps
Environmentally sound refrigerators
Low-pollutant emulsion paints
Water-economizing flushing toilets
No mercury-added dry-cell batteries
Recycled paper
Low-energy air conditioners
CFC-free sprays
Guidelines Under Consideration
Environmentally sound detergents
Energy-saving motors
Water-economizing closing faucets
Products made from non-bleached cloth
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US PROGRAMS
RECHARGEABLE BATTERY LABELING
Introduction
During the early 1990s, many in the rechargeable battery industry sought to create a nationwide
battery collection and recycling program. This voluntary industry initiative was impeded, however,
by differing state battery labeling and waste management requirements. One type of battery waste
might be subject to differing regulations, depending on the state in which it was generated. In
particular, differing waste management requirements stemmed in part from the Resource
Conservation and Recovery Act (RCRA) of 1976, which regulates the management of hazardous
wastes such as used rechargeable nickel-cadmium batteries. In May of 1995, EPA sought to
remedy the situation by promulgating the Universal Waste Rule which, among other things, eased
the regulatory burden on businesses that generate batteries and certain other hazardous wastes by
streamlining some of the most stringent provisions of the hazardous waste regulations. The Rule
only took effect, however, when states formally adopted it into their own regulations. As of May
1996, only 32 states had done this, resulting in differing requirements across states and further
complicating efforts to implement a nationwide recycling program. Subsequently, the Portable
Rechargeable Battery Association (PRB A) pushed for the Mercury-Containing and Rechargeable
Battery Management Act (the Battery Act), which was signed into law on May 13, 1996. The goal
of the Battery Act was twofold: to reduce the mercury content of consumer batteries and to
encourage battery recycling. As part of the latter goal, the Act made the Universal Waste Rule
effective immediately in all 50 states. In addition, it specified national uniform battery labeling
requirements for the collection, storage, and transportation of batteries covered by the Battery Act.
Covered batteries include rechargeable nickel-cadmium batteries, certain small sealed lead-acid
batteries, and certain rechargeable consumer products powered by such batteries.
Program Summary
Battery labeling under the Battery Act is unlike most other environmental labeling programs. As a
mandatory program, it is dedicated not to product quality differentiation like most labeling
programs, but to promoting recycling efforts following product use.
The Battery Act requires that each regulated battery (rechargeable nickel-cadmium batteries and
certain small sealed lead-acid batteries) or rechargeable consumer products without an easily
removable battery manufactured at least one year after the Act's enactment, bear the following
labels:
(1) 3 chasing arrows or a comparable recycling symbol.
(2) On each regulated nickel-cadmium battery, the chemical name or abbreviation "Ni-Cd" and
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-111
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the phrase "BATTERY MUST BE RECYCLED OR DISPOSED OF PROPERLY."
(3) On each regulated lead-acid battery, "Pb" or the words "LEAD," "RETURN," and
"RECYCLE," and if the regulated battery is sealed, the phrase, "BATTERY MUST BE
RECYCLED."
(4) On each rechargeable consumer product containing a regulated battery that is not easily
removable, the phrase, "CONTAINS NICKEL-CADMIUM BATTERY. BATTERY MUST
BE RECYCLED OR DISPOSED OF PROPERLY." or "CONTAINS SEALED LEAD
BATTERY. BATTERY MUST BE RECYCLED.", as applicable.
(5) On the packaging of each rechargeable consumer product, and the packaging of each
regulated battery sold separately from such a product, unless the required label is clearly visible
through the packaging, the phrase "CONTAINS NICKEL-CADMIUM BATTERY.
BATTERY MUST BE RECYCLED OR DISPOSED OF PROPERLY." or "CONTAINS
SEALED LEAD BATTERY. BATTERY MUST BE RECYCLED." as applicable (Public Law
104-142, Section 103)
Alternative labels can be certified by EPA if they convey the same information or conform to a
recognized international standard created for the same purpose as the regulation. The Battery Act
also gives EPA the authority to impose similar labeling requirements on other classes of
rechargeable batteries, should they be deemed toxic and harmful when disposed of through land
disposal or incineration.
EPA was designated the official administering agency of the Battery Act. Within EPA, specific
responsibilities have been delegated to various offices and divisions. Enforcement issues are
handled by the Office of Enforcement and Compliance Assurance, while the Office of Solid Waste
(OSW) is responsible for many of the other tasks. Specifically, OSW's Municipal Information and
Analysis Branch has been assigned responsibility for interpreting the labeling and easy
removability requirements of the act. Its responsibilities also include reviewing applications for
alternative labels, as well as petitions for exemptions from the easy removability requirements.
Program Methodology
All regulated batteries and certain rechargeable battery-containing products must be labeled
according to Section 103 of the Battery Act. Though some of these regulated product categories
are established by the law, the Battery Act does allow EPA to include other classes of batteries
should they be deemed toxic and harmful to human health and the environment when incinerated
or disposed of in landfills. In this way, the setting of product categories beyond that established by
the Act is left to EPA. Labeling criteria are set by the Battery Act however, since EPA can only
certify alternative labels if they convey the same information as the labels specified in the
regulations. With regulated products labeled, individual product evaluation does not occur.
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Other Information
In December 1995, the International Electrotechnical Commission (IEC) published International
Standard LEG 1429 for the labeling of batteries with a Moebius loop (three chasing arrows,
established by ISO 7000-1135 as the international recycling symbol) and chemical symbols
indicating the electrochemical system of the battery. IEC 1429 hasn't been adopted by the
American National Standards Institute (ANSI) as a voluntary US standard. In promoting the
Battery Act, however, US rechargeable battery manufacturers recognized that it would be
advantageous to comply with IEC 1429 in the interest of wider consumer recognition and reduced
burden on manufacturers seeking to comply with both domestic and international standards.
References
Bagby, Jefferson. President, Global Labeling International Limited. Personal communication with
Abt Associates. Summer 1997.
Bleacher, Sam. Portable Rechargeable Battery Association. Personal communication with Abt
Associates. Summer 1997.
England, Norm. Portable Rechargeable Battery Association. Personal communication with Abt
Associates. Fall 1997.
Fishbein, Bette. Extended Product Responsibility: A New Principle for Product-Oriented
Pollution Prevention. University of Tennessee, Center for Clean Products and Clean
Technologies, June 1997.
Lindsay, Clare. Office of Solid Waste, EPA. Personal communication with Abt Associates,
Summer 1997.
Mooney, Saskia and Howrey and Simon. Personal communication with Abt Associates, Fall 1997.
Nogas, Susan. Municipal Information and Analysis Branch of the Office of Solid Waste, EPA.
Personal communication with Abt Associates, Summer 1997.
The Mercury-Containing and Rechargeable Battery Management Act., Public Law 104-142.
Product Categories
Toxic rechargeable batteries (e.g. nickel-cadmium and certain small sealed lead-acid batteries)
Rechargeable consumer products without easily removable batteries
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THE CHLORINE FREE PRODUCTS ASSOCIATION (CFPA)
Introduction
During the early 1990s, environmental campaigns against the use of chlorine bleaching in paper
manufacturing prompted some manufacturers to seek alternative methods of paper processing.
Wishing to publicize the use of such alternative methods, paper and pulp manufacturers interested
in chlorine-free bleaching established the Chlorine Free Products Association (CFPA) in March of
1994 as a non-profit trade association dedicated to the elimination of chlorine-based chemistry in
manufacturing processes. Supported primarily by pulp and paper manufacturers and associated
businesses, CFPA's activities are focused on advocating totally chlorine-free (TCF) processing,
educating consumers on chlorine processing alternatives, and developing markets for TCF
manufacturers. On June 9, 1997, CFPA announced the development of a certification program for
the pulp and paper industry. It is also in the process of developing a certification program for
recreational and drinking water purification.
Program Summary
The CFPA pulp and paper certification program is completely voluntary and examines the
bleaching chemistry used in paper mills, bleach plants, and/or de-inking facilities. Facilities whose
bleaching processes are free of chlorine and chlorine compounds may be certified. While hired
technicians perform the actual site visit, CFPA staff set the criteria for chlorine-free processing
based on standard TAPPI (Technical Association of the Pulp and Paper Industry) processes used in
the pulp and paper industry. The manufacturing plant is visited biannually to ensure compliance
with TCF standards. Though CFPA itself is funded by member dues, there are unpublished
evaluation fees associated with the certification, which must be renewed annually.
For the pulp and paper industry, CFPA has developed two logos for use on paper products.
"Totally Chlorine Free" logos are reserved for virgin fiber papers that have been produced without
the use of pulp bleached with chlorine or chlorine compounds. "Processed Chlorine Free" logos
are for recycled content papers and indicate that any virgin fiber is totally chlorine-free and that the
recycled content, though it may have originally undergone chlorine bleaching, was not re-bleached
with chlorine-containing compounds when recycled. The logo also ensures that a minimum of 20
percent post-consumer waste was used. Once certified, companies may use the proper CFPA logo
in ads and on retail products. Certified pulp manufacturers may provide their logos to distributors
who market or process their chlorine-free goods, but they are responsible for the correct use of the
logo. Any use of the logos must be registered with CFPA. CFPA also asks certified facilities for
annual sales reports so that they can track the market success of CFPA's certified products. Two
facilities are currently certified. The pulp and paper industry is the first to use the logo, but others
will use it soon, except water purification.
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Program Methodology
CFPA's selection of product categories is done through environmental impact evaluation, political
processes, and manufacturer initiative. Product criteria are developed through a published peer-
review process. Product criteria address manufacturing processes, product uses, reuse, recycling,
ingredient or materials restrictions, and the environmental performance of production processes.
Both manufacturers' input and impending studies serve to inform the selection of product
categories and the setting of product criteria.
Other Information
As part of its efforts to promote chlorine-free processing, CFPA has been involved in efforts to
obtain federal procurement preference for chlorine-free papers under President Clinton's 1993
executive order 12873. This executive order directs federal agencies to purchase "environmentally
preferable" products, a designation whose current definition does not include chlorine-free papers.
The development since 1993 of several chlorine-free papers that meet federal specifications helps
argue for inclusion in the federal government's procurement program.
References
Beaton, Archie. Executive Director, Chlorine Free Products Association. Personal communication
with Abt Associates. Summer 1997.
Chlorine Free Products Association. Guide to TCP & PCF Papers. 1997.
"CFPA Works to Broaden'Environmentally Preferable'Designation." CFPA Today Spring 1997:
2.
Chlorine Free Products Association. Use of TCP/PCF Logos 1997 Certification Program. June 9,
1997.
Chlorine Free Products Association. A New Association was Formed to Promote TCP Technology
and Products. March 16, 1994.
Product Categories
Final Categories
Virgin fiber paper
Recycled content paper
B-116 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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Categories Under Consideration
Drinking water purification
Recreational water purification
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US ENVIRONMENTAL PROTECTION AGENCY'S
CONSUMER LABELING INITIATIVE
The Consumer Labeling Initiative (CLI) is a voluntary cooperative effort to foster pollution
prevention, empower consumer choice, and improve understanding by presenting clear, consistent,
and useful safe use, environmental, and health information on household consumer product labels.
The CLI was created by the US Environmental Protection Agency (EPA) to reach out to
consumers, the chemical industry, trade associations, and environmental and public interest groups
to determine what information is needed on consumer product labels, and how that information
should be presented. It is one of several EPA efforts resulting from the President's goal to
"Reinvent Government." The CLI has been highlighted as a prototype for the Agency due to its
innovative research process, one that brought together a cross-section of stakeholders and
successfully worked to gather input from diverse points of view. The CLI research and policy
formulation began with work groups that included EPA, federal and state government staff,
representatives from the United States' leading chemical companies, public interest organizations,
and other stakeholders. These groups worked together to ensure that the CLI would be as useful as
possible and that results could be used productively by everyone involved at the government,
industry, and consumer level.
The CLI is a multi-phased pilot project focusing on indoor insecticides, outdoor pesticides, and
household hard surface cleaners, some of which are FIFRA certified, meaning that they are
registered antimicrobials or disinfectants. Phase I of the project involved a qualitative consumer
research study, a review of comments solicited through a notice in the Federal Register, and a
literature review of relevant publications and reports of studies. Phase I research findings were
categorized into three areas: 1) labeling issues not requiring further validation; 2) labeling issues
requiring further development or statistical validation; and 3) education, policy planning, and
coordination issues. EPA has already implemented a number of interim label recommendations
based on Phase I findings. These include encouraging producers to: print telephone numbers on
product labels, use common names instead of formal chemical names, list "Other Ingredients"
instead of "Inert Ingredients," and use "First Aid" instead of "Statement of Practical Treatment."
Phase II of the CLI will include quantitative and secondary research, as well as education activities
and policy planning and coordination activities. The research study will focus on consumer
comprehension, attitudes, behavior, and satisfaction regarding labeling, as well as an evaluation of
labeling alternatives. Education activities will be aimed at consumers and will emphasize the
importance of reading the label. Through the policy and coordination activities, EPA will
investigate issues relating to ingredients, health and safety, and product storage and disposal.
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THE RAINFOREST ALLIANCE - ECO-O.K. CERTIFICATION PROGRAM
Introduction
The Rainforest Alliance is an international nonprofit organization dedicated to the conservation of
tropical forests. Founded in 1987, its mission is to develop and promote economically viable and
socially desirable alternatives to the destruction of rainforests, an endangered, biologically diverse
natural resource.
In 1991, the Rainforest Alliance created a labeling program called ECO-O.K, that specifically
targets agricultural products grown at the expense of tropical ecosystems. The program has
developed standards for bananas, coffee, and oranges, and is in the process of developing standards
for cocoa and cane sugar. They aim to promote sustainable production of these products in the
rainforests of Latin America. To date, ECO-O.K. has certified 5 farms for oranges, 3 farms for
coffee, and close to 100 farms for bananas.
Program Summary
Anyone can suggest an agricultural product to the Rainforest Alliance as a possible category.
Rainforest Alliance then evaluates the potential impact of the product and decides whether to
develop criteria. Certification criteria are developed by a team of producers (farmers), scientists,
conservationists, representatives of government agencies, and other stakeholders. Criteria are
determined by scientific and community issues, and vary based on specific community needs.
Once criteria have been determined, certification begins with a field evaluation by ECO-O.K.
technicians. The technicians document changes that must be made to meet criteria. After the
grower has made the changes, the technical team returns to the farm to prepare a detailed report
which is then passed on to a review board for approval or rejection. If approved, the product
receives the ECO-O.K. seal of approval, distinguishing the labeled product from other retail
products in the marketplace. Audits are conducted annually to ensure compliance.
Program Methodology
As mentioned above, anyone can suggest an agricultural product to the Rainforest Alliance as a
possible category. Once Rainforest Alliance evaluates the potential impact of the product, it
proceeds on whether to develop criteria. Criteria are determined by scientific and community
issues, and vary based on specific community needs. The certification criteria for the ECO-O.K.
project are unique compared to many of the other programs included in this report, in that they
measure social as well as environmental responsibility. The specific guidelines for each of these
criteria are extensive, involving many restrictions for each category. Although criteria have been
developed for bananas, coffee and oranges, the criteria for oranges are not yet available in English.
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Listed below are the basic principles to which any certified farm must comply. These standards are
used regardless of crop or country of production.
Conservation:
No deforestation of new farms
Protect wildlife and native plants
- no hunting
- special protection for threatened or endangered species
- Use native plants in buffer zones
Conserve forest patches and take measures to improve them as wildlife habitat
Protect streams and enact special protection for wetlands and riparian areas
Mandatory canopy cover over coffee and cocoa
No negative impacts on nearby parks and refuges
Conserve watersheds
Community
Fair and just treatment of workers
Adherence to local labor laws and to ILO conventions
The right to organize and join worker representative groups
Fair and reasonable working hours within context of the local labor economy
No racial discrimination
Age restrictions on hazardous jobs
Work should not interfere with education for children
Safe and sanitary working conditions
Dignified housing for workers living on the farm, including access to potable water
Access to latrines, washrooms, and potable water
Access to health care, including regular, mandatory, medical checkups for workers who
apply agrochemicals
Complete analysis of working areas to prevent accidents
First aid and fire suppressants readily available
Security measures, including proper safety equipment and secure storage of agrochemicals
Clean and orderly working environment
Good neighbor policy toward nearby communities
Respect for cultures and beliefs
Always a fair price and a green premium where possible
Cultivation:
Soil conservation
Vegetative cover
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Compost and recycle organic wastes
Planting on contours; vegetative erosion barriers
Minimal use of fertilizers, only when warranted by soil analysis
Crops planted only on suitable areas according to national land-use and soil analysis maps
Water conservation and reutilization
Pollution control, including processing plants and mills
Comprehensive waste management to reduce, reuse and recycle
Minimal and strictly managed use of pesticides
Other Information
The Rainforest Alliance has not experienced any trade issues. It states that trade issues tend to be
minimized because it is a voluntary, non-government, non-profit program.
As explained above, ECO-O.K. is a certification of sustainable operating practices. However, in
the European Union, the use of the word "eco" is legislatively restricted to mean "organic." The
ECO-O.K. label is therefore not used, for instance, on Chiquita brand bananas in the EU even
though its farms are certified.
References
Hoist, Eric. The Rainforest Alliance. Personal Communication with Abt Associates. Summer
1997.
Rainforest Alliance. Brochure. September 1997.
Rainforest Alliance. The ECO-O.K. Coffee Certification Project. March 1997.
Rainforest Alliance. ECO-O.K. Update Documents. May 1996.
Rainforest Alliance. Agricultural Certification Program, Better Bananas, General Production
Standards. August 1997.
Rodriguez, Sabrena. The Rainforest Alliance. Personal Communication with Abt Associates. Fall
1997.
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HVS ECO SERVICES' ECOTEL® CERTIFICATION
Introduction
The ECOTEL® Certification is a third-party seal of approval awarded by HVS Eco Services to
hotels and motels that "demonstrate a heightened level of environmental sensitivity." HVS Eco
Services, an environmental consulting firm serving the hospitality industry, created the ECOTEL®
Certification in November 1994 and has since awarded the certification to less than 5 percent of the
hotels that have applied.
The ECOTEL® Certification was developed in response to a heightened level of environmental
consciousness among travelers, as illustrated by the US Travel Data Center's studies, which show
that 87 percent of consumers claim to support environmentally-oriented travel companies.
Demand for eco-tourism prompted both travelers and hoteliers to wonder what aspects and what
level of environmental performance were considered "good." The ECOTEL® Certification helps
establish a benchmark for environmental performance, as well as a way for hotels' own
environmental claims to be independently verified.
According to HVS Eco Services, undergoing the ECOTEL® evaluation can help to highlight
potential environmental and conservation opportunities that can result in significant cost savings.
In addition, some ECOTEL®s (certified hotels) are reporting increases in bookings for meetings
and room reservations since attaining the certification.
Program Summary
The ECOTEL® Certification consists of a five-globe rating system where each globe represents a
different category of environmental performance: solid waste management; energy management;
water conservation and preservation; employee education and community involvement; and
legislative compliance and native land preservation. Hotels can be evaluated in any of these
categories, although most choose all five. Hotels need only one globe to be considered an
"ECOTEL®". Physical facilities and operating procedures are evaluated according to HVS Eco
Services' criteria which were developed in consultation with such hospitality and environmental
organizations as The Rocky Mountain Institute, The Ecotourism Society, Certified Utility
Consultants, and Cornell University's School of Hotel Administration. HVS Eco Services reports
that its criteria are reviewed and updated quarterly as well as in response to periodic technological
innovations. Although the criteria are proprietary information, evaluated hotels are briefed on
which specific certification requirements they failed to satisfy. Based on the evaluation, hotels can
be awarded an ECOTEL® Globe Award for each qualifying category.
The ECOTEL® evaluation process begins with a preliminary telephone interview to determine
whether a hotel is a viable candidate for certification. The hotel might be asked to submit to HVS
Eco Services documentation regarding its environmental program, or to describe specific
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environmental projects. Once a basic level of environmental performance is determined, an on-site
inspection is then performed by HVS Eco Services personnel who inspect the physical plant and
conduct interviews with management, employees, and possibly the local community. Management
and employee perspectives help to give evaluators a realistic picture of the hotel operations, while
interviews with the local community are conducted as part of their evaluation for the "employee
education and community involvement" and the "legislative compliance and native land
preservation" globes.
ECOTEL® evaluates hotels according to a three-tiered scoring system in which the first round
addresses the most basic standards of environmental performance, the second awards points for
more advanced levels, and the third gives points for outstanding environmental programs. Hotels
must earn all of the first-round points, but only 75 percent of the second-round points. Third-round
points are bonuses that count toward the second-round requirement. This variable scoring system
was created to allow for the individuality of different environmental programs, while ensuring a
minimum performance level. In addition, the scoring system is adapted for each hotel's size and
location. At the end of every evaluation, whether or not certification is granted, hotel management
is presented with a Justification Rating summarizing the results of the evaluation, as well as an
Environmental Action Plan describing methods to improve and ensure the longevity of the hotel's
environmental program.
Certified ECOTEL®s undergo scheduled inspections every two years, as well as surprise visits to
ensure continued environmental performance. ECOTEL® Certification can be revoked at any time
if there is substandard performance.
The ECOTEL® Certification conveys a number of promotional benefits upon its recipients,
including a license to use the ECOTEL® logo in signage and marketing. HVS Eco Services
promotes its member hotels through regional and international events highlighting the ECOTEL®s,
feature stories in international travel magazines, and exhibitions at international conferences.
ECOTEL®s are listed in a referral system, a number of international travel directories, and the
ECOTEL® Internet Directory. HVS Eco Services also provides information and ongoing
consulting to certified hotels on environmental products and services, environmental conferences,
and industry events.
ECOTEL® evaluations are completely voluntary; hotels must request to be reviewed. The
ECOTEL® program was originally funded largely by HVS Eco Services' consulting practice. HVS
Eco Services now requires an evaluation fee starting at $1,000. Fees are based on the size of the
hotel and are negotiable to accommodate smaller hotels that might have difficulty affording the
evaluation. Once the evaluation is completed, HVS Eco Services' consulting practice can be
further contracted to provide expertise on improving a hotel's environmental performance.
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Program Methodology
The ECOTEL® Certification program was a natural extension of HVS Eco Services' hotel
consulting practice into the environmental field. The ECOTEL® performance criteria were
determined through consultation with such hospitality and environmental organizations as the
Rocky Mountain Institute, the Ecotourism Society, Certified Utility Consultants, and Cornell
University's School of Hotel Administration. The criteria are proprietary information of HVS Eco
Services, and are therefore not disclosed to the public. However, a summary of the criteria is
available. The criteria cover such areas as the extraction and processing of raw materials,
manufacturing, transportation and distribution, product uses, reuse, maintenance, recycling, final
disposal, ingredient or materials restrictions, and the environmental performance of production
processes.
A numerical rating system, used to quantify the findings, is adapted for each hotel's size and
location. It consists of a primary, secondary, and tertiary qualifying round. Hotels must receive all
of the primary qualifying points in order to be considered for the secondary points, 75 percent of
which must be attained to achieve the ECOTEL® Globe Award. This 75 percent requirement
allows for flexibility within the prescribed standards by rewarding hotels for good environmental
performance despite differences among individual programs. The tertiary round awards bonus
points to those hotels with outstanding environmental programs.
ECOTEL® evaluates hotels in any of the five performance categories listed below, per the hotel's
request; most request all five. A hotel must earn the Globe Award in at least one category to be
considered an "ECOTEL®." The categories are as follows:
Solid Waste Management
Energy Management
Water Conservation and Preservation
Employee Education and Community Involvement
Legislative Compliance and Native Land Preservation
References
"Can You Believe the 'Eco' Label?." Successful Meetings February 1996.
HVS Eco Services. ECOTEL® Information Portfolio. July 1997.
Jones, Beth Frankowski. "Going Green in the Hospitality Market." Interiors and Sources March
1996.
Moffitt, Kimberly. Director of Marketing, HVS Eco Services. Personal communication with Abt
Associates. Summer 1997.
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Scoviak-Lerner, Mary. "Eco-Friendly Retreat In The Arizona Desert." Hotels March 1996.
Product Categories
Hotels
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THE ENERGY GUIDE: HOUSEHOLD APPLIANCE ENERGY
EFFICIENCY LABELING
Introduction
In December 1975, Congress passed the Energy Policy and Conservation Act (EPCA), the primary
purpose of which is to "conserve energy by enabling consumers purchasing appliances to compare
the energy usage of competing models" (US Federal Trade Commission, The Appliance Labeling
Rule, 1997). EPCA requires that Energy Guide labels be placed on certain new home appliances
including refrigerators, refrigerator-freezers, freezers, water heaters, clothes washers, dishwashers,
furnaces, room air conditioners, central air conditioners, and heat pumps. These appliances are
covered under EPCA because their energy costs can vary greatly, depending on their construction
and design. EPCA also directed standards and labeling for humidifiers and dehumidifiers, clothes
dryers, direct heating equipment, kitchen ranges and ovens, and television sets. The Federal Trade
Commission (FTC), which shares responsibility for EPCA's implementation, did not include these
products in the labeling program, however, stating that there were insufficient differences in energy
efficiency among different models.
The National Appliance Energy Conservation Act (NAECA) of 1987 amended EPCA by, among
other things, establishing minimum efficiency standards for all EPCA products. In 1988, National
Appliance Energy Conservation amendments added fluorescent lamp ballasts. The Energy Policy
Act of 1992 added general service fluorescent lamps and general service incandescent lamps,
including reflector lamps. It also expanded EPCA to address water efficiency issues by specifying
water flow labeling requirements for showerheads, faucets, water closets, and urinals. In 1994 the
FTC extended the rule to include pool heaters and certain other water heater types.
Program Summary
Under EPCA, the FTC was given responsibility for establishing the format of the Energy Guide
labels, while the Department of Energy (DOE), then the Federal Energy Administration, was given
responsibility for promulgating standardized test procedures and minimum efficiency standards,
and conducting a consumer education program to complement the labeling program.
The original label design was announced by the FTC in 1979; it required the disclosure of an
appliance's estimated annual operating cost as well as a comparison with similar models. For room
air conditioners and furnaces only, where variations in climate make a national average
meaningless, an energy rating figure was required on the labels. For all other appliances covered
by the law, it was required that labels disclose the cost of the average annual energy use for the
appliance in dollars and a comparison with similar models. The FTC has since revised the format
of these labels. Critics pointed out that expressing the energy use in dollars could be confusing
because the cost of energy changes over time. When energy prices changed by more than 15
percent from the previous baseline, the FTC required that new Energy Guide labels incorporate the
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new energy prices into their operating cost figures. This meant that two identical appliances on the
same storeroom floor could be labeled with two different operating costs, if energy prices changed
between manufacture dates. Comparisons among different models and brands were also thrown
off by this discrepancy, creating confusion among consumers.
On July 1, 1994, partly in response to this criticism, the FTC announced amendments to the
labeling requirements to make the label more "user-friendly." Among other things, the new
specifications require that primary energy use disclosures, previously given as estimated operating
cost, now be given in units of energy consumed per year. Estimated yearly operating cost is still
given in some cases, but it appears as a smaller figure toward the bottom of the label, allowing the
energy consumption figure to dominate as the primary figure on the label. Where given, the
operating cost is accompanied by the energy price used in its calculation, making explicit the fact
that the cost is simply a snapshot indicator and does not take in to account energy cost fluctuation
over time. Under this system, every appliance's primary energy use disclosure is a unique, fixed
figure. Although the labels vary somewhat for different types of appliances, they all contain
specific information on energy efficiency and costs. The current rule requires that, for covered
products other than fluorescent lamp ballasts, lamps, and plumbing fixtures, the text of the labels
include:
1. the manufacturer, model number, type of appliance, features, and size, all listed at the top
of the label;
2. a number in the center of the label which is either the appliance's energy consumption per
year or the energy efficiency rating (for room and central air conditioners, heat pumps, and
furnaces). Energy consumption may be given in kilowatt-hours, therms, or gallons per
year, depending on the type of fuel consumed. Energy efficiency ratings are presented such
that the higher the number, the more efficient the appliance and the less it costs to operate;
3. the "range of comparability" published by the FTC, showing the energy consumption or
energy efficiency rating of the most and least efficient models of similar size and features,
placed at either end of a bar below the appliance's energy use figure. This figure is marked
with a triangle at the appropriate position along the bar to convey how the appliance
compares with similar models; and
4. for most products, a boxed number at the bottom giving the appliance's estimated yearly
operating dollar cost based on the national average fuel cost in effect at the time the range
of comparability specified for that product was published. This national fuel cost and any
other assumptions used to calculate the figure are stated below the box. For central air
conditioners, heat pumps, and furnaces, annual operating cost information does not appear
on the label, but rather must be given separately on fact sheets available through the
manufacturer or in product directories compiled by industry trade associations.
Products not included in the above descriptions must meet different labeling requirements.
Fluorescent lamp ballasts and luminaries containing such ballasts must be labeled with an encircled
"E" indicating compliance with DOE minimum efficiency standards. Covered lamps must be
labeled with such figures as the electrical power consumed, its light output, and lamp life
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expressed in hours. Manufacturers of showerheads, faucets, toilets, and urinals must disclose their
products' flow rate in terms of water used per flush, minute, or cycle.
Program Methodology
The primary purpose of EPCA is to "conserve energy by enabling consumers purchasing
appliances to compare the energy usage of competing models" (US Federal Trade Commission,
The Appliance Labeling Rule, 1997). To accomplish this goal most efficiently, the FTC included
only those appliances for which there was a significant potential for a reduction in energy use due
to altered consumer purchasing behavior. For this reason, only those appliances that showed
significant differences in energy efficiency among different models were included in the Energy
Guide program.
As an information disclosure requirement, the Energy Guide program does not set product criteria
or evaluate individual products. The FTC does, however, establish the format of the labels. It also
requires that manufacturers of regulated appliances submit their energy consumption or energy
efficiency rating as determined through standardized DOE test procedures. This enables the FTC
to publish the annual range of comparabilities for each appliance. When the range of
comparability changes by more than 15 percent, the FTC requires that manufacturers print new
labels incorporating the new range.
References
Federal Trade Commission. "FTC Updates Energy-usage Disclosures for Home Appliances: New
Labels to be Simpler, More Useful to Consumers, FTC Says." FTC News May 24, 1994.
Mills, James. Attorney, Federal Trade Commission. Personal communication with Abt
Associates, Summer 1997.
US Federal Trade Commission. "Rule Concerning Disclosures Regarding Energy Consumption
and Water Use of Certain Home Appliances and Other Products Required Under the Energy Policy
Act (The Appliance Labeling Rule')." Code of Federal Regulations 16 CFR 305. January 1, 1997.
US Federal Trade Commission. "Rule Concerning Disclosures Regarding Energy Consumption
and Water Use of Certain Home Appliances and Other Products Required Under the Energy Policy
Act; Final Rule." Federal Register 59 FR 34014. July 1, 1994.
US Federal Trade Commission. "The US Appliance Labeling Rule." May 20, 1997.
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Product Categories
Refrigerators
Refrigerator-freezers
Freezers
Room air conditioners
Central air conditioners
Heat pumps
Water heaters
Furnaces
Dishwashers
Clothes washers
Fluorescent lamp ballasts
General service fluorescent lamps
General service incandescent reflector lamps
Medium base compact fluorescent lamps
Showerheads
Faucets
Toilets
Urinals
Pool heaters
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US EPA ENERGY STAR PROGRAMS
Introduction
The U. S. Environmental Protection Agency's (EPA) ENERGY STAR program is an umbrella of
voluntary programs consisting of: the ENERGY STAR Labeling program, the ENERGY STAR
New Homes program, the ENERGY STAR Buildings program and the ENERGY STAR Small
Business program. All the programs are administered by EPA's Atmospheric Pollution Prevention
Division; the Labeling program is jointly run by the EPA and the US Department of Energy
(DOE).
The overall goal of the various ENERGY STAR programs is to reduce air pollution from the
burning of fossil fuels (needed to generate the large quantities of electricity used in the United
States) by promoting the development and use of energy efficient products. ENERGY STAR
Partners (e.g., manufacturers, private sector industries, government, public and private
organizations) volunteer to join one or more of the ENERGY STAR programs and pledge to either
make or use energy efficient products. It is hoped that the cost savings realized by the use of
energy efficient products will encourage more companies and other organizations to join the
program, and therefore prompt more manufacturers to produce these types of products in larger
volume and at lower prices.
Each of the programs will be discussed briefly below with more emphasis on the ENERGY STAR
Labeling Program.
Recent Developments
The ENERGY STAR Labeling program is in the process of expanding to include televisions, video
cassette recorders (VCRs), and windows. EPA has decided to label consumer electronics because,
according to the US Energy Information Administration, consumer electronics and small electrical
appliances are expected to account for about 90 percent of the projected increase in carbon dioxide
emissions from residential and commercial buildings over the next 20 years. Manufacturers are
now signing agreements to label Televisions and VCRs, and it is expected that these labeled
products will be on the market in early 1998. The DOE has chosen to label windows, which in
many homes are a significant factor in heating and cooling losses and therefore energy
consumption.
Program Summaries
ENERGY STAR Labeling Program
As mentioned above, the ENERGY STAR Labeling program is funded and managed jointly by the
US EPA and the US Department of Energy (DOE). The program was created to provide customers
with an easy way to recognize energy efficient products by labeling these products with the
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ENERGY STAR logo. Manufacturers and retailers participating in the ENERGY STAR Labeling
program sign a Memorandum of Understanding (MOU) with EPA and DOE agreeing to produce,
label, and sell products that meet the product specifications. EPA and DOE establish the criteria,
and the agencies then allow manufacturers and retailers to use the ENERGY STAR logo, a single-
attribute seal of approval, on products and in advertising. As part of this program, EPA is
implementing a nationwide consumer education awareness campaign to educate users about these
products and the label.
Though there are plans to expand the labeling program in 1998, currently there are seven product
categories that are part of the labeling program. These include: office equipment, residential light
fixtures, exit signs, transformers, residential heating and cooling equipment, insulation, and major
household appliances. Some of these will be discussed briefly below.
ENERGY STAR Office Equipment Program:
The Office Equipment program was the first of the ENERGY STAR programs to label products. It
was launched in June 1992, and is designed to promote the development and use of energy-
efficient office equipment. Manufacturers of computers, monitors, printers, fax machines, and
copiers are eligible to join the program if they produce energy-efficient versions of these products.
The basis of this program is that each participating company agrees to introduce computers,
monitors, printers, fax machines, or copiers, that switch to a low power state when left idle. For
example, ENERGY STAR computers drop their power draw to 30 watts or less, a 50 to 75 percent
reduction compared to normal power draw, by automatically turning to a "sleep" mode when not
in use. Similarly, ENERGY STAR monitors power down to 30 watts or less when not in use by
turning to a sleep mode. Printers power down to 15 to 45 watts when not in use. ENERGY STAR
fax machines have a power-management feature that can reduce energy costs by 50 percent. They
also have a sleep mode and double-sided faxing capabilities, thereby cutting down on paper costs.
ENERGY STAR copiers automatically turn off after a period of inactivity.
An independent study by the US DOE Lawrence Berkeley Laboratories estimates that US
businesses could save almost $1 billion per year in energy costs, or $900 million, by the year 2000,
by converting to energy-efficient office equipment.
Almost all major manufacturers of these products have joined the program. Companies that
market qualifying products may use the EPA ENERGY STAR logo to identify those products.
EPA emphasizes that the purpose of the ENERGY STAR logo is to promote energy efficiency
only, and that EPA does not endorse any particular product. For office equipment users, however,
joining the program and buying energy efficient products is voluntary. Executive Order 12873
(which addresses Federal Acquisition, Recycling, and Waste Prevention), however, directs the
various agencies of the federal government, the largest purchaser of office equipment in the world,
to purchase ENERGY STAR computers, monitors, and printers, provided that they are available
commercially and meet performance standards.
B-134 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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ENERGY STAR Residential Light Fixtures Program:
Established in June 1997, the ENERGY STAR Residential Light Fixtures Program is one of the
newest programs under the ENERGY STAR Labeling program. Partners agree to manufacture
energy-efficient lighting fixtures for installation in homes, especially in high-use sockets, such as
in kitchens, living rooms, and outdoor areas. ENERGY STAR lighting fixtures are 'dedicated'
fixtures, which means that they are designed to operate only energy-efficient sockets. These
fixtures start immediately, (i.e. they don't need to warm up), operate quietly, and may also have
dimming or switching features. Outdoor fixtures automatically turn off in daylight and some
fixtures have motion detector on-off features.
ENERGY STAR Exit Signs Program:
In June 1996, EPA launched the ENERGY STAR Exit Signs Program to develop energy-efficient
exit signs. Manufacturers involved in this program produce energy-efficient exit signs that meet
the EPA ENERGY STAR guidelines. Manufacturers can then use the ENERGY STAR logo on
their product. Manufacturers do their own testing to ensure that products meet the guidelines.
ENERGY STAR exit signs operate on less than 5 watts of electricity per face. In addition, they
have been tested by the manufacturer and are found to have levels for visibility and luminance that
exceed those required by the National Fire Protection Agency's Life Safety Code. It is estimated
that by the year 2000, these exit signs could save companies a cumulative 800 million kilowatts of
electricity, an estimated cost savings of $70 million each year.
ENERGY STAR Transformers Program:
This program is a partnership between the EPA and electric utility companies and transformer
manufacturers. The program was established in April 1995. By joining the program, utility
companies agree to buy cost-effective, high-efficiency transformers for their electricity distribution
systems. Manufacturers of transformers also agree to produce ENERGY STAR transformers and
agree to market them to electric utilities. Even though electric transformers are already about 98
percent efficient, it is estimated that ENERGY STAR transformers can easily reduce energy loss
levels by 10 to 40 percent. Additionally, an estimated 3.4 billion kilowatt hours of savings is
projected with the use of ENERGY STAR transformers.
ENERGY STAR Residential Heating and Cooling Program:
In this program, manufacturers agree to produce and market high-efficiency heating and cooling
equipment. The program was established in April 1995. ENERGY STAR-labeled products under
this program include furnaces, air conditioners, geothermal heat pumps, gas-fired heat pumps,
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-135
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thermostats, and boilers. Further, EPA is working with the financial industry to encourage the
development of lower cost commercial loans to purchasers of ENERGY STAR heating and
cooling equipment.
ENERGY STAR Homes Program
The ENERGY STAR Homes Program was established in April 1995. It is a partnership between
EPA and home builders and developers. Builders and developers who join the program agree to
build energy-efficient homes. Guidelines for these homes are detailed in the ENERGY STAR
Homes MOU. Energy efficient lighting systems, heating, ventilation, and air condition systems, as
well as energy efficient insulation, are installed in ENERGY STAR homes.
ENERGY STAR Homes can be advertised as such in real estate listings and with real estate
brokers. Home buyers may also inquire about energy-efficiency upgrades in their existing homes.
It is estimated that home buyers can cumulatively save an estimated $1.80 billion in utility bills by
purchasing ENERGY STAR Homes.
ENERGY STAR Buildings and Green Lights Program
The ENERGY STAR Buildings and Green Lights Program was established in 1991 and is the first
of the ENERGY STAR programs. It is aimed at encouraging the widespread use of energy-
efficient lighting. Partners agree to install energy-efficient lighting "where profitable as long as
lighting quality is maintained or improved." Federal agencies that are partners in the program have
until the year 2005 to complete lighting upgrades in their buildings.
In April 1995, the Green Lights program was expanded in the ENERGY STAR Buildings Program
aimed at maximizing energy efficiency building-wide. In order to become a partner, commercial
building owners agree to upgrade their building to become more energy efficient. Partners are
encouraged to follow a five-step upgrade procedure: 1) installing energy efficient lighting; 2)
completing a general building tune-up; 3) performing load reductions; 4) undertaking fan system
upgrades; and 5) upgrading heating plant and cooling systems. The MOU in this program outlines
in detail each of the requirements under these stages as well as EPA's and the partner's
responsibilities.
Participants in the ENERGY STAR Green Lights and Buildings Program include corporations,
small businesses, universities, health care facilities, non-profit organizations, school districts, and
federal and state governments. Since the beginning of the Green Lights program in 1991,
participation has grown from 39 members to 2,400 in 1997.
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ENERGY STAR Small Business Program
Launched in June 1996, the ENERGY STAR Small Business Program is a partnership between
EPA and small businesses. The program provides technical assistance and information to its
partners in order for them to find ways to earn energy-efficient simple pay backs of three years or
less. Small businesses or non-profit organizations can join the program if they have facilities of
100,000 square feet or less, and if they agree to upgrade these facilities to make them energy-
efficient. Additionally, partners agree to purchase ENERGY STAR-labeled products. EPA will
provide partners with workshops, seminars, a hotline, and a Web site on available energy-efficient
upgrades, as well as publicize success stories. It is estimated that typical small business can save
from 30 to 50 percent of their energy bills by conducting energy efficiency upgrades. As of August
1997, 100 small businesses had joined the program.
Program Methodology
As mentioned above, all of the ENERGY STAR programs aim at reducing air pollution through
the use or production of energy-efficient products. Product categories are therefore evaluated
according to their environmental impacts in terms of their energy use. Similarly, businesses are
assessed according to their energy-efficient building management.
The ENERGY STAR program reports that when choosing product categories and establishing
product standards for the ENERGY STAR Labeling program, previous literature about the product
category, independent testing and auditing, and information provided by participating producers are
used. Additionally, the program conducts generic/modeled environmental impact assessments
when choosing product categories.
References
Betsy Agle, ENERGY STAR Labeling Programs, US Environmental Protection Agency. Personal
communication with Abt Associates, October, 1997.
Jeff Ryan, ENERGY STAR Programs, US Environmental Protection Agency. Personal
communication with Abt Associates, November, 1997.
United States Environmental Protection Agency, ENERGY STAR Homepage,
http://www.epa.gov/energystar.html
US Department of Energy, ENERGY STAR Homepage, http://www.energystar.gov.
Business and the Environment (BATE), US "ENERGYSTAR" Program Continues to Expand,
August 1997.
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-137
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Business and the Environment (BATE), US "ENERGYSTAR" Program to Include TVs and VCRs,
June 1997.
Lawrence Berkeley Laboratories, US EPA ENERGY STAR Program,
http://eande.lbl. gov/EP A/EUF/oeexesum. html.
Product Categories
ENERGY STAR Labeling Program
Computers
Monitors
Fax Machines
Photocopiers
Printers
Exit Signs
Residential Light Fixtures
Furnaces
Air conditioners
Geothermal heat pumps
Gas-fired heat pumps
Thermostats
Boilers
Transformers
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FUEL ECONOMY INFORMATION PROGRAM
In 1975, Congress passed the Energy Policy and Conservation Act (EPCA), which established
Corporate Average Fuel Efficiency (CAFE) standards as well as a testing, labeling, and
information program to assist consumers in purchasing new cars. One aspect of the information
program was the Gas Mileage Guide, a publication listing the fuel economy of cars manufactured
at a given time. Car dealers were required to have the Guide available for customers.
The law also required a label to appear in the windows of new cars that lists the miles-per-gallon
(MPG) of the car for city and highway driving, the estimated annual fuel cost associated with its
operation, and the fuel economy of comparably-sized models. Such labeling began in 1974 with a
voluntary program administered by the EPA and the Federal Energy Administration (FEA), a
precursor of the Department of Energy. The EPCA made the program mandatory as of March
1976. Although EPA is responsible for testing cars and preparing the Gas Mileage Guide and the
MPG labels, responsibility for other aspects of the fuel economy program is shared with three other
federal agencies: Department of Energy, Department of Transportation, and the Federal Trade
Commission.
The labeling program had a number of problems initially with the measurement of vehicle mileage.
A Congressional Committee hearing noted, "As the public quickly discerned, the EPA mileage
figures were not an accurate measure of on-road performance" (US House, 1980). According to
Elder Bontekoe of EPA's Office of Mobile Sources, the tests were not run according to "real
world" conditions and considerably overestimated the actual mileage automobiles could be
expected to achieve. In response, in 1985 a formula was worked out to adjust the mileage for
actual city and highway driving conditions. This new system has been found to be fairly reliable
(Bontekoe, 1993).
A few changes have been made to the format of the label since the program's inception. Initially
showing both highway and city ratings for MPG, 1979 EPA regulations removed the higher (and
less accurate) highway rating, and changed the wording to "Estimated MPG." Car makers were
still allowed to use both ratings in advertising, so there was a concern that consumers were "being
misled by nightly television advertisements and auto showroom displays featuring extravagant
gasoline mileage claims based on their government's own testing program" (US House, 1980).
After changes were made in 1985 to improve the accuracy of the tests, labels again bear estimated
MPG ratings for city and highway use.
A study performed in 1976 found that 72 percent of new car buyers were aware of the Fuel
Economy Information Program and more than half had seen the mileage label on the car they
bought (while only 7 percent were aware of the Gas Mileage Guide). Also, buyers who were
aware of the label bought cars with higher mileage than did unaware buyers, with the mileage of
their new car more than 20 percent higher than their old vehicle. Unaware buyers achieved almost
no increase in mileage. On the other hand, 64 percent of buyers did not believe the MPG estimates
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-139
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(Abt, 1976). Two important considerations for interpreting this study are that the OPEC oil
embargo, in the winter of 1973-74, was fresh in car buyers' minds at that time, and that the program
was still quite new.
The effectiveness of the EPA gas mileage labeling program is largely dependent on public opinions
toward gasoline use and conservation. Due to the low price of gasoline in recent years, mileage
has become a less important consideration for many car buyers. "We perceive that the numbers are
well accepted and the program has a fair degree of recognition in the marketplace," said Mr.
Bontekoe. "A lot of people don't care, but they do seem to be paying attention."
References
Abt Associates, 1976. Impact of the FEA/EPA Fuel Economy Information Program, prepared for
the Federal Energy Administration by Vince Scardino, James Birch, and Kathy Vitale, June.
Bontekoe, Elder. US EPA, Office of Mobile Sources. Personal communication with Abt
Associates, April 1, 1993.
Tyree, C.D. US EPA Certification Policy and Support Branch, 1982. History and Description of
the EPA (Environmental Protection Agency) Motor Vehicle Fuel Economy Program, NTIS# PB
84-212091, EPA# AA-CPSB-82-02.
US House of Representatives, Committee on Government Operations, 1980. Automotive Fuel
Economy: EPA's Performance, May 13, report no. 96-948.
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PESTICIDE LABELING UNDER THE FEDERAL INSECTICIDE, FUNGICIDE, AND
RODENTICIDE ACT
Introduction
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), first enacted in 1947 and
subsequently amended, requires the registration of pesticides and pesticide producers with the US
Environmental Protection Agency. Pesticides, as defined by FIFRA, are substances designed to
prevent, destroy, repel, or mitigate any pests, or to regulate, defoliate, or desiccate plants.
Each of the 600-odd pesticide active ingredients in use today must pass a set of health and safety
standards in order to be approved for registration, or in the case of chemicals registered before
1984, a re-registration. (Tweedy et al., 1991). As part of registration or reregi strati on, the labeling
of each product is reviewed and approved by the Agency.
Program Summary
Under EPA's Consumer Labeling Initiative (CLI), EPA and several stakeholders are evaluating the
need for improvements to FIFRA labels for pesticides and household cleaners. See the write-up on
CLI in this section for details.
FIFRA requires labels to appear on the containers of every pesticide product sold in the US, and
imposes standards and restrictions regarding the wording and format (40 CFR §156.10). As
outlined in the Code of Federal Regulations (CFR), a pesticide label must clearly and prominently
display the following information:
a) The name, brand, or trademark under which the product is sold;
b) The name and address of the producer, registrant, or person for whom produced;
c) The net contents (weight or measure);
d) The product registration number;
e) The producing establishment number;
f) An ingredient statement;
g) Warnings and precautionary statements;
h) The directions for use; and
i) The use classification(s) (restricted use).
All required label text must be set in 6-point type or larger, and must appear in English. The
Agency, however, may require additional text in other languages if it is considered necessary in
protecting the public health.
The Office of Pesticide Programs (OPP) at EPA reviews each pesticide label individually to ensure
appropriateness and accuracy. (Frane, 1993) The particular environmental or health effects of a
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-141
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pesticide may prompt EPA to require additional warnings or messages to be included on its label
(e.g., groundwater advisory statements, chronic hazard warnings).
The various components of the label are discussed in more detail below. Label requirements as
described below are taken from the 40 CFR §156.10. The regulations set only broad guidance on
label content. In practice, the Agency has wide latitude to require, or accept, statements that
deviate from the regulations, and many statements that are accepted reflect variations based on
product type and use.
A. Name, brand, or trademark: The name that appears on the label must be registered with the
EPA, and not be false or misleading.
B. Name and address of the producer, registrant, or person for whom produced: If the
registrant's name that appears on the label is not the producer of the pesticide, it must be
qualified by appropriate wording such as "Packedfor ***" "Distributedby ***" etc.
C. Net contents (weight or measure): The net weight or measure, exclusive of wrapping
materials, must be stated as an average content unless explicitly stated as a minimum
quantity.
D. Product registration number: The EPA registration number (often abbreviated to "EPA Reg.
No.") assigned to the pesticide product at the time of registration must appear on the label.
E. Producing establishment number: The producing establishment number, preceded by the
phrase "EPA Est," must appear on the label or on the immediate container.
F. Ingredients statement: The ingredients statement is normally required on the front panel of
the label. If there is an outside container or wrapper through which the label cannot be
read, then the ingredient statement must also appear on that container or wrapper.
The label of each pesticide product must bear a statement that contains the name and percentage by
weight of each active ingredient, and the total percentage by weight of all inert ingredients. Each
ingredient may be referred to by its accepted common name, if there is one. If no common name
has been established, then the chemical name must be used. Trademarked names not accepted as
common names are not allowed.
Pesticide products that contain one or more chemical components that change significantly over
time must also include a statement that reads: "Notfor sale after [date]."
G. Warning and precautionary statements:
Required warning and precautionary statements regarding toxicological hazards to humans fall into
B-142 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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two groups: those required on the front panel and those that may appear elsewhere. The child
hazard warning and the appropriate human hazard signal word (see below) must appear on the
front panel of a pesticide label. The human hazard signal word also appears elsewhere on the
label. Other warnings and messages, including the first aid or statements of practical treatment
(except in cases of extremely toxic products), health and environmental precautionary statements,
and physical and chemical hazard statements, may appear elsewhere on the label.
1. Child hazard warning
Except for those products deemed safe for use on children or infants, or where the possibility of
contact with children is exceedingly small, all pesticide product labels must bear on the front panel
the warning "Keep Out of Reach of Children."
2. Toxicity Categories
The text required on the front panel of the label is determined by the Toxicity Category of the
pesticide product. A pesticide is assigned a Toxicity Category based on its highest hazard potential
in any of the following indicators listed in Table 1:
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Table 1 : Toxicity Category Definition
Hazard
Indicators
Oral LD50
Inhalation LC50
Dermal LD50
Eye Effects
Skin Effects
Toxicity Categories
I
up to and including
50 mg/kg
up to and including
0.05 mg/liter
up to and including
200 mg/kg
Corrosive
(irreversible
destruction of
ocular tissue) or
corneal
involvement or
irritation persisting
for more than 2 1
days
Corrosive (tissue
destruction into the
dermis and/or
scarring)
n
from 50 thru 500
mg/kg
from 0.05 thru 2
mg/liter
from 200 thru 2000
mg/kg
Comeal
involvement or
irritation clearing in
8-21 days
Severe irritation at
72 hours (severe
erythema or edema)
m
from 500 thru 5000
mg/kg
from .5 thru 2
mg/liter
from 2000 thru
20,000 mg/kg
Corneal
involvement or
irritation clearing in
7 days or less
Moderate irritation
at 72 hours
(moderate
erythema)
IV
greater than 5000
mg/kg
greater than 2
mg/liter
greater than 5, 000
mg/kg
Minimal effects
clearing in less than
24 hours
Mild or slight
irritation (no
irritation or slight
erythema)
NOTES: LD50 is the lethal dose at which 50 percent of the animals in lab testing die. LD50 is measured in mg
pesticide per kg bodyweight. LC50 is the lethal concentration at which 50 percent of the animals in lab testing
die. LC^0 is measured in mg pesticide per liter of air.
SOURCE: Consumer's Research, July 1992; 40 CFR §156.10
3. Human Hazard Signal Words
Pesticide labels must bear specific signal words, depending on the pesticide's assigned Toxicity
Category.
A pesticide that meets the criteria of Toxicity Category I must bear the signal word "Danger" on
the front panel of its label. In addition, if the product was assigned to Toxicity Category I based on
its oral, inhalation, or dermal toxicity, the label must also bear the word "Poison " in red on a
background of distinctly contrasting color and the skull and crossbones symbol must appear in
close proximity to the word "Poison. "
A pesticide meeting the criteria of Toxicity Category II must bear the signal word "Warning" on
the front panel of its label.
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A pesticide meeting the criteria of Toxicity Category III or IV must bear the signal word
"Caution" on the front panel of its label.
4. First Aid (Statements of Practical Treatment)
For pesticides in Toxicity Category I, a first aid statement (or statement of practical treatment) is
normally required on the front panel, although in practice reasonable variations are permitted by
EPA. For other pesticides, first aid statements are not required on the front panel, but must appear
elsewhere on the label.
5. Other Required Warnings and Precautionary Statements
Other appropriate warnings and precautionary statements must appear on the label under the
general heading of "Precautionary Statements," and under the subheadings of "Hazard to Humans
and Domestic Animals," "Environmental Hazard," and "Physical or Chemical Hazard."
Typical precautionary statements indicating hazard to humans and domestic animals are listed in
Tables 2 through 8 below, and are arranged by Toxicity Category. Other statements are also used -
- there is considerable variability in hazard statements.
If a pesticide is found to be potentially hazardous to non-target organisms (excluding humans and
domestic animals), the text on its label must include precautionary statements describing the nature
of the hazards and the appropriate precautions to avoid problems. For example, for a pesticide
intended for outdoor use, which contains an agent with an acute oral LD50 of 100 or less, the label
must read, "This Pesticide is Toxic to Wildlife. " Other statements address toxicity to birds, fish,
and aquatic organisms.
Finally, for chemical or physical hazards, the required precautionary statements are listed below in
Table 9.
H. Directions for use
All pesticide labels must have printed on them detailed use instructions or references to
accompanying instruction leaflets.
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Table 2: Hazard to Humans and Domestic Animal Precautionary Statements
Toxicity
Category
I
II
III
IV
Precautionary statement by Toxicity Category
Oral, inhalation, or dermal toxicity
Fatal (poisonous) if swallowed [inhaled or
absorbed through skin]. Do not breathe [vapor,
dust or spray mist]. Do not get in eyes, on skin,
or on clothing [Front panel statement of practical
treatment required].
May be fatal if swallowed [inhaled or absorbed
thru the skin]. Do not breathe vapor [dust or
spray mist]. Do not get in eyes, on skin, or on
clothing [Appropriate first aid statements
required.]
Harmful if swallowed [inhaled or absorbed thru
the skin]. Avoid breathing vapor [dust or spray
mist]. Avoid contact with skin [eyes or
clothing]. [Appropriate first aid statements
required.]
[No precautionary statements required.]
Skin and eye local effects
Corrosive, causes eye and skin damage [or skin
irritation]. Do not get in eyes, or skin, or on
clothing. Wear goggles or face shield and
rubber gloves when handling. Harmful or fatal
if swallowed. [Appropriate first aid statement
required.]
Causes eye [and skin] irritation. Do not get in
eyes, on skin, or on clothing. Harmful if
swallowed. [Appropriate first aid statement
required.]
Avoid contact with skin, eyes, or clothing. In
case of contact immediately flush eyes or skin
with plenty of water. Get medical attention if
irritation persists.
[No precautionary statements required.]
SOURCE: 40 CFR §156.10.
Table 3 : Acute Oral Toxicity Study*
Toxicity
Category
I
II
IE
IV
Signal Word
DANGER
Skull & Crossbones required
WARNING
CAUTION
CAUTION
Precautionary Statements and Personal Protective Equipment
Fatal if swallowed. Wash thoroughly with soap and water after
handling and before eating, drinking, or using tobacco.
May be fatal if swallowed. Wash thoroughly with soap and water after
handling and before eating, drinking or using tobacco.
Harmful if swallowed. Wash thoroughly with soap and water after
handling.
No statements are required. However, if the registrant chooses to use
category III labeling that is acceptable.
"Products Containing 4% or more of methanol: Add the following to the precautionary statements: "Methanol may cause
blindness."
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Table 4: Acute Dermal Toxicity Study
Toxicity
Category
I
II
m
IV
Signal Word
DANGER
Skull & Crossbones required
WARNING
CAUTION
CAUTION
Precautionary Statements and Personal Protective Equipment
Fatal if absorbed through skin. Do not get in eyes, on skin, or on clothing.
Wear protective clothing and gloves (specify- protective clothing and type of
gloves). Wash thoroughly with soap and water after handling and before eating,
drinking, or using tobacco. Remove contaminated clothing and wash before
reuse.
May be fatal if absorbed through skin. Do not get in eyes, on skin, or on
clothing. Wear protective clothing and gloves (specify protective clothing and
type of gloves). Wash thoroughly with soap and water after handling and before
eating, drinking or using tobacco. Remove contaminated clothing and wash
clothing before reuse.
Harmful if absorbed through skin. Avoid contact with skin, eyes or clothing.
Wash thoroughly with soap and water after handling.
No statements are required. However, if the registrant chooses to use category
III labeling that is acceptable.
Table 5: Acute Inhalation Toxicity Study
Toxicity
Category
I
II
m
IV
Signal Word
DANGER
Skull & Crossbones required
WARNING
CAUTION
CAUTION
Precautionary Statements and Personal Protective Equipment
Fatal if inhaled. Do not breathe (dust, vapor, or spray mist).* [Identify specific
respiratory protective device approved by the Mine Safety and Health
Administration and the National Institute for Occupational Safety and Health.]™
Remove contaminated clothing and wash clothing before reuse.
May be fatal if inhaled. Do not breathe (dust, vapor or spray mist).* Wear a
mask or pesticide respirator jointly approved by the Mine Safely and Health
Administration and the National Institute for Occupational Safety and Health.
Remove contaminated clothing and wash clothing before reuse.
Harmful if inhaled. Avoid breathing (dust, vapor or spray mist).* Remove
contaminated clothing and wash clothing before reuse.
No statements are required. However, if the registrant chooses to use category
III labeling that is acceptable.
* Choose the word which appropriately describes the product during use.
** Refer to Section to determine the specific respiratory protective device. This section can be used for both WPS and Non-
WPS products.
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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Table 6: Primary Eye Irritation Study
Toxicity
Category
I
n
m
IV
Signal Word
DANGER
WARNING
CAUTION
CAUTION
Precautionary Statements and Personal Protective Equipment
Corrosive.* Causes irreversible eye damage. Do not get in eyes or on clothing. Wear protective
eyewear (goggles, face shield, or safety glasses)." Wash thoroughly with soap and water after
handling. Remove contaminated clothing and wash clothing before reuse.
Causes substantial but temporary eye injury. Do not get in eyes or on clothing. Wear protective
eyewear (goggles, face shield, or safety glasses)." Wash thoroughly with soap and water after
handling. Remove contaminated clothing and wash clothing before reuse.
Causes moderate eye irritation. Avoid contact with eyes or clothing. Wash thoroughly with soap
and water after handling.
No statements are required. However, if the registrant chooses to use category III labeling that is
acceptable.
The term "corrosive" is not required if only eye irritation (redness) was observed during the study and was still present at day
21.
"Use the term " safety glasses" in the precautionary labeling for residential use products.
Table 7: Primary Skin Irritation Study
Toxicity
Category
I
II
m
IV
Signal Word
DANGER
WARNING
CAUTION
CAUTION
Precautionary Statements and Personal Protective Equipment
Coirosive. Causes skin burns. Do not get in eyes or on clothing. Wear protective clothing and
gloves (specify protective clothing and type of gloves)*. Wash thoroughly with soap and water
after handling. Remove contaminated clothing and wash clothing before reuse.
Causes skin irritation. Do nol get on skin or on clothing. Wash thoroughly with soap and water
after handling. Remove contaminated clothing and wash clothing before reuse.
Avoid contact with skin or clothing. Wash thoroughly with soap and water after handling.
No statements are required. However, if the registrant chooses to use category III labeling that is
acceptable.
"The need for rubber (homeowner products) or chemical-resistant gloves must be determined on an individual basis. Some
products cause blistering if confined under clothing.
Table 8: Dermal Sensitization Study
Study Results
Product is a sensitizer or is
positive for sensitization.
Product is not a sensitive or is
negative for sensitization.
Precautionary Statement
Prolonged or frequently repeated skin contact may cause allergic reactions in some
individuals.
No labeling is required for this hazard.
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Table 9: Physical or Chemical Hazard Precautionary Statements
Flash Point
Required Text
(A) PRESSURIZED CONTAINERS
Flash point at or below 20 °F, if there is a flashback at any
valve opening.
Flash point above 20 °F and not over 80 °F or if the flame
extension is more than 18 in long at a distance of 6 in from
the flame.
All other pressurized containers.
Extremely flammable. Contents under pressure. Keep away
from fire, sparks, and heated surfaces. Do not puncture or
incinerate container. Exposure to temperatures above 130°F
may cause bursting.
Flammable. Contents under pressure. Keep away from heat,
sparks, and open flame. Do not puncture or incinerate
container. Exposure to temperatures above 130°F may cause
bursting.
Contents under pressure. Do not use or store near heat or
open flame. Do not puncture or incinerate container.
Exposure to temperatures above 130°F may cause bursting.
(B) NON-PRESSURIZED CONTAINERS
At or below 20 °F
Above 20 °F and not over 80 °F
Above 80 °F and not over 150°F
Extremely flammable. Keep away from fire, sparks, and
heated surfaces.
Flammable. Keep away from heat and open flame.
Combustible. Do not use or store near heat or open flame.
SOURCE: 40 CFR §156. 10
The directions must appear under the heading "Directions for use, " and include the following:
a) the statement of use classification (see section I, below);
b) the statement, "It is a violation of Federal law to use this product in a manner inconsistent
with its labeling;"
c) the sites of application (e.g., crops, lawns, etc.), or objects to be treated;
d) the target pests;
e) the dosage rate;
f) the method of application;
g) the proper frequency and timing of application;
h) the reentry statement (if needed), which specifies the length of time that must pass before
people can reenter a treated area;
i) the disposal directions; and
j) any use limitations or restrictions required to prevent unreasonable adverse effects.
I. Use classification
Every registered pesticide has one or more EPA-designated uses. Each of these uses is evaluated
for hazard potential and may be classified for restricted use if necessary to protect human health or
the environment.
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1 General Use Pesticides
Unclassified products, with one exception, do not bear the term "General Use" as discussed in 40
CFR 15.160. The one exception involves products containing the active ingredient, chlorine gas.
These products are the only products which bear the classification "General Use."
2. Restricted Use Classification
Products designated for restricted use only must include the words "Restricted Use Pesticide " on
the front panels of their labels. A statement describing the nature of the restrictions and the reason
for the restriction must appear directly below the above statement. For example, "Due to
oncogenicity," "For retail sale and use only by Certified Applicators or persons under their direct
supervision and only for those uses covered by the Certified Applicator's certification." For each
specific pesticide, other additional restriction statements may be required by EPA.
Enforcement
According to FIFRA Sec. 2(q) and 12 (Federal Environmental Laws, 1988), failure on the part of
the pesticide producer or registrant to comply with labeling requirements may be considered
"misbranding" of the pesticide. Sales or distribution of a misbranded pesticide constitutes an
unlawful act. The Environmental Protection Agency may then cancel the registration, or bring
criminal and/or civil charges against the registrant or producer of the pesticide.
References
Code of Federal Regulations, 40: PARTS 150 to 189. Revised as of July 1, 1992.
Committee on Scientific and Regulatory Issues Underlying Pesticide Use Patterns and Agricultural
Innovation, Board on Agriculture, and the National Research Council (US), 1987. Regulating
Pesticides in Food: The Delaney Paradox. National Academy Press, Washington D.C.
Consumers' Research, 1992. How to Read Pesticide Labels, July, pp 34-36.
Federal Environmental Laws, 1988 Edition, 1988. West Publishing Co., St. Paul, MN.
Frane, Jean, US EPA, OPP, 1993. Personal Communication with Abt Associates.
Hurst, Peter, Alastair Hay, and Nigel Dudley, 1991. The Pesticide Handbook, Journeyman Press,
London, Concord, MA.
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Tweedy, E.G. et al. eds., 1991. Pesticide Residues and Food Safety: A Harvest of Viewpoints,
American Chemical Society, Washington D.C. pp 324-332.
US EPA, undated. Simazine Re-registration Guidance Document.
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GREEN SEAL
Introduction
Green Seal is an independent, non-profit organization involved in environmental standard setting,
product labeling, and public education in the United States. Established in 1989, Green Seal issues
a third party, seal-of-approval to consumer products that "cause less harm to the environment than
other similar products" (Green Seal, 1997). The Green Seal is available to both US and foreign
companies. In addition, Green Seal also encourages companies and other large buyers to become
members of Green Seal's "Environmental Partners Program" to develop environmentally sound
procurement policies, and to pledge to buy environmentally preferable products.
As of August 1997, product standards or criteria had been developed for 88 product categories.
Fifteen of these are currently undergoing final revisions after the public comment period that is part
of Green Seal's standards/criteria finalization process. To date, approximately 300 products have
been awarded the Green Seal. As of August 1997, Green Seal has certified products from several
foreign manufacturers including three Canadian companies (producing newsprint paper, sanitary
equipment, and engine oil), one Japanese company (producing a heat pump,) and one Korean
company (producing a bleach product).
Recent Developments
In 1993 Green Seal started distinguishing between two types of award criteria. These award
criteria are known as "product standards" or "product criteria," depending upon the product
category. Product standards are award criteria for products that require more in-depth
environmental impact or life cycle analysis. Standards are established for products that Green Seal
considered to have greater environmental impacts and are, therefore, tested and assessed more
comprehensively. In contrast, product criteria were established as a response to market interest
(i.e., for product categories that manufacturers were interested in getting eco-certified). Product
criteria are developed as a way to quickly certify product categories that are less complex or that
are experiencing technological changes. Over time, however, the distinction between product
standards and product criteria has become less significant for Green Seal.
Program Summary
Green Seal standards and criteria are developed on a category-by-category basis. Anyone,
including industry, public interest groups, and the general public, may submit proposals for new
product categories. Green Seal, however, makes the final decision as to which categories are
chosen. Product categories are assessed based on a life cycle analysis. Once product categories are
chosen, product standards and criteria are developed. Draft standards and criteria are sent for
comment to relevant parties, such as manufacturers, trade associations, environmental and
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consumer groups, and government officials, as well as to any member of the public who requests
them. The comment period lasts for about 45 to 60 days.
Once the public comment period is completed, staff of the Green Seal Board of Directors finalizes
the product standards and criteria and forwards them to the Environmental Standards Committee.
The Environmental Standards Committee acts on behalf of Green Seal's Board of Directors in
approving the final standards. Product criteria do not need the Board's approval and are sent
directly for publication. Product standards and criteria are usually revised every three years to keep
up with technological advances in product categories and to encourage continual environmental
improvement.
Once the standards and criteria are published, manufacturers are encouraged to apply for the Green
Seal. As part of the certifications process, manufacturers must demonstrate that they are in
compliance with all applicable federal, state, and local environmental regulations. Manufacturers
pay a product evaluation fee and a monitoring fee, which is based on a fixed price plus the
additional estimated cost of laboratory tests and travel to the manufacturers' facilities. If the
product meets Green Seal's standards/criteria, the manufacturer is given a contract to use the Green
Seal label on its product(s), packaging, and in advertising, for as long as the product stays in
compliance with the standards. Green Seal re-evaluates its product standards every three years.
Program Methodology
Green Seal's acceptance of a product category for its label is based on a life-cycle assessment of
several products on the market. Green Seal makes assessments based on the environmental
impacts during various stages of the products' life cycle. These include: raw material extraction,
manufacturing, transportation and distribution, product use, and disposal. Additionally, products
are assessed on their potential for reuse, their maintenance needs, potential for recycling,
ingredients, and environmental performance during the production process. Green Seal's goals are
to set standards and criteria that reduce one or more of the following: toxic chemical pollution,
energy consumption, impacts on water resources, impacts on wildlife, natural resource
consumption, impacts on the atmosphere, and global warming. Products within a category must
also comply with minimum performance standards, i.e, they must perform at least as well as other
products in their category which are considered less environmentally preferable.
In setting product standards, Green Seal collects information about the product category from
previous literature and studies done on the product category, as well as from its own independent
testing and studies. Additionally, Green Seal collects data from manufacturers and previous life-
cycle assessments conducted by other ecolabeling programs. For example, Green Seal exchanged
information with Canada's TerraChoice program and adopted several of its product standards.
Green Seal's standard-setting procedure is a transparent one. The public is given the opportunity
to provide comments on the draft standards. The commentors' suggestions are often based on the
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feasibility of meeting the proposed environmental standards, given the available technologies for
the category. Once standards are finalized by the Environmental Standards Committee,
commentators may appeal the standards if they feel that their comments were not addressed
adequately. This is done through a body known as the Environmental Standards Council, made up
of technical experts and academic scientists. Once appeals are taken into consideration, Green Seal
publishes the final standards along with a document that lists all significant comments and Green
Seal's responses.
Other Information
In addition to the labeling program, Green Seal has also established the "Environmental Partners
Program." There are two aspects to the program. Environmental Partners (businesses, government
agencies, and other organizations,) may join the program by agreeing to the Environmental
Partners Pledge, thereby committing to buying environmentally preferable products and services as
part of their procurement policies. Additionally, pledged Partners have to establish a recycling
program in their offices. Alternatively, business, organizations, and government agencies may opt
to subscribe to the program and simply receive information materials from Green Seal about
environmentally preferable products. Green Seal provides all its Partners with monthly Choose
Green Reports, which recommend specific environmentally preferable brands of products, and lists
places these products can be purchased. As of August 1997, there are 461 organizations taking
part in the program; 163 of these organizations have made the Environmental Partners Pledge.
Partner organizations include federal, state, and local government agencies, private companies, and
universities and colleges.
In addition to the Choose Green Reports, Green Seal has published the Office Green Buying Guide
and Greening Your Property. The Office Green Buying Guide provides guidelines for businesses
to set up environmentally preferable purchasing policies. Specifically, the Office Green Buying
Guide provides information on types of products offices can consider buying. For example, the
Guide encourages businesses to reassess the type of paper products they buy (e.g., buying papers
made with recycled materials and fibers other than wood-pulp), or it may encourage purchasing
energy-efficiency office equipment (e.g., Energy Star-labeled photocopiers, computers, and fax
machines). In Greening Your Property, Green Seal provides similar guidance, specifically for the
lodging (hotels and motels) industry, on developing their environmentally preferable purchasing
policies and ways to engage in the notion of eco-tourism. The guide aims to educate the industry
on ways to cost-effectively better their hotels' and motels' environments. In addition to Greening
Your Property, Green Seal regularly contributes to the lodging industry's monthly magazine,
Lodging, with articles on specific brands and product names.
Both the Office Green Buying Guide and Greening Your Property provide information on
environmental considerations to keep in mind when purchasing products. Green Seal encourages
businesses to consider the following characteristics of the products before making purchases: the
products' life-cycle costs (e.g., cost of purchase, use, and disposal,) instead of simply the up-front
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costs; durability; performance; energy and natural resources use; recyclability and recycled content;
toxicity; biodegradability; and packaging. Additionally, guidance to businesses on ways to
advertise to their employees, suppliers, and customers about their new environmental policies are
provided.
Green Seal is also actively involved in coordination with other labeling programs. Green Seal and
the Canadian TerraChoice program were the first two ecolabeling programs that urged for the
establishment of the Global Ecolabelling Network (GEN). In fact, Green Seal chaired GEN
during the first three years GEN was established. Green Seal has encouraged information
exchange and harmonizing with other programs through GEN. Additionally, Green Seal
participates in International Organization for Standardization (ISO) activities.
References
Arthur Weissman, President and CEO, Green Seal. Personal Communication with Abt Associates,
1997.
Mark Petruzzi, Director of Certification and Compliance, Green Seal. Personal communication
with Abt Associates, 1997
Green Seal, Green Seal of Approval and List of Standards, Green Seal Homepage,
http ://www.greenseal. org
Green Seal, Rules Governing the Use of the Green Seal Certification Mark, Green Seal Homepage,
http ://www.greenseal. org
Green Seal, Standards and Criteria, Green Seal Homepage, http://www.greenseal.org
Green Seal, About Green Seal, information page.
Green Seal, August 1997, 10 Ways to Save Energy, Green Seal's Choose Green Report.
Green Market, What is Green Seal? http://www.igc.org/GreenMarket/FORUM/gs.html
Green Seal, Green Seal Environmental Partners Program.
American Hotel and Motel Association, July 1997, Lodging: Special Design and Renovation
Section.
Green Seal, Greening Your Property.
Green Seal, Hotel Projects, Green Seal Homepage, http://www.greenseal.org.
B-156 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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Green Seal, 1996, Office Green Buying Guide: A Green Seal Guide.
Green Seal, 1996, Powdered Laundry Bleach, GC-11.
Product Categories (number of awarded products in parentheses)
Final Product Standards
Electric chillers (100 tons to 2,000 tons rated capacity)
Clothes dryers
Clothes washers
Combination ranges
Electric or gas cooktops
Dishwashers
Freezers (30 CF or less)
Ovens
Refrigerators (39 CF or less)
Combination refrigerator-freezers (39 CF or less)
Engine oil
Reusable utility bags
General purpose cleaners
Compact fluorescent lamps
E26 medium screw ballast adaptors
E26 medium screw fluorescent self-ballasted lamps
E26 medium screw lamp holder conversion kits
Interior and exterior architectural coatings
Bathroom tissue
Blanks
Bond paper
Bristol paper
Business forms
Coated printing paper
Copy paper
Cover paper
Drawing paper
Facial tissue
Gift wrapping paper
Labels
Ledger paper
Lightweight printing paper
Manifold and onion skin paper
Newsprint and printed products manufactured from newsprint
Other printing and writing paper
Paper napkins
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Paper towels
Tablet paper
Uncoated groundwood-free paper
Faucet aerators
Kitchen faucet
Lavatory faucet
Toilets
Electric storage heaters (20 to 120 gallons and 12 kW input)
Heat-pump heaters (max current rating of 24 amp. at 250 volts)
Gas storage heaters (20 to 100 gallons and 75,000 Btu/hr max input)
Oil-fired storage heaters (50 gallons or less and 105,000 Btu/hr max input)
Glazed exteriors doors
Skylights
Storm doors
Windows
Retrofittable window films
Final Product Criteria
Residential central air-conditioning systems (cooling capacity of 65,000 Btu/hr or less)
Split ductless air-source heat pumps (cooling capacity of 65,000 Btu/hr or less)
Alternative-fueled vehicles (CNG or electric)
Fleet vehicle maintenance
Powdered laundry bleach
Discrete informational labels for plastic parts
Passive infrared sensors
Ultrasonic sensors
Dual technology sensors
Audio and/or microwave sensors
Anti-corrosive paints
Paper products used in the preparation of food (coffee filters, baking paper and parchment)
Office copiers
Showerheads
Garden hoses
Sprinkler hoses
Product Categories under revision after the public comment period (all of these will be product
standards once finalized)
Adhesives
Gap sealants
Weather proofing sealants
Tub and tile sealants
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Through the wall air-conditioning units
Window air-conditioning units
Ceiling and close to ceiling luminaries
Exterior luminaries with photocell
Outdoor brackets and lanterns
Porch lights
Recessed downlights and wallwashers
Security lights
Task lights
Wall sconces and brackets
Toner cartridges for printing and reproduction equipment
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-159
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ERA'S OZONE DEPLETING SUBSTANCE (ODS) WARNING LABEL
Introduction
Section 611 of Title VI of the Clean Air Act, as amended in 1990, requires "labeling of products
that contain or were manufactured with class I or II [ozone depleting] substances" by May 15,
1993. Class I substances are chlorofluorocarbons (CFCs), halons, carbon tetrachloride, and 1,1,1-
trichloroethane (methyl chloroform), while class II substances are hydrochlorofluoro-carbons
(HCFCs). The text of the label reads: "WARNING: Contains (or "Manufactured with" if
applicable) [insert name of substance], a substance which harms public health and environment by
destroying ozone in the upper atmosphere."
Recent Developments
In an amendment promulgated on January 19, 1995, EPA added several exemptions in response to
comments that the former rule placed burdens "on specific parties whose activities contribute no
additional emissions of ozone-depleting substances." Examples include exemptions from the
labeling requirement "when controlled substances are destroyed,... [and] for spare parts that are
used in repair." The amendment also made some minor clarifying revisions on such issues as the
labeling of waste. These changes were intended to "provide additional flexibility to the regulated
community [while] in no way [compromising] the environmental goals and benefits of protecting
public health through the labeling regulation" (60 FR 4010).
Program Summary
In 1977, "the Food and Drug Administration and the Consumer Product Safety Commission
required marketers and importers of self-pressurized medical and consumer products that use a
CFC propellant to label their products with a warning that such products may harm public health
and the environment by reducing ozone in the upper atmosphere."6 Soon afterward, CFC was
banned as an aerosol propellant for all but "essential applications," thus making the FDA/CPSC
warning label irrelevant on such consumer products.
The final rule implementing section 611 was promulgated by EPA on February 11, 1993. The rule
prohibits the sale of "any container containing class I and class II substances, product containing
class I substances and product manufactured with class I substances, unless it bears a warning
statement indicating that the product contains or is manufactured with ozone-depleting
substances." Before January 1, 2015, products containing or manufactured with class II substances
may require labeling should "the Administrator [determine] that safe alternatives are available."
After January 1, 2015, all products containing or manufactured with class I or II substances must
be labeled (58 FR 8136).
See the Federal Register April 29, 1977, 42 FR 22018, and August 24, 1977, 42 FR 42780.
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"Products manufactured with class I substances can be temporarily exempted from the labeling
requirements if EPA determines that there are no substitute products or manufacturing processes
that (a) do not rely on the use of the class I substance, (b) reduce the overall risk to human health
and the environment, and (c) are currently or potentially unavailable. All products must be labeled
by 2015" (Labeling Subcommittee, "Meeting Summary").
"Products manufactured with" class I substances might include electronic parts washed in class I
solvents or packaging, books, or sporting goods that use class I adhesives. A container of class I
substances might be a can of CFC-12 intended for use in degreasing units or refrigeration
equipment. Such refrigeration or degreasing units would then be considered "products containing
class I substances."
Although a symbol featuring a globe within an octagon (a stop sign) was considered in the rule
proposal, the final rule requires only the text of the warning above. EPA believed that "this symbol
would substantially increase consumer understanding and recognition of the required warning and
thus heighten the effectiveness of the label" (57 FR 1992). The agency was also concerned,
however, that the cost of changing product labels "would outweigh the benefits of using the label"
(58 FR 8136).
Section 611 also required that the warning be "clearly legible and conspicuous;" EPA proposed
that it should appear on the "principle display panel," defined as the place on a product or package
"where the consumer is likely to look for product information." After receiving comments on the
proposal, EPA decided that, "In view of the broad diversity of products potentially affected by the
labeling requirements...manufacturers will need some latitude as to where to place the labels" (58
FR 8136). Therefore, the final regulation reverts to the language of the Clean Air Act requiring the
warning to be "clearly legible and conspicuous" wherever it is presented. Other labeling options
such as hang tags, stickers, and supplemental printed materials are also acceptable.
At the time of the Clean Air Act Amendments in 1990, the US was committed to a phaseout of
class I substances by the year 2000 (two years later for methyl chloroform), in accordance with the
1987 Montreal Protocol on Substances that Deplete the Ozone Layer. In a November 1992
meeting in Copenhagen, the phaseout schedule for class I substances was accelerated to January
1996 (two years sooner for halons). Thus, the ODS warning label was in effect for fewer than
three years before the class I phaseout was completed. The 1993 rule states, "The recent decision
of the Protocol Parties to significantly accelerate the phaseout of the listed ozone-depleting
substances reduces the importance of the labeling program.... [When the phaseout was scheduled
for the year 2000], the labeling requirements provided an incentive for manufacturers to move
away from their use of such substances before 2000 in order to avoid any negative marketplace
reaction. With the acceleration of the phaseout,... requiring products to be labeled is unlikely to
significantly add to the manufacturers' incentive to switch to alternative substances." As a result,
EPA streamlined the labeling requirements by rejecting a proposed pass-through requirement
whereby any manufacturer that incorporates a labeled component into its product would be
required to label its product. Instead, EPA defined "manufactured with," such that manufacturers
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must label products only when "the manufacturer of the product itself used an ozone-depleting
substance in manufacturing that product.... The incorporation of that [labeled] product into another,
however, [would] not necessitate a label" (58 FR 8136).
References
"Some 'Nonessential' Products Containing Ozone Depleters to be Banned, EPA Rules." BNA Daily
Environment Report January 9, 1992: A-12.
Labeling Subcommittee of the Stratospheric Ozone Protection Advisory Council. Labeling
Products Containing or Manufactured with Class I or II Substances March 11, 1991.
Meeting Summary. Washington, D.C. March 11, 1991.
Meeting Summary: Second Meeting. Washington, D.C. August 30, 1991.
US EPA. "Protection of Stratospheric Ozone: Notice of Proposed Rulemaking." Federal Register
57 FR 1992, January 16, 1991.
"Protection of Stratospheric Ozone: Notice Listing Ozone-depleting Substances." Federal Register
56 FR 2420, January 22, 1991.
"Protection of Stratospheric Ozone: Temporary Final Rule." Federal Register 56 FR 9518,
March 6, 1991.
"Protection of Stratospheric Ozone: Notice of Proposed Rulemaking." Federal Register 57 FR
19167, May 4, 1992.
"Protection of Stratospheric Ozone: Final Rule." Federal Register 58 FR 4768, January 15, 1993.
"Protection of Stratospheric Ozone; Labeling." Federal Register 58 FR 8136, February 11, 1993.
"Protection of Stratospheric Ozone; Labeling Supplemental Rulemaking." Federal Register 60
FR4010, January 19, 1995.
US EPA: Stratospheric Protection Division. Section 611: Product Labeling, [online: web],
updated October 31, 1995, cited September 18, 1997. URL:
http://www.epa.gov/ozone/title6/labeling/labfact.html
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CALIFORNIA PROPOSITION 65
Introduction
California's Proposition 65, officially known as the Safe Drinking Water and Toxic Enforcement
Act of 1986, is a statute that waplaced on the ballot by citizen petition due to concern over
inadequate governmental public health regulations. The purpose of the law is to enhance
community right-to-know, protect drinking water supplies, and reduce toxic releases. Although the
law was opposed by industry and agriculture groups, as well as almost every major newspaper in
California, Proposition 65 was approved by the California electorate by nearly a two to one margin.
Proposition 65 mandates that the Governor of California publish a list of chemicals that are known
to cause cancer, or been developmental or reproductive toxicity. In addition, warnings must be
provided by businesses that knowingly and intentionally expose individuals to these chemicals,
unless it is determined that the exposure poses no significant risk assuming a exposure at the level
in question for cancer causing chemicals. For chemicals causing reproductive toxicity, businesses
that knowingly and intentionally expose individuals to these chemicals must provide warnings,
unless it is determined that the exposure will have no observable effects assuming an exposure
level 1,000 times the level in question. The warning requirements become effective twelve months
after the date of listing of the chemical. Businesses are required to provide a "clear and
reasonable" warning, which can take the following forms: labeling a consumer product, posting
signs at the workplace/businessplace, or publishing notices in the newspaper. In addition,
discharge of these chemicals into drinking water supplies are prohibited twenty months after the
date of listing of the chemical, except in those cases where the discharger can demonstrate that the
discharge is insignificant. The governor's list currently includes over 580 chemicals, 420
carcinogens, and 160 reproductive toxins. The Act is not applicable to government agencies,
drinking water utilities, and businesses employing fewer than ten persons.
Recent Developments
Following the implementation of the Act, many industries have attempted to avoid or reduce the
requirements. The food, drug, and cosmetic industries lobbied to receive a temporary exemption
from the law on the grounds that they are already regulated by the US Food and Drug
Administration (FDA). In addition, some industry groups tried to avoid having to develop warning
labels by setting up a toll-free telephone number for product information which was ruled
unacceptable by the courts. By contrast, other industries (such as the tobacco industry) have
implemented Proposition 65 warning labels. These labels have added significantly to the scope of
hazard warnings on consumer products in California.
Proposition 65 has had some measure of success in influencing the decisions of manufacturers,
wholesalers, and retailers, and reducing the risks of chemical exposure. While data are not
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currently available on actions taken by the regulated community to remove themselves from the
purview of Proposition 65, there is evidence that manufacturers have reformulated products to
eliminate or reduce exposures to listed chemicals to avoid having to provide warnings.
Proposition 65's effectiveness as a market-based incentive for the reformulation of products has led
to the removal of certain solvents from correction fluids, as well as the removal of lead from
certain ceramic products and from foil wraps on wine bottles. In addition, Proposition 65 has been
cited as the reason for process modifications, chemical substitutions, and the use of pollution
control devices to eliminate or reduce emissions of listed chemicals that would have required
warnings.
Program Summary
California EPA's OEHHA is designated as the lead agency for Proposition 65 implementation.
OEHHA is "directed to implement the Act in a manner that is fair, predictable, and based on a firm
foundation of science." OEHHA compiles the list of carcinogens and reproductive toxins, prepares
dose-response assessments on listed chemicals, promulgates regulations, and provides assistance to
the regulated community in complying with the law. In addition, the Science Advisory Board
(SAB), established by the Governor, reviews chemicals and recommends those to be added to the
list. The state's SAB consists of two independent committees of scientists and health professionals
that serve as the state's qualified experts; the Carcinogen Identification Committee and the
Developmental and Reproductive Toxicant Identification Committee. The authority to enforce
Proposition 65 is vested in the Attorney General, local district attorneys, and certain city attorneys.
Private citizens may also take action to enforce Proposition 65, following certain conditions (see
"Enforcement") (Health and Safety Code, Section 25249.7).
Proposition 65 uses an unusual means of enforcement that allows private citizens to initiate
proceedings against alleged violators and reap monetary benefits from successful actions. Sixty
days after notifying public authorities (i.e., the Attorney General, the appropriate district attorney,
or city attorney) of an alleged violation, any individual or group may sue the offending business if
the authorities are not "diligently prosecuting" the matter. If successful, the individual or group
bringing suit receives 25 percent of the penalty fines, which may amount to a maximum of
$2,500/day for each violation. The plaintiff filing suit must first show that the alleged violator
generated a knowing discharge or exposure. It is then the responsibility of the defendant to prove
that the exposures and discharges were within legal limits.
Examples of warnings that have been issued as a result of Proposition 65 include: labels on cigars,
pipe tobacco, and other tobacco products not covered by the federal cigarette labeling
requirements; point-of-purchase signs warning about risks of alcoholic beverage consumptions
during pregnancy; signs warning about the presence of environmental tobacco smoke; and
newspaper notices about routine or incidental emissions from facilities in the community.
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Program Methodology
OEHHA compiles and publishes the list of chemicals known to the state to cause cancer or
developmental/reproductive toxicity, and updates it at least annually. A chemical is listed:
1) if, in the opinion of the "state's qualified experts," the chemical has been clearly shown to
cause cancer or reproductive toxicity;
2) if an "authoritative" body designated by the "state's qualified experts" has formally
identified the chemical as a carcinogen or a developmental/reproductive toxicant; or
3) if any state and/or federal agency has formally required the chemical to be labeled or
identified as a carcinogen or a developmental/reproductive toxicant.
The "state's qualified experts" have designated the following organizations as authoritative bodies:
the US EPA, the FDA, the International Agency for Research on Cancer, the National Institute for
Occupational Safety and Health (NIOSH), and the National Toxicology Program.
Additionally, there are two business requirements as part of the rule. First, twelve months after a
chemical is listed, businesses must not knowingly and intentionally expose any individual to a
listed chemical without first providing a "clear and reasonable warning," unless the business can
demonstrate that the exposure:
• does not exceed 1/1000 of the "no observable effect level" (NOEL) for reproductive toxins;
• poses "no significant risk" of cancer. "No significant risk" is defined as the level that
results in a cancer risk of less than one excess case of cancer per 100,000 individuals
exposed over a 70-year lifetime for carcinogens. In other words, if you are exposed to the
chemical in question at this level every day for 70 years, your chances of getting cancer will
be no more than 1 case in 100,000 individuals so exposed.
The second business requirement stipulates that twenty months after the chemical is listed,
businesses must not knowingly discharge the chemical into the drinking water supply unless the
discharger can demonstrate that a "significant amount" of the listed chemical has not, did not, or
will not enter any drinking water source and that the discharger complies with all other applicable
laws, regulations, permits, requirements or orders. "Significant amount" refers to any detectable
amount, unless the resulting exposure meets the same criteria for exemptions from the warning
requirement.
References
Becker, Richard A., Using Sound Science and Common Sense to Improve Proposition 65
Implementation.
California EPA, Office of Environmental Health Hazard Assessment (OEHHA), 1996. The
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Implementation of Proposition 65: A Progress Report. September 1996.
California EPA, OEHHA, 1996b. Proposition 65 in Plain English. December 1996.
Safe Drinking Water and Toxic Enforcement Act of 1986, Chapter 6.6. California Health and
Safety Code, Section 25249.5 et. seq.
Kizer, Kenneth W., et al., 1988. "Sound Science in the Implementation of Public Policy: A Case
Report on California's Proposition 65", The Journal of the American Medical Association, August
19, 260 (7): 951-955.
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SCIENTIFIC CERTIFICATION SYSTEMS'
ENVIRONMENTAL CLAIMS CERTIFICATION PROGRAM
Introduction
Scientific Certification Systems's (SCS) Environmental Claims Certification Program was
developed in 1990 to independently verify the "accuracy of environmental claims on products."
Under this program, SCS conducts detailed investigations to determine whether a claim can be
verified. When the program was developed, environmental claims were largely unregulated and it
was difficult for consumers and retailers to know what claims to believe. SCS certifies claims in
the following areas:
• Recycled Fiber
• Biodegradable Product
Certified Organic Ingredients
• No Smog Producing Ingredients (VOCs)
• Water Efficiency
Once a product has been certified by SCS, its packaging may display an "authorized certification
emblem" accompanied by an exact description of the verified claim. SCS emphasizes consumer
education by providing product shelf signs, information printed on the products, and special
educational material prepared by manufacturers and retailers. SCS will certify claims for consumer
products and packaging, as well as for materials used by product manufacturers. To date, more
than 150 manufacturers and retailers are participating in the SCS Environmental Claims
Certification Program, and SCS has evaluated claims for more than 2,000 consumer and business
products. Participants range from small entrepreneurs to Fortune 500 companies. The vast
majority of companies are based in the US
Recent Developments
SCS recently integrated its Environmental Claims Certification Program and its LCA and Certified
Eco-Profile programs. This allows SCS to help companies choose from several environmental
claims to find the best certification for a particular product. A company may choose a full life-
cycle assessment, but also may choose to have a specific claim certified.
Program Summary
Five steps are taken during claims certification. In Step 1, SCS does an initial feasibility
assessment of the manufacturer's product to determine the appropriate certification in one of the
five certification categories. The manufacturer and SCS sign a contract in Step 2. In Step 3, SCS
engineers or scientists verify the manufacturer's claim by evaluating information released by the
manufacturer, reviewing results from independent testing facilities, and performing on-site
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inspections to verify the information. In Step 4, if a product's claims are substantiated, SCS issues
a certificate and authorizes the use of the SCS Certification Emblem to the manufacturer. Ongoing
monitoring takes place in Step 5, during which quarterly reviews are conducted to maintain the
accuracy of data. Fees for certification vary greatly, ranging from $1,500-8,000. Among other
factors, fees depend on the number of sites that have to be visited, the complexity of the production
process, and the ease of obtaining information from the company being studied. SCS charges
companies for quarterly certification updates, but does not charge an annual fee or royalty.
In addition to verification, SCS administers special claims screening programs for retailers and
other purchasing agents. These programs help purchasing agents to ensure that product
environmental claims that manufacturers may be using are credible and comply with all state and
federal green marketing guidelines.
Program Methodology
The categories for claim certification were chosen based on the types of environmental claims that
prevailed in the market. Criteria were developed with information gathered from stakeholders,
outside literature, independent studies, and SCS's scientific advisory board. The criteria were
reviewed by industry and stakeholders. Criteria are readily available on Fact Sheets provided by
SCS.
Other Information
In 1991, SCS announced joint efforts to establish an Environmental Claims Evaluation Program
for The Home Depot, a nationwide retailer. Under this program, SCS is working with The Home
Depot to verify the accuracy and significance of claims made for products that it stocks. In
addition to the Environmental Claims Evaluation Program, many of The Home Depot stores carry
products that have undergone actual certification.
References
Brown, Linda. Senior Associate, Program Development and Communications, Scientific
Certification Systems. Personal communication with Abt Associates. Fall 1997.
Brown, Sydney. Director, Communications, Scientific Certification Systems. Personal
communication with Abt Associates. Fall 1997.
Montgomery Advertiser. "Quality Products Abound at Home Depot." 23 January 1997.
Scientific Certification Systems. [Online: Web]. Cited 26 November 1997. URL:
http ://www. scs 1. com/
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Scientific Certification Systems. Biodegradability: Certification Program for Soaps, Detergents,
and Cleansers. Summer 1997.
Scientific Certification Systems. Certified Claims: Products, Packaging, and Materials Whose
Environmental Claims Have Been Certified by Scientific Certification Systems. July 1997.
Scientific Certification Systems. Certified 'No VOCs': Certification Standards for Paints and
Coatings. Summer 1997.
Scientific Certification Systems. Certified Recycled Content: SCS Environmental Claims
Certification Program. Summer 1997.
Scientific Certification Systems. Environmental Claims Certification Program [Online: Web].
Cited 26 November 1997. URL: http://www.scsl.com/claims.html
Scientific Certification Systems. Water Efficiency: Certifying Low Flow Rates for Showerheads.
Summer 1997.
Weidman, Elaine. Associate Director, LCA and Environmental Claims, Scientific Certification
Systems. Personal communication with Abt Associates. Fall 1997.
Product Categories
Final Categories
Recycled Fiber
Biodegradable Product
Certified Organic Inputs
No Smog Producing Ingredients (VOCs)
Water Efficiency
Categories Under Development
Alternatives to Poison
Poison-free
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SCIENTIFIC CERTIFICATION SYSTEMS'
CERTIFIED ECO-PROFILE LABELING SYSTEM
Introduction
Scientific Certification Systems's (SCS) Certified Eco-Profile Labeling System is a third-party,
neutral declaration of environmental performance of a product. It is designed to help "managers,
design engineers, purchasing agents, retail and industrial customers, and policy makers understand
the environmental performance of products and materials to make better informed decisions" by
conveying the findings of life-cycle assessment (LCA) studies. As part of the Eco-Profile, SCS
performs a cradle-to-grave assessment that covers all relevant impacts for each of a product's life-
cycle stages: raw material extraction, material processing, manufacturing, distribution, use, and
disposal. The results of the assessment are presented quantitatively on the "Certified Eco-Profile,"
which communicates an overall declaration of the environmental performance of a product or
industrial system. The Certified Eco-Profile has both internal and external applications. When
used as a product label, the eco-profile has often been referred to as the environmental equivalent
of a nutritional label. Based on the life-cycle assessment, special claims of achievement may also
be certified. These claims include "Certified Environmental State-of-the-Art," "Certified
Environmental Improvements," and "Certified Environmental Advantages." At the present time,
the results from the Eco-Profile and an accompanying report are used primarily at the industrial
level to communicate environmental performance data and to provide a tool that can be used to
improve manufacturers' processes from an environmental standpoint. SCS is currently engaged in
several assessment projects at both the domestic and international levels. SCS expects that in early
1998, many new products will carry the Eco-Profile on their labels. Several products that are
currently in the marketplace carry an older version of the Eco-Profile (see "Recent
Developments").
Recent Developments
The Certified Eco-Profile Labeling System evolved from SCS's Environmental Report Card,
which was introduced in 1993. The Report Card provided a quantified summary of the resources
used and emissions associated with a product system. The Certified Eco-Profile, in contrast, is
based on a more advanced form of LCA that goes a step further to link the quantified resources and
emissions of a product back to the specific environments where releases occur. Both the Report
Card and the Certified Eco-Profile have consumer and industrial applications (e.g., internal
company communications and industry-to-industry communications), but currently, demand for the
Certified Eco-Profile is primarily at the industrial level. The name was changed because "Eco-
Profile" is more consistent with the methodology. SCS believes that the name "Eco-Profile" is
easier than "Report Card" to translate, and is more compatible with international terminology.
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Program Summary
Through the Certified Eco-Profile Labeling System, SCS assesses an industrial product material.
SCS is engaged in projects in several industries, chosen on the basis of industry interest and
demand. The products and services currently being assessed include: building materials, energy
production systems, textiles and apparel, forest products, steel products, glass, household
appliances, telecommunications equipment, paints, and plastics.
The assessment process consists of several phases. SCS meets with the client to set the parameters
of the study, then conducts primary and secondary research, including collecting information and
data from the manufacturing process, vendors, and suppliers. SCS processes the data, identifying
and quantifying the system resources used and emissions which impact the environment. SCS then
develops a quantitative profile of these impacts.
The results are presented in a detailed report for the client that is accompanied by a "Certified Eco-
Profile Executive Summary and Data Sheet" (ES/DS), and a "Certified Eco-Profile." The report
and ES/DS detail these findings for each unit process in the life-cycle. This includes a detailed
description of the study boundaries, an explanation of the production process, a summary of key
findings as illustrated on the Certified Eco-Profile, details of these findings for each unit process in
the product life cycle, an explanation of any significant environmental achievements, and an
illustration on how the production system studied compares to similar systems. The results
presented on the Certified Eco-Profile summarize the net resources depleted and the effective
emission loadings on the environment under a set of 15-20 core "environmental impact indicators"
that reflect the unique system being studied. The Certified Eco-Profile also indicates when there
are no measured indicator values above internationally recognized thresholds. The Certified Eco-
Profile could be affixed to a retail product or used internally by a company as an environmental
management tool. One of three claims of environmental achievement based on the assessment may
be certified:
Environmental State-of-the-Art: Earned by a product performing in the top 20th percentile in its
product category for all significant environmental indicators.
Environmental Improvements: Earned by products with demonstrated environmental performance
improvements over time.
Environmental Advantages: Indicates key advantages (and trade-offs) when comparing the product
evaluated to another product or material that can perform the same function.
As in all LCA studies, resource consumption and emissions data are collected for each "life-cycle"
stage studied. SCS employs a methodology known as life-cycle stressor-effects assessment
(LCSEA), which goes beyond traditional LCA practice by integrating environmental data in order
to characterize the actual environmental significance of the inventory data. This process was
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selected because SCS felt that it provides a more scientifically accurate and objective measure of
environmental performance. The ES/DS, mentioned above, presents the streamlined life-cycle
stressor-effects assessment inventory data as well as the final LCSEA impact indicator values. It
shows the relative contribution of specific unit operations to the cumulative environmental
indicator values, and shows the relationship between the original inventory values and the final
indicator values. Of SCS's current projects, a portion use LCSEA, but all future projects intended
for a consumer audience will use LCSEA.
SCS describes five features of the Certified Eco-Profile Labeling System as follows:
1. The system is a comprehensive and science-based system. Findings from the life-cycle are
presented in an understandable and usable label format, both in numeric and graphic form.
The findings are listed under global, regional and local environmental indicators that are
relevant to the system studied.
2. The system provides a level playing field for comparative assessment. The LCA
methodology provides a uniform foundation for product assessment, and helps to ensure
that fair comparisons can be made among products.
3. The system records the unique environmental "footprint" of each product. The eco-profiles
of similar products may differ greatly, depending on the source of its natural resources, the
manner in which such resources are extracted, differences in production technologies used,
emissions released, and the relative tolerance of the environment into which these
emissions are released.
4. The system documents current practices and environmental achievements, and gives
companies information that allows them to determine where improvements are most
needed.
5. The system is applicable to all markets and avoids trade barriers because it is a site-specific
declaration of actual environmental performance, and does not have restrictive criteria and
standards that could reflect local and national priorities. It is directly translatable in all
countries and markets.
The typical LCSEA study, including the production of a full life-cycle report, the Executive
Summary and Data Sheet, and the Certified Eco-Profile, costs between $15,000-$50,000. There
are no licensing or annual fees, and maintenance fees are minor.
Program Methodology
SCS performs a life-cycle stressor-effects assessment (LCSEA), which is a form of LCA developed
for use in the evaluation of product's environmental performance evaluation and labeling. It is a
cradle-to-grave assessment that covers all relevant impacts for each of a product's life-cycle stages:
raw material extraction, material processing, manufacturing, distribution, use, and disposal. The
LCSEA methodology has a number of key features. First, it maintains simplified data treatment:
inventory data are not aggregated in order to maintain data characteristics of time and space.
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Second, it incorporates environmental data from the "providing" environments (i.e., the source of
material inputs) and the "receiving" environments; third, recognized threshold levels are used to
determine whether an emission is causing a measurable effect; and finally, it models the
environmental mechanism through defined stressor-effects (i.e., cause and effect) networks that
link specific system inputs, outputs or activities (i.e., the "stressors") to model actual impacts on
the environment. The system presents results from the assessment in two broad categories of
environmental indicators:
1. Net Resources Depleted includes the following indicators: water, wood fiber, fossil fuels,
non-fuel oil and gas, minerals, metals, direct land area, and marine resources.
2. Emission Loadings includes the following indicators: greenhouse gases, acidying
chemicals, ground level ozone, stratospheric ozone-depleting substances, hazardous air
pollutants, noise, eutrophication chemicals, total oxidizable organic carbon, total suspended
solids, hazardous water pollutants, and hazardous waste.
Eco-Profile studies are conducted when individual companies and industry groups come forward
with interest and demand. Information for each study is collected from sources including primary
data from participating companies and suppliers, published and unpublished data from LCA
studies, environmental impact assessment and risk assessment studies, government statistics, and
industry sources. Each project is peer reviewed and opportunities for input and review by key
stakeholders are provided. SCS conducts site-specific impact assessments, recognizing local,
national, and global conditions. The methodology for the Certified Eco-Profile goes beyond the
conventional Life-Cycle Inventory methodology (e.g., such as that put forth by the Society for
Environmental Toxicology and Chemistry (SETAC)) to include data pertaining to actual
environmental effects. Examples of environmental characterization data collected include:
local/regional exposure data; background concentration levels; exceedance of threshold levels by
GIS mapping for acidification and ground level ozone formation; composition and structure of
floral and fauna types; the size of the reserve base for a given resource; and recycling rates for a
given material and the number of times the material is recycled.
Other Information
SCS is involved with the development of ISO 14000 standards for Type III labeling, the category
of labeling that includes the Certified Eco-Profile. SCS is also working to harmonize with
emerging Type III labeling initiatives being conducted outside of the US, believing in the
importance of harmonizing with programs before they are developed. SCS has formed alliances
with institutions in Chile, Finland, Sweden, Japan, and Korea to offer LCA and Certified Eco-
Profile services worldwide. SCS is also collaborating with two Nordic organizations, the Swedish
Environmental Research Institute (IVL) and Soil and Water (the environmental division of Jaakko
Poyry, Finland), to write an LCSEA practitioners' manual for Type III labeling. The first version
(1.2) was released in April 1997, and international stakeholder input is being assembled. The new
version will be released in 1998.
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The Environmental Work Place Analysis is another LCA based program run by SCS. The program
assists companies to incorporate environmental considerations into the overall management
strategies. It was designed to educate employees at all levels about the environmental
consequences of their actions, and to help employees make good environmental decisions at work.
At the same time, it has been used as a tool to document environmental savings and their
corresponding cost savings for corporations. Employees complete a questionnaire about job-
related activities, and SCS calculates the amount of raw materials and energy used and the amount
of pollution and waste generated as a result of these activities. The information is summarized for
each employee on "Employee Eco-Profiles," along with departmental or faculty eco-profiles.
References
Brown, Linda. Senior Associate, Program Development and Communications, Scientific
Certification Systems. Personal communication with Abt Associates. Fall 1997.
Brown, Sydney. Director, Communications, Scientific Certification Systems. Personal
communication with Abt Associates. Fall 1997.
Montgomery Advertiser. "Quality Products Abound at Home Depot." 23 January 1997.
Scientific Certification Systems. [Online: Web]. Cited 26 November 1997. URL:
http ://www. scs 1. com/
Scientific Certification Systems. Certified Eco-Profile; Executive Summary and Data Sheet.
Summer 1997.
Scientific Certification Systems. Environmental Performance of Products. [Online: Web]. Cited
26November 1997. URL: http://www.scsl.com/impact.html
Scientific Certification Systems. Environmental Workplace Analysis. 1996.
Scientific Certification Systems. Life-Cycle Assessment and CertifiedEco-Profile Projects. June
1997.
Scientific Certification Systems. Life-Cycle Assessment Peer Review and Stakeholder Review
Procedures. 1997.
Scientific Certification Systems. Overview of LCSEA Methodology. 1997.
Scientific Certification Systems. Programs and Qualifications Profile; Supporting Informed
Decision Making for a More Sustainable Future. Fall 1997.
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Scientific Certification Systems. Response to EPA Type III Labeling Survey. July 1997.
Scientific Certification Systems. The Evolution of a Technical Framework For Life-Cycle Impact
Assessment. 10 November 1997.
Weidman, Elaine. Associate Director, LCA and Environmental Claims, Scientific Certification
Systems. Personal communication with Abt Associates. Fall 1997.
Product Categories
All product categories
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SCIENTIFIC CERTIFICATION SYSTEMS'
FOREST CONSERVATION PROGRAM
Introduction
The Forest Conservation Program (FCP) was developed by Scientific Certification Systems (SCS)
in 1991 to "help the forest products industry, government policy makers, and the general public
bring order to the contentious public debate over management, harvesting, and the conservation of
the earth's forests." The goal of the Forest Conservation Program is to identify forest management
practices that most successfully sustain timber resources while maintaining the ecological viability
of the forest and benefiting the surrounding community.
SCS sends independent inspection teams to evaluate company or state forest operations. Each
evaluation team consists of experts representing such disciplines as forestry, wildlife biology,
hydrology, sociology, natural resource economics, and sustainable resource management. The
evaluation team produces a detailed report with valuable feedback and recommendations for
individual operators who are interested in maximizing the longevity of their timber resources.
High-scoring forests (80 or above on a 100-point index) are certified as "Well-Managed." In this
way, SCS can provide an "independently verified basis for potential marketplace claims." The
program can be applied in tropical, temperate, and boreal forests and plantations, and is open to
small and large land holders alike. SCS certification is also available through Chain-of-Custody
Certification to manufacturers who produce goods from certified well-managed timber, and to
retailers and distributors who merchandise these products. The FCP was accredited by the Forest
Stewardship Council in 1995.
As of September 1997, SCS had certified 15 forestry operations and 35 Chain-of-Custody
operations. Four additional forestry operations are pending certification. Applicants to the
certification programs vary greatly, and include forest managers that produce logs and lumber,
distributors, manufacturers, wholesalers, and retailers. SCS has certified forests and chain-of-
custody operations in North and South America, as well as in Sweden.
Recent Developments
SCS recently initiated a program to evaluate and certify public forestland management units. A
pilot project in Pennsylvania was initiated in early 1997 to evaluate about half of the state's
forestland. Due to the success of this program, Pennsylvania has given SCS the authority to
evaluate the remaining state forestland. SCS considers state land evaluations to be an emerging
field.
SCS has also recently initiated the Consulting Forester and Small Woodlot Certification Program
(Small Woodlot Program) to recognize sustainable forest management on small woodlots. The
operational steps for evaluation are very similar to those of the FCP; however, the program is
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designed to reflect the scope and scale of small, nonindustrial woodlots, usually no larger than
2,000 acres. In this new program, the management practices of a forestry consultant are evaluated
on a sample of woodlots that are under the forester's care. Each woodlot being considered for
certification must meet the Forest Stewardship Council's Principals and Criteria.
Program Summary
In the in-depth analysis of specific forestland area (management units), SCS establishes an
Evaluation Team composed of consultants with expertise in disciplines such as forestry, biology-
ecology, economics, wildlife, sustainable resource management, and decision sciences. The
summary of the Forest Conservation Program and Chain-of-Custody Certification are explained
separately below.
Forest Conservation Program
The process of forest evaluation and certification involves five main steps. In Step 1, SCS and the
client plan the evaluation of the forest operation management practices, including its scope and
geographic limitations. The selection of an Evaluation Team takes place in Step 2. Although the
final decision is made by SCS, the Team selection includes input from the client. Step 3 involves
determining the scope of the evaluation, as well as data collection and analysis. According to an
FCP fact sheet, the Team "conducts on-site inspections, collects and reviews landowner-supplied
records, reviews documents from government forestry agencies and other sources, and conducts
interviews with people in the surrounding community."
The Team identifies relevant "importance-weighted" evaluation criteria in Step 4. These criteria
are organized into three categories: timber resource sustainability, forest ecosystem maintenance,
and financial and socio-economic considerations. Because of the diversity of each site, these
criteria and their relative weights differ from operation to operation. Finally, in Step 5, the Team
assesses the extent to which the site "meets the underlying objectives and goals associated with
each evaluation criterion," and prepares a written report detailing the findings. This report is given
to the client for review and feedback to ensure that the client does not disagree with the accuracy of
the data, or the veracity of any observations and assumptions. The report is then submitted to peer
reviewers for comments on the general FCP methodology and the results of the specific evaluation.
Performance is measured on a 0-100 point scale in each of the three main program elements, and
SCS provides scoring guidelines that describe a threshold and optimal performance. Forests that
rate above 80 in all three categories are designated as "Well-Managed Forests" by SCS. In
addition to scoring sites in the three categories, the evaluation can also make non-mandatory
suggestions to the applicant to improve the quality of management.
Certification is usually valid for three to six years, at which point a full re-evaluation occurs. The
period before re-evaluation depends on the length in years of the applicant's management plan.
SCS requires annual on-site audits to monitor the applicant's compliance with stated goals, as well
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as to establish an ongoing framework that allows SCS to track issues or concerns raised in the
initial evaluation.
The cost of forest certification varies greatly from site to site, and depends on the size of the
operation, the geographic location and distribution of the forest areas, and the ease of access. The
initial fee is between $.05-.40 per acre, and annual audits cost between $2,000-5,000.
Chain-of-custody Certification
Valid chain-of-custody procedures are an essential component to a forest certification program.
Chain-of-custody procedures are intended to ensure that products bearing FCP labeling are
produced from certified sources and materials. Procedures vary greatly from one production
system to another, but SCS has developed basic requirements for the different possible scenarios.
Procedures can include assuring that logs bear a tag identifying the forest of origin, segregating
certified lumber from other lumber at a secondary mill, and segregating the lumber during
transport. The procedures are implemented at key points where the product is transferred, such as
when it leaves the forest, arrives at a paper mill, or is delivered to the broker, wholesale dealer, or
retailer. The chain-of-custody program certifies that production systems have these procedures in
place.
Applicants submit a summary of their processing/sales operations outlining how their operational
procedures will incorporate chain-of-custody considerations. SCS reviews the summary to
determine whether or not to proceed with an on-site compliance audit. The purpose of the audit is
to ensure that the applicant's staff follow the documented procedures, determine if the
documentation of activities is sufficient, and review the effectiveness of the system in meeting
chain-of-custody requirements. The audit is compiled into a report reviewed by the applicant to
ensure that the client does not disagree with the accuracy of the data. If the operations
successfully meet chain-of-custody requirements, SCS issues the applicant a certificate. SCS
requires annual on-site audits of the manufacturing and distribution process, and can conduct
random, short-notice inspections and request documentation related to the product's chain-of-
custody.
The fee for a chain-of-custody certification is between $200-2,000 annually, depending on the size
and complexity of the operation.
Program Methodology
The framework and criteria for the FCP and Chain-of-custody Certification were developed
through a process of consultation with professionals and experts in the forestry field, and
information collected from the literature and independent studies. The FCP's framework was peer-
reviewed in the development stages. Because the field of forestry management changes with
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technical developments, the criteria and methodology are also peer-reviewed during each
evaluation. The criteria are published in the Program Description and Operations Manual.
Other Information
Because small and mid-sized timberland owners are becoming more common, the FCP has
developed an evaluation process that accommodates the realities of small owners. In particular, the
costs of the evaluation are reduced. The new Small Woodlot Program will also help small
businesses.
SCS is following the negotiations and debate over ISO forestry standards, but is not actively
participating in their development. Since ISO forestry standards are being developed to provide a
certification framework, and the Forestry Stewardship Council (FSC) provides performance
measurements, SCS foresees that ISO and the FSC could eventually work well together.
References
Brown, Sydney. Director of Communications, Scientific Certification Systems. Personal
communication with Abt Associates. Fall 1997.
Forest Conservation Program: Quantitative Assessment Program Ranks Forest Management
Practices. Summer 1997.
Hammel, Debbie. Director of the Forest Conservation Program, Scientific Certification Systems.
Personal communication with Abt Associates. Summer 1997.
Pennsylvania, Commonwealth of. News Release: Pennsylvania Chosen to Participate in
Landmark Study of Its Public Forestlands. 13 January 1997.
Scientific Certification Systems. [Online: Web]. Cited 26 November 1997. URL:
http ://www. scs 1. com/
Scientific Certification Systems. Consulting Forester and Small Woodlot Certification Program.
Summer 1997.
Scientific Certification Systems. Forest Conservation Program. [Online: Web]. Cited 26
November 1997. URL: http://www.scsl.com/forests.html
Scientific Certification Systems. Forest Conservation Program: Certified Forests Status Report.
January 1997.
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Scientific Certification Systems. Forest Conservation Program: Manufacturers and Retailers
Certifiedfor Chain-of-Custody. March 1997.
Scientific Certification Systems. Forest Conservation Program; Program Description and
Operations Manual. October 1995.
Product Categories
Wood products
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SCIENTIFIC CERTIFICATION SYSTEMS' "NUTRICLEAN FOOD SAFETY
MANAGEMENT PROGRAM"
Introduction
The NutriClean Food Safety Management Program was launched by Scientific Certification
Systems (SCS) in 1984. NutriClean is the agricultural division of SCS. The program is based on
the "No Detected Residues"(NDR) certification for fresh produce. The NutriClean-Certified NDR
standard means that produce contains no pesticide residues above a laboratory detection limit of
0.05 parts per million. The program was launched not only to test pesticide residues in fresh
produce, but also to recognize growers whose crops meet these standards. NutriClean standards
are up to 1,000 times more stringent than those of the US Environmental Protection Agency
(EPA). The program has several components, one of which is Grower Certification. Produce from
fields that are NutriClean-certified carries a certification label on pallets and containers and may be
accompanied by a shelf label in retail stores. In addition to grower certification, SCS performs
testing services for growers, retailers, and importers. Foods grown organically that have no
detected residues qualify for NutriClean's Organic Certification.
NutriClean is based on three key principles: 1) the certification is granted by an independent,
neutral, third-party with no vested interest in the product being certified; 2) all claims must be
scientifically verifiable; and 3) the certification process is complete with appropriate "checks and
balances" to ensure accuracy in the final result.
The NutriClean program has certified over 400 growers domestically and internationally. It works
with 15 major grocery store chains with more than 3,000 individual stores, and provides services to
more than 150 importers.
Recent Developments
NutriClean recently introduced a program to provide a variety of food safety management services
based on the principal known as HACCP (Hazard Analysis Critical Control Point). HACCP
procedures cover proper food handling, preparation, and storage techniques, and are designed to
control physical, chemical, and microbiological hazards. The Food and Drug Administration
(FDA) and the Department of Agriculture have established HACCP requirements for seafood,
meat, and poultry. Produce standards are voluntary at this time. SCS assists grocery retailers, food
processors, suppliers, and growers in meeting these requirements. SCS offers food safety and
sanitation programs, employee education, and certification of well-planned and properly
implemented HACCP-based food safety management programs.
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Program Summary
SCS's NutriClean program has several components. Grower Certification involves testing produce
and certifying that it meets "clean" food standards; in other words, that the produce has "No
Detected Residues" (NDR). NutriClean certification requires that growers fully disclose the
pesticides that they use. SCS staff conduct on-site inspections and take field samples from the
produce, which are extensively analyzed by independent laboratories. SCS frequently splits
samples among different testing laboratories as a quality control measure. Tests are conducted for
each pesticide used by the grower, regardless of whether it is natural or synthetically derived.
When a field is certified as having NDR, its produce is licensed to carry a NutriClean label. In
addition, certified products are published in NutriClean's weekly Certified Product Status Bulletin.,
which is available on a subscription basis to wholesale distributors, retailers, and food providers.
Fees for grower certification vary greatly and depend on the number of fields and number of
pesticides, among other variables.
Additional services for growers are intended to encourage the responsible reduction in pesticide
use and can assist growers in meeting NutriClean NDR standards. These services include:
employing microbiological assays to assist growers in developing microbiological quality
assurance programs, nutritional analyses to help growers maximize the nutritional value of crops,
analyzing the rate that pesticides decay on crops to help farmers fine-tune their pesticide
applications, documenting that crops comply with government regulations, and conducting soil and
water analyses to provide information about potential contamination.
NutriClean offers a variety of services to retailers. One of these services is testing non-
NutriClean-Certified produce items for pesticide levels and pathogens to verify compliance with
FDA regulations. This testing service may be part of retailers' own quality assurance program.
This program is known as the "DOCK" program because NutriClean collects samples at the
loading docks of retail distribution centers. Collection is done either weekly or bi-weekly. The
number of samples collected is based on the volume of produce that the retailer purchases.
NutriClean attempts to sample five percent of the incoming product. NutriClean also conducts
laboratory analyses of food microbiology, chemistry, additives, alteration, and nutrition, and can
conduct chain-of-custody sampling and verification. In general, these services help retailers
improve food quality and safety. Fees for DOCK testing vary depending on the quantity of
produce sampled.
NutriClean also tests a variety of food items for importers. In addition to produce, NutriClean tests
seafood, meat and poultry, processed foods, and spices for pesticide residues, harmful bacteria and
parasites. The main purpose of this service is to aid importers in complying with FDA pesticide
residue limits. Fees for importers are competitive with those of other organizations doing similar
work.
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Program Methodology
The "No Detected Residues"(NDR) certification is the same for all types of fresh produce. To be
certified, produce must have no detectable pesticide residue above 0.05 parts per million. The level
of 0.05 ppm is the standard limit of quantification that can be met by most labs. In developing the
program, information was gathered from independent studies, participating producers, and current
literature. The program has been peer reviewed. Operating costs are covered by the fees collected
for services.
Other Information
Although NutriClean certifies growers both within and outside of the US, it has not been involved
in any trade conflicts.
References
Brown, Sydney. Director of Communications, Scientific Certification Systems. Personal
communication with Abt Associates. Summer 1997.
Scientific Certification Systems. [Online: Web]. Cited 26 November 1997. URL:
http ://www. scs 1. com/
Scientific Certification Systems. Certified and Organic Food. [Online: Web]. Cited 26 November
1997. URL: http://www.scsl.com/safety.html#haccp
Scientific Certification Systems. Compliance and Food Safety Services for Importers. Summer
1997.
Scientific Certification Systems. Consulting Forester and Small Woodlot Certification Program.
Summer 1997.
Scientific Certification Systems. Food Safety Programs and Tips [Online: Web]. Cited 26
November 1997. URL: http://www.scsl.com/food.html
Scientific Certification Systems. NutriClean Dock Testing 1995 Annual Report. 1995.
Scientific Certification Systems. NutriClean Food Safety Management Program: For Store-Wide
Protection From Food-Borne Illness. Summer 1997.
Scientific Certification Systems. NutriClean Food Safety Services for Fresh Produce. Summer
1997.
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Scientific Certification Systems. NutriClean: Quality Assurance Services. Summer 1997.
Scientific Certification Systems. NutriClean Services for Growers. Summer 1997.
Scientific Certification Systems. NutriClean Services for Exporters. Summer 1997.
Scientific Certification Systems. NutriClean: Three Principals of Certification. Summer 1997.
Scientific Certification Systems. Scientific Certification Systems Verification Program for
Grocery Retailers. Summer 1997.
Sumner, Wilfred. Technical Director, NutriClean Division, Scientific Certification Systems.
Personal communication with Abt Associates. Summer 1997.
Product Categories
Produce
Seafood
Meat
Poultry
Spices
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PRODUCT LABELING UNDER THE TOXIC SUBSTANCES CONTROL ACT (TSCA)
Introduction
The Toxic Substances Control Act (TSCA) was enacted by Congress in the fall of 1976 to identify
and control toxic chemical hazards to human health and the environment. "To prevent
unreasonable risks," the Act gives EPA the authority to "select from a broad range of control
actions under TSCA, from requiring hazard-warning labels to outright bans on the manufacture or
use of especially hazardous chemicals." (EPA, 1987)
Program Summary
EPA is authorized to require labeling both for existing chemicals appearing on the TSCA Inventory
and for new chemicals. For existing chemicals,
Section 6(a)3 of TSCA allows the Administrator to apply:
a requirement that such substance or mixture or any article containing such substance or
mixture be marked with or accompanied by clear and adequate warnings and instructions
with respect to its use, distribution in commerce, or disposal or with respect to any
combination of such activities. The form and content of such warnings and instructions
shall be prescribed by the Administrator. (PL 94-469)
The law does not specify the form or content of the warnings, and EPA has not promulgated any
regulations establishing a single consistent method of labeling. To date, labels have been required
or proposed for chemicals and products on a case-by-case basis. To date, regulated chemicals and
products subject to TSCA Section 6 labeling include PCBs, asbestos, hexavalent chromium and
acrylamide grout.
Under TSCA Section 5(e), EPA requires labeling for some new chemicals that "may present an
unreasonable risk of injury to health or the environment" using its authority "to prohibit or limit the
manufacture, processing, distribution in commerce, use or disposal" of such substances.
Generic labeling provisions listed in 40 CFR §721.72(b), (g), and (h) are applied to significant new
uses of specific chemicals on a case-by-case basis. Companies may be required to provide labeling
for containers distributed in commerce, for containers used in the workplace by employees, or
both. When labeling is required for containers distributed in commerce, labels must include:
a) The commonly recognized identity of the substance
b) A statement of health hazard(s) and precautionary measure(s), if any
c) A statement of environmental hazard(s) and precautionary measure(s), if any
d) A statement of exposure and precautionary measure(s), if any, and
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e) The name and address of a source of additional information about hazard evaluation and
emergency procedures.
Additionally, labels for containers distributed in commerce must not conflict with the requirements
of the Hazardous Materials Transportation Act and the regulations issued under it. Labeling
requirements imposed under TSCA Section 5 seldom affect consumers because the regulated
substances are mainly distributed between manufacturers and processors and are only rarely used in
consumer products.
40 CFR §721.72 contains slightly different labeling requirements for workplace uses of new
chemicals. Companies may provide signs or other written material in lieu of container labels in the
workplace. There is no requirement to include the name and address of a contact for further
information for workplace labels. Portable containers used to transfer a new chemical from a
labeled container for an employee's immediate use need not be labeled. Existing labels on
incoming containers must not be removed or defaced unless they are immediately relabeled with
the required information.
In addition to the specific labeling requirements applied under TSCA Section 5(e), TSCA Section
5(f) allows EPA to apply Section 6's labeling provisions to new chemicals as well as existing ones.
Examples of TSCA Labels
Poly chlorinated biphenyls (PCBs) were regulated under TSCA in 1978. The labeling section of
this rule required one of two labels to be used, a "Large PCB Mark" or a "Small PCB Mark." The
large label states:
"Caution: Contains PCBs, a toxic environmental contaminant requiring special handling and
disposal in accordance with US EPA regulations 40 CFR 761. For disposal information
contact the nearest EPA office. In case of accident or spill, call toll free the US Coast Guard
National Response Center. " The small label states, "Caution: Contains PCBs. For proper
disposal contact US EPA. "
The labeling of asbestos was required in 1989 as part of regulatory actions that included a ban on
"almost all products" containing asbestos. Consumer products containing asbestos include clutch
parts and brake shoes for cars and trucks, pipeline wrap and vinyl asbestos floor tile. The labeling
aspect of the rule is intended "to facilitate compliance with and enforcement of the rule." The
required label stated:
"Notice: This product contains asbestos. The EPA has banned the distribution in US
commerce of this product under section 6 of TSCA (15 USC. 2605) as of [date, ranging from
August 1990 to August 1995]. Distribution of this product in commerce after this date and
intentionally removing or tampering with this label are violations of Federal law. " (54 FR 29460)
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Hexavalent chromium-based water treatment chemicals used in HVAC and refrigeration systems
were regulated under TSCA in 1990. (55 FR 221) The warning label reads:
"Warning: This product contains hexavalent chromium. Inhalation ofhexavalent chromium
air emissions increases the risk of lung cancer. Federal law prohibits use of this substance in
comfort cooling towers, which are towers that are open water recirculation devices and that
are dedicated exclusively to, and are an integral part of, heating, ventilation and air
conditioning or refrigeration systems. "
EPA has proposed a ban on acrylamide and N-methylolacrylamide (NMA) grouts, which are used
to make repairs to leaking cement structures such as sewers and manholes, but also to dams and
basins, and to stop water flow in mines, reservoirs and hazardous waste sites. The ban would
prohibit all use of acrylamide grout and would allow NMA to be used only for sewer repair for
three years, subsequently banning it. EPA proposed labeling of containers of such grout 15 days
after the effective date of the rule. "EPA believes there is a strong need for labeling to ensure
compliance with the prohibitions on the manufacture, importation, distribution and use of
acrylamide and NMA grouts. Labeling is a necessary mechanism to direct users toward
compliance with the prohibitions on uses of acrylamide and NMA grouts." (56 FR 49871)
No wording for the label warning has been suggested.
40 CFR §721 subpart E defines significant new uses for many specific chemicals. Manufacturers,
importers, or processors of these chemicals are required to notify EPA when they intend to engage
in a significant new use of the listed substance. Failure to comply with labeling requirements
specified in subpart E constitutes a significant new use. For 2-Chloro-N-methyl-N-substituted
acetamide, the first chemical listed in 40 CFR §721 subpart E, companies are required to label only
containers distributed in commerce. The following specific hazard and precautionary statements
are required for 2-Chloro-N-methyl-N-substituted acetamide: "This substance may cause internal
organ effects," "When using this substance avoid skin contact," and, "When using this substance
use skin protection."
40 CFR §721 subpart E prescribes more extensive labeling provisions for halogenated phenyl
alkane. For this substance, companies are subject to all of the §721.72 requirements for
workplace labeling and for the labeling of containers distributed in commerce. In addition, labels
must be legible, prominently displayed, and in English. The information they contain may also be
repeated in other languages. Specific hazard and precautionary statements required for halogenated
phenyl alkane include: "This substance may cause cancer," "When using this substance use
respiratory protection," "When using this substance use skin protection," "This substance may be
toxic to aquatic organisms," and, "Notice to users: do not release to water," Each of these
statements must be followed by "See MSDS for details." 40 CFR §721 subpart E's requirements
do not apply once halogenated phenyl alkane has been incorporated into a resin.
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-191
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References
Axelrad, Dan, Office of Pollution Prevention and Toxics, Exposure, Economics and Technology
Division, Regulatory Impact Branch, US EPA, 1993. Personal communication with Abt
Associates, February 26.
US EPA, Office of Toxic Substances, 1987. The Layman's Guide to the Toxic Substances Control
Act, EPA 560/1-87-011, June.
US EPA, Office of Toxic Substances, 1989. "Asbestos; Manufacture, Importation, Processing and
Distribution in Commerce Prohibitions," Federal Register, 54 FR 29460, July 12.
US EPA, Office of Toxic Substances, 1990. Prohibition of Hexavalent Chromium Chemicals in
Comfort Cooling Towers," Federal Register, 55 FR 221, January 3.
US EPA, Office of Toxic Substances, 1991. "Proposed Ban on Acrylamide and N-
Methylolacrylamide Grouts," Federal Register, 56 FR 49863, October 2.
B-192 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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VERMONT HOUSEHOLD HAZARDOUS PRODUCT SHELF LABELING PROGRAM
Introduction
The Vermont Household Hazardous Product Shelf Labeling Program was implemented in April
1991 by the Solid Waste Division of the State of Vermont, Agency of Natural Resources (the
Agency). The mandatory shelf labeling program was established by a 1990 state law that required
all retailers stocking household products containing hazardous constituents to identify those
products via a shelf label. The program's purpose is to promote toxic use reduction and pollution
prevention by educating consumers about the dangers of hazardous household products and
encouraging them to consider alternatives. Additionally, through customer education, the program
hopes to send a signal to manufacturers to produce less hazardous products by prompting
consumers to avoid purchasing hazardous products. Approximately 3,500 Vermont stores (e.g.,
grocery stores, hardware stores, house and garden stores, and convenience stores) are subject to the
law. Since 1995, however, some changes to the extent of labeling required by retailers have been
made.
Retailers were initially concerned that the program would result in a negative consumer perception
of their stores because they sell hazardous products. Instead, consumers have been quite
supportive of the participating stores, and have expressed their appreciation for the additional
product information. Retailers also worried about possible loss of sales of the labeled products.
The state responded by modifying the program to label products deemed less toxic or nontoxic
with an "exempt" label, so that retailers could offer officially-sanctioned alternatives to the labeled
products. To qualify for an exempt label, a petition must be submitted to the Secretary of the
Agency of Natural Resources, and it must be shown that the product is free of certain ingredients
listed in the Vermont Community Right-to-Know list of hazardous chemicals.
Products covered by the program include those listed as household hazardous products in the
Vermont state statute, and generally fall into the following four categories: cleaning products, auto
and machine maintenance products, hobby and repair products, and outside use products (e.g.,
fertilizers, pesticides, butane or lighter fluid, etc.). Personal care products and food items are
excluded.
Recent Developments
Since 1995, there have been changes made to the program aimed at streamlining its
implementation. The biggest change to the program is that retailers are no longer required to label
the shelf space below every hazardous product. Instead, the Agency provides retailers with 3"x 6",
vinyl coated, yellow and black cards known as "shelf-talker" cards. Retailers are required to place
this card in areas that display a significant quantity of hazardous products.
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Additionally, as mentioned above, products considered less toxic or nontoxic were originally
labeled as "exempt" from the program. Since 1995, however, it is no longer required that retailers
label these products as such, though they are welcome to do so if they wish.
Program Summary
Vermont's program was established with input from the broad-based Governor's Technical
Advisory Committee on Solid Waste and other interested parties. The Technical Advisory
Committee included representatives from retailers as well as environmental organizations. The
program was implemented and is maintained by the Solid Waste Division of the Agency of Natural
Resources. The Commissioner of Agriculture has adopted the shelf labeling programs as its
companion program for pesticides and commercial fertilizers.
Categories of products requiring shelf labeling are those listed in the Vermont state statute. Many
of the products on this list also require labeling under the Federal Hazardous Substances Act. The
Vermont program requires that the Agency provide information pamphlets and guides to retailers
detailing which products meet the statutory determination of hazardous products under the labeling
program. Additionally, the Agency is required to provide retailers information, brochures, and
posters about the program for display on their premises and for their customers to use. However,
since 1995, it is no longer mandatory that retailers label individual products (although the Agency
reports that some retailers still do).
The program currently uses yellow and black shelf talker cards contain the signal words "Poison,"
"Danger," "Warning," "Caution," and "no warning label," in descending order. These signal
words closely follow those on product labels required by the Federal Hazardous Substances Act
and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). On the card, an arrow points
from "Poison," indicating the most hazardous types of products, down to "no warning label,"
indicating that products with no warning labels on them are the least hazardous. A message to
consumers that says, "Read label warning words...Choose less hazardous products" is also
presented on the shelf talker card. The card prompts consumers to read these labels before
purchasing hazardous products. Prior to 1995, every household hazardous product listed by the
Vermont statute had to be labeled as such. Now, however, retailers are only required to place these
shelf-talker cards on shelves (or other display areas) when over 20 percent of the shelf or display
area contains hazardous products.
Retailers are provided with information about household hazardous products and alternatives, as
well as logistical information on how to label shelves in information pamphlets and double-sided
information cards. Also, during the first nine months of the program's implementation, a full-time
"retailer educator" was hired to assist retailers in implementing the program.
In addition to the shelf talker cards, the Agency has developed informational posters to be
displayed close to shelves where hazardous products are sold and brochures that contain
B-194 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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background information on products, potential hazards, safe disposal, and use of alternative
nontoxic products.
Program Methodology
As a mandatory program, the Vermont Household Hazardous Products Shelf Labeling Program
requires retailers to label the shelf space below hazardous product displays, when these products
occupy more than 20 percent of the display area. Products covered by the program include those
listed as household hazardous products in the Vermont state statute.
References
Miller, John, State of Vermont, Waste Prevention Section, Vermont Agency of Natural Resources,
1997. Personal communication with Abt Associates.
Vermont, State of, 1992. The Vermont Household Hazardous Products Shelf Labeling Program -
Retailer Information Guide.
Vermont Agency of Natural Resources, Hazardous Product Shelf Labeling: What retailers need to
know, information pamphlet.
Vermont Agency of Natural Resources, 1996, Report to the General Assembly on Streamlining
Household Hazardous Product Shelf Labeling.
Vermont Agency of Natural Resources, Shelf-Talker Label.
Vermont Agency of Natural Resources, 1995, Household Hazardous Products...deserve your
attention, information brochure.
Product Categories
Auto Maintenance
Motor oil
Transmission fluid and additives
Engine lubricants
Antifreeze
Windshield wiper solution
Lead-acid batteries
Engine cleaners and solvents
Gas treatments
Gas line freeze-up products
Car waxes
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Hobby and Repair Products
Paint (brush, spray, and aerosol)
Lacquers and thinners
Alcohol (not for human consumption)
Cresol, naphtha
Mineral spirts
Turpentine
Wood preservatives
Glues and adhesives
Photographic chemicals
Outside Use Products
Fertilizers
Pesticides
Pool chemicals
Self-lighting charcoal
Charcoal lighter fluid
Butane lighters
Cleaning Products
Furniture polishes and stains
Floor waxes
Car waxes
Spray dust cleaners
Drain cleaners
Toilet bowl cleaners
Oven cleaners
Spot and stain removers (petroleum based)
All aerosols
Shoe polish
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WATER ALLIANCES FOR VOLUNTARY EFFICIENCY (WAVE)
Introduction
The Water Alliances for Voluntary Efficiency (WAVE) program was established by EPA's Office
of Water in December 1992, following the success of other EPA voluntary programs such as Green
Lights. WAVE'S mission is to "encourage commercial businesses and institutions to reduce water
consumption while increasing efficiency, profitability, and competitiveness." WAVE encourages
water use efficiency by providing education on water conservation along with marketing support
and use of the WAVE logo. The program currently targets the lodging industry, whose widespread
public exposure provides an effective medium for educating the public on water conservation
issues. WAVE expects to expand its focus by early 1998 to include office buildings, schools, and
universities.
Program Summary
WAVE is funded and administered by EPA's Office of Water and provides its membership services
free of charge. WAVE membership is divided into three categories: Partners, Supporters, and
Endorsers. Any US commercial business interested in water conservation is eligible to become a
WAVE Partner, although, as mentioned above, the program currently targets the lodging industry.
Water service companies, equipment suppliers and manufacturers, government agencies, and utility
companies are eligible to become WAVE Supporters. Finally, environmental groups and trade
associations are eligible to become WAVE Endorsers.
WAVE Partners are primarily targeted to increase their water use efficiency. The WAVE
Partnership consists of a Memorandum of Understanding (MOU) between EPA and the
participating lodging establishment. The MOU commits the business to water efficiency practices
in exchange for technical assistance, publicity, and use of the EPA and WAVE logo. There are
currently 750 hotels, owned by 33 companies, participating in WAVE.
Specifically, the MOU requires that WAVE Partners appoint a WAVE Implementation Manager
for their hotel or chain. They must survey their current water use devices and practices, and
implement more efficient water use techniques. Partners, however, are not expected to undertake
activities that will have an unreasonable impact on profitability. In addition, Partners agree to
upgrade water devices to achieve 90 percent of projected water use reductions within five years of
enrollment, and to use water-efficient devices in any new construction projects. To assist with
these activities, WAVE provides member hotels with WAVE Saver, a software package that
allows Partners to track water use, evaluate efficiency options, and choose the most economical
alternatives for water use efficiency at their hotel. WAVE Saver allows hotels to enter their own
property data (e.g., the number of rooms, size of the facility, etc.) to calculate the unit cost of water
usage, then estimates annual water costs based on historical occupancy patterns. These data are
used to highlight water-efficiency options and analyze the benefits of water-efficient equipment
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-197
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upgrades. Program data and any progress toward water use efficiency must be reported to the
EPA.
WAVE claims that instituting more efficient water use practices can reduce hotel water use by up
to 30 percent. To accomplish such reductions, WAVE often examines plumbing fixtures, cooling
systems, kitchens, laundries and landscaping. The WAVE Saver program allows hotels to
customize water conservation measures to the unique nature of each property, location, and
clientele. EPA also provides technical support through training, workshops, and a nationwide
member help-line. By giving hotels the ability to identify for themselves the best water-efficiency
options, WAVE encourages creativity and independent decision-making in water conservation.
In order to fulfill the educational component of the program's motivations, Partners must educate
both customers and employees about the benefits of water use efficiency. A designated WAVE
Partner liaison at EPA supplies WAVE outreach materials for this purpose. WAVE promotes
Partners through public service magazine advertisements commending Partners' commitment to
water conservation. WAVE gives Partners the right to use EPA and WAVE logos on stationary,
advertisements, and displays. While the MOU sets limitations on the use of these logos, however,
there is no formal mechanism for ensuring compliance with all of the conditions agreed to in the
MOU,
Both hotel chains and individual franchises are eligible for WAVE Partnership, although, as
mentioned above, the program plans to expand its focus in the near future. Because the WAVE
Saver software is more suitable to larger hotels (more than 100 rooms), most of the current
membership consists of larger hotel chains; however, some small, individual hotels have become
WAVE Partners as well.
WAVE Supporters consist of resource-conscious organizations that can help commercial
businesses become more efficient, such as water service companies, equipment suppliers or
manufacturers, government agencies, and water and wastewater utilities. Supporters promote
water efficiency especially within industry, help to publicize WAVE, recruit Partners, and work
with EPA to improve the market infrastructure for water-efficient equipment. EPA works with
Supporters by providing WAVE outreach and training materials and by establishing an
information-sharing network for Supporters. WAVE Supporters also receive the WAVE Saver
computer program to help them survey and upgrade their water use facilities, and may use the
WAVE logo in promotional materials.
WAVE Endorsers are organizations like Green Seal and the American Hotel & Motel Association,
that simply support the WAVE concept and pledge to help EPA promote water conservation
practices. These organizations may also use the WAVE logo in promotional materials.
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Program Methodology
The WAVE program bases the selection of its product categories on environmental impacts.
Currently working with the hospitality industry, WAVE targets commercial businesses and
institutions whose widespread public exposure provides an effective medium for educating the
public on water conservation issues. WAVE membership is open to all interested hotels and
includes automatic program certification. Members must abide by the terms of the MOU signed by
WAVE and the member institution, which requires that members consider their recycling, reuse,
maintenance, and product use patterns. WAVE reviews information from other environmental
programs and member businesses, as well as relevant literature, in targeting business sectors and
setting the standards for its MOUs.
References
Auer, Joy. "Cutting Back on Profit Leaks." Lodging May 1995.
EPA Office of Water. Introducing WAVE- Water Alliances for Voluntary Efficiency. September
1994.
Flowers, John. WAVE Program Director, US EPA. Personal communication with Abt Associates,
Summer 1997.
Martin, Valerie. WAVE Program, US EPA. Personal communication with Abt Associates,
Summer 1997.
Product Categories
Lodging establishments
Water-service companies
Water or wastewater utilities
Energy utilities
Equipment manufacturers or suppliers
Consulting firms
State governments
Municipalities
Hotel franchisers
Environmental groups
Trade associations
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BUYING GUIDES
Greening the Government: A Guide to Implementing Executive Order 12873
Greening the Government was issued in the summer of 1997 to "familiarize Federal agencies with
Executive Order 12873 and help them understand its intent." It includes guidance on the
prevention of waste, recycling of materials and acquisition of goods manufactured from collected
materials. Although the guide is not a buying guide per se, it does provide basic information for
government procurement of recycled products.
The guide contains a summary of the Executive Order including: standards, specifications, and
designation of items; agency goals and reporting requirements; applicability and other
requirements; and awareness. The guide also describes the regulations or recommendations for
green standards in procurement. For example, it outlines the recommended recovered material
content for many items to be used in green procurement such as paper, carpet, etc. The guide
provides case studies of the actions that have been taken by various agencies to promote the
purchase of recycled content. Finally, the guide provides a listing of resources with product
information, including several buying guides listing environmentally preferable products.
References
Office of the Federal Environmental Executive. Greening the Government: A Guide to
Implementing Executive Order 12873. Summer 1997.
The Green Pages
The Green Pages is a directory of 2,500 US suppliers of environmental products and services.
Since 1993, it has ben published annually by the US Department of Commerce. In addition to
being distributed to foreign countries, it is supported by the United States-Asia Environmental
Partnership (US-AEP). US-AEP facilitates relationships between Asia and the environmental
resources of the US, using The Green Pages as one of its primary tools.
All US companies are listed free of charge in The Green Pages if they are registered in the US
Department of Commerce Office of Export Trading Company Affairs' Contact Facilitation
Database. This database contains any company that exports and registers itself in the database.
Companies can also pay for advertising space in the directory, and the publishers of the directory
also actively recruit companies to advertise in the pages. There is no methodology in place for
ensuring that companies listed in the directory in fact abide by their claims regarding their products
and services. The US Department of Commerce states that it "is unable to verify the qualifications
and continued interest of any of the companies requesting to be included in this directory and
accepts no responsibility for the accuracy of the information contained therein." In addition, the
department does not endorse any of the products and services listed or advertised in the directory.
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-201
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References
US Department of Commerce. The Green Pages. US West Dex, Inc. 1997.
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US EPA NATIONAL VOLATILE ORGANIC COMPOUND EMISSION STANDARDS FOR
ARCHITECTURAL COATINGS
Introduction
The National Volatile Organic Compound Emission Standards (NVOCES) for Architectural
Coatings regulates the content of volatile organic compounds (VOCs) in architectural coatings sold
or distributed in the United States. Architectural coatings are defined as coatings that are
recommended for field application to stationary structures and their appurtenances, to portable
buildings, to pavements, or to curbs. VOC emissions have the potential to cause or contribute to
ground-level ozone, elevating it to levels that violate the national ambient air quality standards
(NAAQS). Ground-level ozone is a major component of "smog" and is associated with a wide
variety of human health effects, agricultural crop loss, and damage to forests and ecosystems. The
EPA determined that architectural coatings account for about nine percent of VOC emissions from
all consumer and commercial products. In many states, architectural coatings represent one of the
largest identifiable sources of unregulated VOC emissions. The NVOCES standards regulate VOC
content in architectural coatings in order to reduce overall VOC emissions and comply with
NAAQS.
The standards arose from and are part of the Clean Air Act, section 183 (e). In September 1998,
the EPA issued a final ruling on VOC standards for architectural coatings (CFR, September 11,
1998, Volume 63, Number 176), outlined below. Among other requirements, the ruling mandates
labeling specifications for architectural coatings produced after September 13, 1999.
Program Summary
For the purposes of this regulatory program, architectural coatings are divided into over 50 sub-
categories. Each sub-category has its own VOC content limit. The VOC content of an
architectural coating must be within this EPA set limit. Domestic manufacturers and importers of
foreign products for distribution in the US whose products do not meet the set standard may
comply with the ruling by paying an exceedance fee. A tonnage exemption allows manufacturers
who sell or distribute quantities of architectural coatings that do not comply with VOC content
limits to comply if they produce less than a specified amount per year.
The labeling program is a combination of neutral labeling and negative labeling. It is neutral
because it mandates the reporting of product ingredients. It can also be considered negative
labeling because warning statements regarding ingredient impacts on home, health, and
environment are required for some coating categories.
The labeling component of the regulation specifies that all architectural coatings produced after
September 13, 1999, must indicate of the following information on the product label or lid of the
container:
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A) The date of manufacture or a code indicating this date (this can also be displayed on the
bottom of the container);
B) A statement of the manufacturer's recommendation regarding thinning of the coating
(this does not apply to thinning with water);
C) Either the VOC content of the coating, displayed in units of grams of VOC per liter of
coating; or the VOC content limit (as specified by the standards) with which the coating is
required to comply and does comply, displayed in units of grams of VOC per liter of coating.
(Any coating that does not comply with VOC content limits, such ones for which the
exceedance fee or tonnage exemption provision is being used, must be labeled with its VOC
content.)
Architectural coatings used for industrial maintenance must also be labeled with one of the
following phrases indicating that the coating is not intended for general consumer use:
A) "For industrial use only."
B) "For professional use only."
C) "Not for residential use," or, "Not intended for residential use."
D) "This coating is intended for use under the following conditions:" (Each of the following
conditions that applies to the coating must be included).
1) Immersion in water, wastewater, or chemical solutions (aqueous and
nonaqueous solutions), or chronic exposure of interior surfaces to moisture condensation;
2) Acute or chronic exposure to corrosive, caustic, or acidic agents, or to
chemicals, chemical fumes, or chemical mixtures or solutions;
3) Repeated exposure to temperatures above 120 deg. C (250 deg.F);
4) Repeated (frequent) heavy abrasion, including mechanical wear and
repeated (frequent) scrubbing with industrial solvents, cleaners or scouring agents; or
5) Exterior exposure of metal structures and structural components.
For recycled coating, manufacturers and importers must include the following statement indicating
the post-consumer coating content on the label or lid of the container: "CONTAINS NOT LESS
THANJTPERCENT BY VOLUME POST-CONSUMER COATING," where "JT is replaced by
the percent by volume of post-consumer architectural coating.
In addition to labeling, compliance is enforced through mandatory recordkeeping and reporting of
VOC content information. All manufacturers and importers of architectural coatings must report
the VOC content of their products. Manufacturers who produce recycled architectural coatings, or
who use the exceedance fee or the tonnage exemption provision to comply with the regulations,
must keep records on the VOC content of their products.
B-204 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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Program Methodology
Mandatory labeling changes are used to target a problem (ground-level ozone), by focusing on one
of the major pollutants (VOCs) that contributes to the problem. The VOC content limits were
determined using information gathered during an initial EPA process of regulated negotiation
(which began in 1992 and concluded without consensus), along with other information.
Specifically, the EPA took into consideration data from a 1990 industry study on the volume, VOC
content, and hazardous air pollutant (HAP) content of architectural coatings.
The EPA expects that the VOC content of architectural coatings limits will encourage the
reformulation of products with lower VOC content. Additionally, labeling requirements that
mandate indicating VOC content on the product label will provide consumers with a method of
readily identifying products with lower VOC content.
References
US Federal Register: September 11, 1998 (Volume 63, Number 176).
Product Categories
Architectural Coatings
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-205
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PROGRAMS UNDER DEVELOPMENT
Brazilian Association For Standardization's "ABNT- Qualidade Ambiental"
Introduction
The Brazilian Association for Standardization (ABNT) is in the experimental stage of an
environmental certification program called "ABNT - Qualidade Ambiental" (Environmental
Quality). The program was developed after research was conducted into the experiences of
environmental labeling programs worldwide. The results of the study formed the conceptual
framework of the Brazilian environmental label. ABNT reports that the program is structured
according to ISO draft Standard 14020, "Environmental Labels and Declarations - General
Principals," and ISO draft Standard 14024, "Guiding Principles and Procedures for Type I
Environmental Labeling." Initiated in 1993, the program is positive, voluntary, and based on
multiple criteria. ABNT is a private, non-profit organization, created in 1940 to develop national
government recognized standards. The mission of Qualidade Ambiental, the environmental
labeling program within ABNT, is to "promote the reduction of environmental burdens and
negative impacts related to products or services," by increasing the awareness of manufacturers,
consumers, and public organizations regarding the "advantages of adopting products less harmful
to the environment." Through its environmental certification program, ABNT hopes to: certify
products in the market that demonstrate environmental quality, promote the supply of such
products for consumer use, expand the program into other sectors, become well known in Brazil
and internationally, and reach financial sustainability. The program is currently working on
developing standards in two categories, leather and footwear products and forest products. The
program is not yet active, however, and no products have been certified.
Program Summary
Three main groups are involved in the environmental certification process. The Certification
Commission is responsible for proposing program policies, and supervises the implementation of
these policies and the certification process. The Commission is appointed by the ABNT Governing
Board. The membership is meant to provide a balance of interests, where no single interest
dominates. It is composed of stakeholders such as representatives from government agencies,
industry organizations, scientific and technological institutions, environmental organizations, and
consumers. The Certification Commission creates a Technical Committee for Certification for
each product category. Representation on the Technical Committee is similar to the Certification
Commission, but has a more technical focus. The Committee is responsible for developing the
product criteria. Finally, the Certification Department of ABNT is responsible for the operational
procedures of product evaluation and certification. The Certification Department is made up of
ABNT staff. ABNT - Qualidade Ambiental currently has two product categories. The Technical
Committee for Leather and Footwear Products is analyzing the environmental aspects of the
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-207
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leather and footwear products' life cycle. The Technical Committee for Forest Products is
establishing criteria for wood products.
To select the initial product categories for possible standard development, ABNT worked with
stakeholders and identified ten product categories. The initial two product categories were chosen
when the two industries expressed interest in the environmental labeling program. The forestry
industry came to ABNT in 1996 with the idea of developing a product category for forest
certification. Forest certification is designed to cover planted and natural forests, and is based on
five principles: care for biodiversity; sustainablity of forest resources and their rational use in the
short and long term; care for water, soil, and air; environmental, economic, and social development
of areas with forest activity; and compliance with government legislation.
To develop product criteria, the individual Technical Committee follows several steps. First the
Technical Committees conduct an inventory and develop an "environmental matrix." The matrix
relates the productive processes of each material in the product to its environmental impacts on air,
water, soil, and noise, as well as with the use of energy and natural resources. The Technical
Committee then conducts an Environmental Impact Evaluation by identifying, characterizing, and
evaluating the environmental impact of these inputs and outputs. Each impact is classified as
being "substantial," "reasonable," "not substantial," or "unknown." Criteria are set by determining
the most relevant of these impacts, establishing "threshold values," and using these values as the
basis for developing criteria. The criteria development process may also consider industrial
performance, trends in improvement, available technology, and economic feasibility.
The draft criteria are submitted for public review, and the final criteria are established following a
"consensus process." The ABNT Certification Commission makes the final decision to adopt the
criteria and certification procedures once they have been accepted by involved and interested
parties. The Technical Committee defines how long the criteria will be valid and when revisions
will be carried out. ABNT usually re-evaluates awards every three years. Although no revisions
have occurred to date, ABNT expects revisions to reflect changes in scientific knowledge, new
industrial practices, and consumer expectations.
Companies submit applications for product evaluation directly to ABNT. The Certification
Department carries out audits and tests to determine whether the company and its product comply
with the established criteria. The Technical Committees review the test results, inspections, and
audit reports, and makes a proposal to the Certification Commission when they believe a product
should be granted the Qualidade Ambiental label.
Fees for the two product categories are determined by the Technical Committees. Funding of the
environmental certification program comes from two sources. Salaries of program staff are funded
by the National Council of Scientific and Technology Development. ABNT funds other program
expenses.
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Program Methodology
ABNT reports that the program conforms to the draft standards for ISO draft Standards 14020 and
14024. The product categories are selected when industry groups come forward voluntarily. When
developing criteria, ABNT collects information from literature, other programs, independent
testing, and participating producers. The ABNT methodology is based on Life Cycle Analysis
(LCA), and considers the following elements: extracting and processing raw materials,
manufacturing, transportation and distribution, product uses, reuse, maintenance, recycling, final
disposal, ingredient or materials restrictions, and environmental performance of the production
process. Proposed criteria are not peer reviewed, but are stakeholder reviewed. ABNT conducts
an environmental evaluation, but not an impact assessment.
Other Information
ABNT staff are involved in the development of ISO draft standards. As the ISO standards develop
and change, those of ABNT Qualidade Ambiental are expected to accommodate these changes.
ABNT has been a member of GEN since 1996, and ABNT's Technical Director was on GEN's
Executive Committee until October 1997. ABNT is beginning to conduct harmonization activities
with Spain's AENOR program.
Another mission of ABNT is to promote the adoption of non-environmental product standards in
Brazil. ABNT is accredited as a Registration Body to certify according to ISO 9000 standards.
Standardization work is conducted by committees made up of representatives from various groups,
and the committees attempt to harmonize the various interests and develop standards through
consensus. Other product certification programs include: fire extinguisher maintenance, fire doors,
sprinklers, civil construction products, cement, liquefied petroleum gas containers, and hotel
classification.
References
Associa9ao Brasileira de Normas Technicas. ABNT' - Qualidade Ambiental. Summer 1997.
Associa9ao Brasileira de Normas Technicas. General Information. Fall 1997.
Cabral, Frederico Jose Marques. ABNT - Qualidade Ambiental. Personal communication with Abt
Associates. Fall 1997.
Product Categories
Criteria Under Development
Leather and footwear products
Forest products
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-209
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Categories Under Consideration
Paper
Electrical house appliances
Cosmetics
CFC-free aerosols
Automobile batteries
Detergents
Lamp bulbs
Dyes
Varnishes
Small Spark-Ignited Engine Environmental Labeling Program
The US Environmental Protection Agency is in the process of developing an environmental
labeling program for hand-held combustion engines used in lawn and garden equipment. The
program will be part of national air emission regulations that limit the emissions of hydrocarbons
(HC) and nitrogen oxides (NOx) that small spark-ignited engines may emit. EPA is currently
proposing Phase II levels of HC+NOx as part of the regulation, which will reduce emissions by
approximately 40 percent from the Phase I levels. Manufacturers representing over 90 percent of
the small, hand-held engine industry have agreed to participate in the development of a voluntary
environmental labeling program that will award labels to engines that emit a certain percentage
below Phase II levels. The EPA is soliciting comment on the development of this program, and
plans to release a proposal by early 1998.
References
McCabe, Betsy, US EPA. Personal communication with Abt Associates. Summer 1997.
MISSTAP News, Vol. 4, No. 6, June 1997.
Electric Utility
The Electric Utility program is a pilot program to provide environmental performance information
to consumers regarding various electricity providers. As the government deregulates the electric
industry, these labels will provide consumers with environmental information about competing
electric companies. The three groups involved in developing this program are: the Regulatory
Assistance Project (an NGO), the Federal Drug Administration (providing guidance based on its
experience with the nutrition label), and the Department of Energy.
Pilot programs have been initiated in several states in which deregulation of the electric industry is
occurring. These pilot programs are examining how consumers would like the program to be
B-210 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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organized and what kinds of environmental performance information they would like to use as they
choose their electricity provider. Depending on the information gathered by the pilot project, the
program could take the form of a multi attribute, positive, seal-of-approval, or a neutral report card,
such as the nutrition label, which discloses facts and lets consumers make judgments. Evidence
from pilot studies already completed suggests that the latter is preferred by consumers, though no
formal decision has been made to propose a particular type of positive or neutral label.
Additionally, no decision has been made as to whether the program will be administered by an
NGO or the government.
References
Tiesel, Mario. Federal Drug Administration. Personal communication with Abt Associates.
Summer 1997.
Indonesian Environmental Labeling
Introduction
Indonesian environmental labeling has been spurred by demand in the export market, where
environmental issues have become increasingly important. For example, with forest products,
Indonesia's second largest export industry, there has been a growing movement to buy sustainably
forested products, and the accompanying call for sustainable forestry certification programs.
Indonesian environmental labeling, however, is still in the developmental stages. Thus far, it is
still unclear which of three possible groups— the Ministry of Trade, the Indonesian Ecolabeling
Institute, and BAPEDAL— will be given responsibility to implement a national labeling program.
A proposal for the breakdown of responsibility among the groups has been tentatively accepted by
all three parties. Under this proposal, the Ministry of Trade would be responsible for the labeling
of export products, while the Indonesian Ecolabeling Institute would be responsible for forestry
products, and BAPEDAL would be in charge of labeling other export and domestic products. It is
clear that each group wishes to be given the primary responsibility for administering an
environmental labeling program.
Ministry of Trade
The Ministry of Trade, concerned about potential losses in the Indonesian export market due to
international concern about the environment, has sought to develop a national environmental
labeling program. Thus far, it has concentrated its efforts on the textile and garment industry.
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-211
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Indonesian Ecolabeling Institute
Although the Indonesian Ecolabeling Institute has yet to be formally established, its precursor, the
Indonesian Ecolabling Working Group, was founded in 1994 with three objectives: first, to
establish a set of criteria and indicators of sustainable forest management; second, to setup a
timber certification program; and third, to design an institutional arrangement for the formal
establishment of the Indonesian Ecolabeling Institute. The working group consists of
representatives of academic and nongovernmental organizations, and is chaired by the former
Minister of Environment. The working group has drafted criteria through consultation with the
public and with several national and international wood product and environmental organizations
including the Forestry Stewardship Council, Rainforest Alliance, ISO TC 207, and the
International Tropical Timber Organization. The draft criteria are directed at securing
sustainability of forest productivity as well as its ecological, social, and cultural functions. The
working group has also drafted plans for a certification system for sustainable natural forest
management. A pilot project is planned in the near future. The working group is also preparing
manuals and training materials to be used in the implementation of their certification program.
BAPEDAL
A government agency, BAPEDAL, is responsible for national environmental protection and has
also undertaken the development of a national environmental labeling scheme. Although it is still
in the developmental stages, the program has established the following three goals: the
improvement of environmental quality through the introduction of environmentally preferable
products; community education on environmental issues; and encouraging manufacturers to apply
for their label and consumers to consider it in their purchasing decisions. The proposed
certification process examines the provision and utilization of raw materials, production processes,
and waste generation. Thus far, BAPEDAL has studied several foreign environmental labeling
programs, held seminars and workshops to disseminate information on environmental labeling, and
drafted criteria for several products including pulp and paper, textiles, and leather products.
References
Bratasida, Liana. Director for Technical Development, BAPEDAL. Personal communication with
Abt Associates. Fall 1997.
Djalims, Upik. Indonesian Ecolabeling Working Group. Personal communication with Abt
Associates. Summer 1997.
Heinke, Gary W. et al., Final Report: Development of an Eco-label Certification Programme for
Hong Kong/RC96-19. Hong Kong: Research Centre of the Hong Kong University of Science and
Technology, June 1996.
B-212 Appendix B: Summaries of Environmental Labeling Programs Covered in This Report
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Germany's Type III Eco-report Card
Germany is in the preliminary stages of developing an environmental "report card." Research has
begun on the feasibility and practicality of Type III environmental labeling for Germany. The
initial research and development activities are a joint effort between the Federal Environment
Agency (Umweltbundesamt) and various manufacturers in Germany. This research includes
documentation of practiced labeling programs related to Type III labeling as discussed in the
International Organization for Standardization (ISO) TC 207/SC3/WG1. Also, investigations are
underway to determine if it will be possible to incorporate existing private labeling programs with
a national Type III ecolabel. Additionally, as part of the program's development, a questionnaire
and workshops with representatives of German industrial branches will be conducted to investigate
three characteristics of Type III labeling: target groups for the label and the influence of these
groups on the format of the label, organization of an administration that will supply third party
validation for the label, and development of Life Cycle Analysis methodology.
References
Eva Schmincke, Biologist, Office for Ecological Studies, Germany. Personal communication with
Abt Associates Inc., July - October, 1997.
Hong Kong Ecolabeling Scheme
Hong Kong does not currently have an environmental labeling program. A study was conducted
(1994 - 1996) by the Institute of Environmental Studies at the Hong Kong University of Science
and Technology (HKUST), to determine the suitability of an ecolabeling program for Hong Kong.
The study examined several well-established ecolabeling programs in Europe, the United States,
and Asia to see how their programs were established and to investigate their success. The research
team also conducted meetings with industry, consumer organizations, and government
representatives to obtain their opinions on establishing an ecolabeling program for Hong Kong.
The study concluded that environmental labeling programs may be established for two primary
reasons — to 1) improve environmental quality and protection through market forces, and 2) assist
industries exporting to markets where environmental labeled products are available. It was
determined that because Hong Kong is a major exporter, there are several product categories that
may be suitable for a Hong Kong ecolabel. The report illustrated a number of such products
including: clothing, textiles, electronics, chemicals, plastic products, plastic packaging, metal
products, and industrial machinery.
The HKUST research team conducted discussion forums to determine industry's, consumers' and
government's opinions on the potential establishment of an ecolabel for Hong Kong. Most of the
groups thought that Hong Kong should follow a "wait and see" option. That is, having been
Appendix B: Summaries of Environmental Labeling Programs Covered in This Report B-213
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informed of other worldwide ecolabeling programs, Hong Kong should be an observer at
ecolabeling meetings (UNCTAD, GEN, OECD, ISO) before deciding to initiate its own program.
Another option discussed was for the textile industries to cooperate with one or more of already
established, private, textile ecolabels in Europe, two of which have a branch office in Hong Kong.
The third option discussed was a "franchise scheme" where Hong Kong industries could work with
agents, set up in important export countries, to assist them in obtaining that country's ecolabel. A
fourth option is for Hong Kong to join China's ecolabeling scheme, provided China's label gains
worldwide recognition.
Costs for establishing an ecolabeling scheme for Hong Kong were determined. Meetings have
taken place between Hong Kong's Industry Department and several industries for an exploration of
views. To date, the "wait and see" option is being pursued.
References
Heinke, Gary W. et al., Final Report: Development of an Eco-label Certification Programme for
Hong Kong/RC96-19, Hong Kong: Research Centre of the Hong Kong University of Science and
Technology, June, 1996.
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Select Bibliography on Environmental Labeling
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Global Ecolabeling Network, GENews, March 1997, Issue No. 2.
Heinke, Gary W. et al., Final Report: Development of an Eco-label Certification Programme for
Hong Kong/RC96-19. Hong Kong: Research Centre of the Hong Kong University of Science and
Technology, June 1996.
Organization for Economic Co-operation and Development, Case Study on Eco-Labelling
Schemes. Paris. 30 December 1997.
European Communities, Commission of the, Eco-label Revision; COM (96) 603 final;
SUMMARY. Date Unknown.
Lee, James Dr., et. al., Trade Related Environmental Measures: Sizing and Comparing Impacts.
April 1996. Taken from World Wide Web site:
http://gurukul.ucc.american.edu/ted/GETSPAPI.HTM.
Polak, John and Bergholm, Kari, Eco-Labelling and Trade: A Cooperative Approach. January
1997.
United Nations Council on Trade and Development (UNCTAD), International Trade Division,
Trade and Environment Section. Eco-labelling and International Trade: Preliminary Information
from Seven Systems (Draft)., Geneva, Switzerland, May 19. 1993.
Business and the Environment (BATE), volume 9, no. 6, June 1998.
Draft International ISO Standards, ISO/DIS 14020:1997 (E), 1997.
United States, Congress of the, Office of Technology Assessment, Trade and Environment:
Conflicts and Opportunities (BackgroundPaper), OTA-BP-ITE-94. Washington, DC:
Government Printing Office, May 1992.
Dawkins, Kristin, Institute for Agriculture and Trade Policy, Eco-Labelling: Consumers's Right-
to-Know or Restrictive Business Practice? Minneapolis, Minnesota. January 1996.
United States Environmental Protection Agency, Status Report on the Use of Environmental
Labels Worldwide (EPA Document #742-R-9-93-001). September 1993.
United States Environmental Protection Agency, The Use of Life Cycle Assessment in
Environmental Labeling (EPA Document #742-R-93-003). September 1993.
United States Environmental Protection Agency, Determinants of Effectiveness for Environmental
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