April 12, 2013
Having reviewed the Draft Commission Recommendation on the use of Product Environmental Footprint (PEF) and the Organisation Environmental Footprint (OEF) methods, both Orgalime and ANEC are extremely disappointed that, notwithstanding their joint opposition to the draft proposal, the Commission should once again have opted for yet more big brother ‘voluntary’ regulation.
Orgalime sees this proposal as representing an unreliable tool for creating demand for better and greener products in the EU, while it risks exposing companies to unfair competition and to market distortion as consumers would base their buying decisions on misleading information.
ANEC too has been a persistent critic of the value of environmental footprint information, whether from a methodological perspective, or the perspective of consumer understanding, and maintains that information to consumers based on the LCA approach – at the centre of PEF/OEF methodologies – should be rejected and neither supported nor promoted by the European Commission or member states.
Although principles such as clarity, credibility and reliability, identified in the Commission Communication, are values shared by consumer organisations and the engineering industry, the proposed methodologies cannot serve to apply these principles. Information to consumers should be based on robust, measurable and verifiable indicators, elaborated product group by product group, in collaboration with stakeholders.
ANEC Secretary-General, Stephen Russell, commented: “Environmental Product Declarations are useless for consumers as they do not allow for the reliable identification of environmentally-superior products. They are based on questionable methods and lack meaningful benchmarks and rating scales. Real world cases of LCA studies – such as nappies and packaging – have already shown that the results of an environmental assessment based on LCA depend on subjective choices. Moreover, statistical uncertainties inherent in the data are likely to make the identification of superior products almost impossible anyway”.
Concluded Adrian Harris, Orgalime’s Director General: “It never ceases to astound me how the institutions can one day adopt proposals aimed at enticing manufacturing industry to invest in Europe and to contribute to much needed re-industrialisation, and the next come up with yet more bureaucratic proposals, which will be prohibitively heavy to apply for our small companies and no doubt achieve the opposite result. It really is time to snap out of this business as usual mode”.
Methodology for the calculation of the environmental footprint of products, services and organisations with a view to assess, display and benchmark their environmental performance based on a Life Cycle Assessment (LCA) approachAuthor : EngineerComms