United States
Environmental Protection
Agency
Risk Reduction Engineering
Laboratory
Cincinnati, OH 45268
Research and Development
EPA/600/S2-90/048 Dec. 1990
Project Summary
Background Document on Clean
Products Research and
Implementation
Beverly J. Sauer, Robert G. Hunt, and Marjorie A. Franklin
The concept that products can be made
"environmentally friendly" or "clean" has
been attracting much attention. As yet,
however, there is no accepted definition
of what is meant by "environmentally
friendly," nor any agreement on how to
achieve clean products. The full report
summarized here provides Information
on current activities In the U.S. and
around the world concerning clean
products and identifies Issues to be re-
solved. Although focus is on consumer
products, the same criteria and method-
ologies can be used for any product or
process.
This Project Summary was developed
by EPA's Risk Reduction Engineering
Laboratory, Cincinnati, OH, to announce
key findings of the research project that
Is fully documented In a separate report
of the same title (see Project Report
ordering Information at back).
The Life Cycle of Products
The manufacture, use, and disposal of
products can affect resources and the envi-
ronment at every stage in the product's life
cycle. The life cycle of a product moves
from extraction of raw materials to process-
ing stages and on through manufacture.
The product then goes through the distribu-
tion channels to the consumer. Finally the
product is consumed, disposed of, or per-
haps recycled.
There is general agreementthat minimiz-
ing a product's overall effect on resources
and the environment, is desirable; however,
determining what the effects really are and
how one product compares with another is
not easy. Many claims that a given product
is "environmentally friendly" are based on
only one of the many possible points or
types of its effect on the environment.
Existing and Proposed Clean
Products Programs
Existing labeling programs range from
well-controlled national programs and simple
shopping guidelines recommended by vari-
ous consumer/environmental groups to la-
beling claims with undefinedtechnical basis
made by manufacturers and retailers trying
to cash in on consumers' rising environ-
mental concerns.
Germany: Blue Angel
The Federal Republic of Germany is
clearly the pioneer in the field of national
environmental labeling, rts "Blue Angel"
program, in existence since 1978, is used
by other countries as a model. Over 3000
products in 57 product categories now carry
the Blue Angel label. The program defines
clean products as those that
"... when compared with other products
fulfilling the same function and when con-
sidered in their entirety, taking into account
all aspects of environmental protection
(including the economical use of raw ma-
terials), are, as a whole, characterized by
a particularly high degree of environmen-
tal soundness withoutthereby significantly
reducing their practical value and im-
pairing their safety."
It is claimed that a cradle-to-grave ap-
proach is used in evaluating products for the
label; however, it appears that, lacking any
outstanding environmental effects in other
areas, products in a given category are
usually differentiated on the basis of a single
Printed on Recycled Paper
-------
criterion. This criterion may be recycled
content, reusability, or some other environ-
mental concern.
Criticisms of the program include
• failure to update (tighten) criteria;
• not enough emphasis on quality and
usability of labeled products;
• use of a single environmental criterion;
• failure to provide broader labeling
opportunities;
• no guarantee that an unlabeled prod-
uct may not be as environmentally
sound as, or even superior to, a la-
beled one; and
• because some product categories are
excluded, some use of manufactur-
ers' own labels results in consumer
confusion.
Canada: Environmental Choice
Canada's Environmental Choice program
produced its first three guidelines in the
summer of 1989. As of May 15, 1990, 11
approved product category guidelines were
in use and 6 draft issues were out for public
review.
The program literature discourages use
of the term "environmentally friendly" in
favor of referring to products that "reduce
the burden on the environment." A good
environmental product is "any product which
is made, used or disposed of in a way that
causes significantly less harm to the envi-
ronment than other similar products."
Japan: EcoMark
Japan's environmental labeling program
was launched in February 1989. The pro-
gram aims to promote "clean" innovation by
industry, heighten consumers' environmen-
tal awareness, recommend products that
contribute to environmental protection and
conservation, and symbolize an ecological
lifestyle.
"Clean" products considered for labeling
are those that cause little or no pollution
when used or discarded, improve the envi-
ronment while being used, or otherwise
contribute to conservation of the environ-
ment. The logo will also be used for environ-
mentally favorable activities such as recy-
cling programs.
To qualify for the EcoMark, preventive
measures against environmental pollution
must have been taken during manufactur-
ing, product disposal must not involve diffi-
cult processing, opportunity must be avail-
able for conserving energy or resources
through use of the product, compliance with
quality and safety laws, standards, and
regulations must be demonstrated, and price
must not be excessively higher than that of
comparable products.
Nordic Countries
In November 1989, the Nordic Council of
Ministers agreed to implement a voluntary
environmental labeling program. Common
criteria developed with the cooperation of
all participating Nordic countries and a com-
mon label will be used. The environmental
performance of selected product groups will
be assessed in terms of such factors as
what was involved in extracting the raw
materials, what production processes were
used, and what disposal methods are avail-
able; a set of minimum requirements will be
established. In some cases, the label will be
granted to the least harmful product in a
group; in other cases, the label will be
granted to products that represent an alter-
native, more environmentally sound means
of satisfying consumer needs.
Participation of individual Nordic coun-
tries will be voluntary. Norway, Sweden,
Iceland, and Finland have all indicated that
they will participate; Denmark is waiting to
see whether the European Economic Com-
munity will adopt a labeling program before
it decides whether to participate.
Australia: Green Spot
Australia is preparing to launch a labeling
program late in 1990. The Green Spot
program proposes to identify and label con-
sumer products that are environmentally
sound in terms of four broad impacts:
* they cause substantially less pollution
than other comparable products,
* they are recycled and/or recyclable,
* they significantly contribute to saving
nonrenewable resources or minimize
use of renewable resources, and
* they contribute to a reduction of ad-
verse environmental health conse-
quences.
Types of products universally considered
environmentally benign are not to be in-
cluded in the labeling program.
U.S. States and Regional
Organizations
In the absence of a nationally authorized
environmental labeling program inthe United
States, individual states and regional orga-
nizations have begun to attack the issue of
"environmental friendliness." Legislative
efforts have primarily been directed at defin-
ing and banning environmentally unaccept-
able goods, rather than promoting "clean"
products. Judgments of whether or not
goods are environmentally friendly are
usually based on recyclability, degradability,
and reusability.
Perhaps more than any other, the issue
of degradability illustrates the differences in
perceptions of what is better for the environ-
ment. Although many states have bills
pending that seek to ban nondegradable
plastics, many other bills have also been
introduced to ban degradable plastics be-
cause of the lack of information on the
identity and effect of degradation products
that may be mobilized by the breakdown of
the material and the possibility of adversely
affecting plastics recycling operations. Pro-
posed legislation often does not specify a
preferred or optimum substitute materialfor
banned materials nor indicate that the envi-
ronmental effects of substitute products have
been thoroughly considered.
CONEG (Coalition of Northeastern Gov-
ernors) has focused its attention on the
issue of environmental responsibility in
packaging. Its preferred packaging guide-
lines, in order of preference, are: no pack-
aging, minimal packaging, consumable,
returnable, refillable/reusable packaging,
and recyclable packaging or recycled mate-
rial in packaging. CONEG is also support-
ing requirements for removal of toxic agents
such as lead, cadmium, and mercury from
packaging.
The Pennsylvania Resources Council
(PRC) sponsored an environmental shop-
ping seminar in March of 1990. They also
publish an environmental shopping guide
that recommends buying items packaged in
recycled or recyclable materials or reusable
containers and avoiding mixed material
packaging and excessive packaging.
The New York Public Interest Research
Group has put out a pamphlet similar to
PRC's guide in its recommendations on
packaging. Consumers are urged to avoid
single-use, disposable items, difficult-to-re-
cycle or nonrecyclable packaging, and
toxic packaging and to look for reduced,
reused, and recycled products.
The most recent entrant into the field of
product certification and labeling is Scien-
tific Certification Systems of Sacramento,
California, with its "Green Cross" labeling
program. The program is being supported
by the National Toxics Campaign and four
West Coast supermarket chains. Two seals
of approval will be awarded, one for recy-
cling and one for overall environmental ac-
ceptability.
Environmental Groups
Among environmentalists, enthusiasm for
green marketing is high. In an informal
telephone survey, many environmental or-
ganizations were eager to hear of any de-
velopments in this area, particularly regard-
ing the possibility of the beginning of a
standardized approach to environmental
labeling claims.
Many environmental shopping guides
are now widely available as well as "save
the world" books that contain product/pack-
-------
aging recommendations. Shopping and en-
vironmental action guides are books and
pamphlets, published by various individu-
als and environmental groups, intended to
provide the reader with information to use in
making purchasing decisions, investments,
lifestyles adjustments, etc., that will have
the least adverse effect on the environment.
Most of these publications do not claim to
provide the answer of what is environmen-
tally best; rather they aim to help readers
make informed choices or modify their habits
in order to minimize waste and pollution and
conserve resources. These guides include:
Shopping for a Better World, The Green
Consumer, The Green Consumer's Super-
market Shopping Guide, 50 Simple Things
You Can Do To Save The Earth, How to
Make the World a Better Place, and Save
Our Planet - 750 Everyday Ways You Can
Help Clean Up The Earth.
These guides generally appear to use a
single-criterion approach to evaluating
products. None of these guides attempted
even a simplified life cycle analysis. When
more than a single criterion is used, the
presentation of data is often one-sided.
Data on a sing le topic may vary considerably
from book to book depending on its source.
Private Organizations
(Companies, Supermarkets,
etc.)
Many manufacturers, eager to respond
to environmental concerns by labeling their
products "environmentally friendly," are
sponsoring evaluations of the environmen-
tal implications of their products. The re-
sults of these evaluations may be published
in private reports, in informational pamphlets,
or as advertisements.
Typically, manufacturers' environmental
labels are based on a single environmental
criterion; no clue is given as to whether any
other environmental effects were consid-
ered. Common criteria for labeling claims
are those with high public interest or visibil-
ity, such as recycled content, degradability,
or lack of chlorofluorocarbons (CFCs) in
content or manufacture.
In the above programs, criteria have been
developed for various product groups--
groups selected for one or more of the
following reasons:
* the product is a major constituent of
the waste stream,
* the product has a significant impact
on the waste stream because of its
toxicity, etc.
* product use provides a substantial
environmental benefit,
* the product meets safety and quality
requirements for normal use,
* product requirement levels for the la-
bel are high to challenge industry to
meet or exceed current levels of clean
technology,
* the product is easy to evaluate,
* the product is commonly used, and
* the product does not shift environ-
mental impacts from one area only to
create problems in another.
Criteria Used to Evaluate
Products
Most "clean product" recommendations
are based on one or a few of the criteria
discussed below rather than on a total envi-
ronmental impact evaluation.
Recycled Content
Recycled content is the most popular and
widespread criterion used. It is a popular
criterion because of wide recognition and
support by consumers; however, different
groups may use different definitions or re-
quirements for recycled content.
Recyclablllty/Reusabillty
In the United States, recyclabilrty and
reusability are widely used as criteria in
legislation although definitions may vary.
For example, recent proposals in Massa-
chusetts and Oregon to ban environmen-
tally unacceptable packaging differed in their
definitions of "recyclable." Obviously, stan-
dard definitions of terms would be a step in
the right direction. In addition, proposed
legislation is not specif icon the materials or
containers that are to replace thosedeemed
unacceptable.
Degradability
Degradability is a popular and widely
disputed criterion. It has been heavily used
as an advertising point but is currently being
questioned or even denounced by many
environmentalists. Many manufacturers and
retailers focus on degradability as a positive
characteristic, however, at least one "envi-
ronmentally conscious" mail ordercompany
has temporarily withdrawn its biodegrad-
able plastic bags for reevaluation of their
environmental effects. Some legislative
proposals have called for bans on
nondegradable plastics, whereas others
have attempted to eliminate degradables.
Hazardous/Toxic Material
Content
This criterion can be used to justify the
need for environmental labeling, or it can be
used to disqualify products from eligibility
for labeling.
Water Pollution Impacts
Water pollution has not been frequently
used as a criterion although it is given
specific attention in several environmental
guides, particularly those having to do with
phosphates and bleaches in detergents and
biodegradability of various household prod-
ucts.
So/7 Pollution Impacts
This is another criterion that is an integral
part of a cradle-to-grave analysis, but it is
not a popular single criterion for labeling,
except perhaps in the case of organically
grown foods. Soil pollution is given some
attention as an issue associated with the
disposal of batteries and concern about the
fecal wastes in disposable diapers. It is also
being mentioned as a concern regarding
degradable plastics because little is known
about the identity and effect of degradation
products.
Air Pollution Impacts
The most popular air pollution issue in the
past few years has been the chlorofluoro-
carbon (CFC) content of certain products or
a product's "ozone friendliness." Ozone
friendliness has been covered by labeling
programs, environmental shopping guide-
lines, and proposed legislation, particularly
with regard to foam plastics production and
content. Air pollution effects are also used
as a criterion when discussing disposal of
products by incineration.
Noise Pollution Impacts
Noise pollution is little used as a criterion
in the United States; however, it has been
used as the primary criterion in labeling
certain West German products, e.g., lawn
mowers, car mufflers.
Production Processes Used
This criterion has not been directly used
but draft Canadian guidelines for re-refined
oil and recycled cellulose construction ma-
terials specified "acceptable processes" for
oil demetallization and hydrotreating and
use of a "dry process" to produce recycled
paper products, however, these specifica-
tions were removed from the final guide-
lines.
Use of Resources (Including
Energy)
This criterion can be subdivided into use
of energy and use of resources. Unless
energy usage is the primary evaluation cri-
terion, it is difficult to tell whether it has been
-------
addressed in assessing environmental im-
pact of a product. For example, ciradle-to-
grave energy consumption is rarely men-
tioned when comparing plastic bags with
paper bags. In addition, it is difficult to
determine whether legislative bodies seek-
ing to ban certain materials have consid-
ered the increased energy use for collect-
ing, transporting, cleaning, and distributing
reusable products such as refillable glass
bottles.
Product recommendations on the basis
of resource conservation are most often
related to plastics as a user of petroleum
(considered a nonrenewable resource) and
paper as a user of wood (considered a
renewable resource).
Other Criteria
Other criteria that have been used are
more benign products/processes, general
requirement of safety/usability, amount or
type of packaging, provision of information
for the consumer, overall corporate reputa-
tion, effect on rain forest, longer lasting or
repairable products, weight or volume con-
tribution to landfills or waste streams or
troublesome disposal problems.
Methods Used to Evaluate
Products
Product Life Cycle Analysis
Environmental problems can be poten-
tially alleviated by either direct or indirect
means. A direct means would include bans
or economic incentives or disincentives
(such as taxes or grants) that have an
im mediate effect on an environmental prob-
lem caused directly by the product. Indi-
rect means include the banning of a product
or the substitution of one product for an-
other where the environmental problem al-
leviated is not as clearly linked to the prod-
uct.
The worth of either a direct or an indirect
approach can only be assessed by a life
cycle analysis that examines the entire
complex of operations associated with a
product. The theory behind the use of
product substitution or banning as a way to
benefit the environmental is that if the prod-
uct is not purchased, then the manufactur-
ing and processing will cease and, along
with it, the environmental consequences
will cease. The substitute product also
produces environmental consequencesthat
need to be evaluated. A narrow focus
analysis can greatly err in assessing the
actual results of any action that affects
purchasing habits.
In comparing a given product or a set of
products on two or more environmental
issues, even life cycle analysis may not be
enough to give adequate guidance. The
reason is that there are no weighting factors
that tell how to compare environmental im-
pacts, for example, of one pound of toxic
heavy metal sludge to one gallon of water
usage or consumption of one Btu of energy.
Matrix Approach (Pass/Fail)
Although the life cycle analysis approach
is the most comprehensive method, a more
common approach is using a matrix with
"pass/fail" ratings. For example, a widely
used book in England lists a variety of
packaging materials with a series of envi-
ronmental criteria (recyclable?degradable?
etc.) with yes/no answers and some com-
ments.
Weighting Systems
A problem with either the life cycle analy-
sis approach or the matrix approach is that
decisions as to which criteria are most im-
portant are left to the reader or consumer of
the product. For example, two products
(say aluminum cans and glass bottles) can
be compared using a life cycle analysis.
One product may "win" based on air pollu-
tion impacts and the other may "win" based
on the amount of solid waste to be dis-
posed. Which is more important?
Issues/Technical Problems to
be Resolved
Selection of Products to be
Evaluated
Several of the criteria used in product
selection are somewhat vague or contro-
versial such as selecting products that are a
significant factor in the waste stream (the
issue here is definition of the term, "signifi-
cant"), selecting products that are simplest
to evaluate, or selecting products that do
not contain hazardous components.
Complete Life Cycle Analysis
Versus Easier, Quicker
Methodologies
Decisions must also be made as to
whether a complete life cycle analysis should
be made or whether easier, quicker meth-
odologies should be used. The main con-
cerns here are time and expense involved in
analysis versus environmental benefit, and
consumer loyalty and possible disillusion-
ment or confusion. A true cradle-to-grave
life cycle analysis is time-consuming, ex-
pensive, and raises difficult questions about
weighting the relative importance of various
environmental concerns. Also, once envi-
ronmentally committed consumers have
embraced an idea, it may be difficult to
change their minds with the facts.
Handling Trade-Offs
In complete life cycle analyses, summa-
ries of environmental effects such as the
total energy usage or water usage associ-
ated with one product can be directly com-
pared with the same effects associated with
another. Problems arise over comparing
different impacts with respectto each other.
There are no established scientific method-
ologies for deciding which is more impor-
tant. Some ways to handle these trade-offs
are: weighting systems (this involves sub-
jective judgment as to which components
are least desirable or most harmful); pass/
fail systems (using quantitative compari-
sons with minimum or maximum allowable
levels); letting the consumer decide (aban-
don asimple logo and present environmental
impact information, letting the consumer
decide what is environmentally preferable);
or using only one easy consumer-deter-
mined criterion (the advantage is easy
evaluation by consumers but the disad-
vantage is oversimplified and erroneous
conclusions on environmental impact).
Implementation Issues
Who should implement labeling pro-
grams? Some governmental clean product
programs are being done at the national
level but not in the United States. A number
of states are, however, moving in the direc-
tion of some kind of "environmentally
friendly" product regulations. The states
that are in CONEG have been particularly
active in this regard. Environmentalist or
other nonprofit groups also are involved in
studying clean product/source reduction
issues. Finally, many private companies
have been carrying out their own initiatives,
sometimes in connection with groups like
CONEG.
Policy Implications
There would be some advantages to
implementing a clean product program na-
tionwide. However, having a federal pro-
gram would not necessarily preclude states
or other organizations having their own pro-
grams as well. There would be the need to
determine which agency(ies) would imple-
ment the program, research would be re-
quired, and an implementation mechanism
would have to be developed and adminis-
tered.
Another issue is the necessity to update
the criteria used to measure products. These
criteria can change with time as research
provides new information on environmental
phenomena. Also, new products are con-
tinually being developed, and processes
used to manufacture products also evolve
over time.
-------
Recommendations
Both manufacturers and consumers gen-
erally appear to recognize the potential
benefits of labeling products as being envi-
ronmentally safe. As yet, however, no uni-
versally accepted and supported course of
action has been identified. Although cur-
rent efforts by various individual groups
may be well-intentioned, they do not ad-
equately address the comprehensive envi-
ronmental impacts associated with a
product's entire life cycle, and therefore,
may offer consumers misguided direction.
Additional effort in several areas could
aid in the development and support of clean
products programs, e.g., standardized defi-
nitions and use of environmental impact
terminology, survey of consumers to find
out what types of information/education
would be most useful, further development
of methods to thoroughly and effectively
evaluate products on a life cycle basis,
development of a standardized environ-
mental labeling program, reward incentives
for manufacturers who provide cleaner
products.
Additional measures that could minimize
environmental effects of consumer prod-
ucts might include: education on proper use
and disposal of products; elimination of high
environmental impact products for which
acceptable, less damaging alternatives ex-
ist; elimination of excess packaging; and
efforts to reshape today's convenience-ori-
ented consumer perspective to a more en-
vironmentally responsible attitude.
The benefits to the environment, and
consequently to mankind, that may be
gained by support of clean products are
considerable. The information provided
and issues raised in this report can serve as
a starting point.
Thefull report was submitted in fulfillment
of Contract No. 68-01-7310, Work Assign-
ment No. 125, by Franklin Associates, Ltd.,
under subcontract to NUS Corporation un-
der the sponsorship of the U.S. Environ-
mental Protection Agency.
-------
-------
-------
Beverly J. Sauer, Robert G. Hunt, and Marjorie A. Franklin are with Franklin Associ-
ates, Ltd., Prairie Village, KS 66208.
Mary Ann Curran is the EPA Project Officer (see below).
The complete report, entitled "Background Document on Clean Products Research and
Implementation," (Order No. PB91-108 977/AS; Cost: $17.00, subject to
change) will be available only from:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Telephone: 703-487-4650
The EPA Project Officer can be contacted at:
Risk Reduction Engineering Laboratory
U.S. Environmental Protection Agency
Cincinnati, OH 45268
United States
Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati, OH 45268
BULK RATE
POSTAGE & FEES PAID
EPA PERMIT NO. G-35
Official Business
Penalty for Private Use $300
EPA/600/S2-90/048
------- |