Product environmental footprinting: Will the EU pave the way?

Environmental labelling initiatives have multiplied in recent years, both within and outside the European Union. For instance, in France, voluntary environmental labelling has been used since 2013 and covers about 30 product categories such as furniture, clothing, hotels or food products, referring generally to greenhouse gas emission, damage to biodiversity and consumption of water and other natural resources.

Other types of ratings, such as the Planet score, take more account of biodiversity and the use of pesticides, which are still insufficiently assessed by the Eco-score for instance.

As environmental labelling initiatives have multiplied, so have calls for unified eco-labelling schemes.
In the United Kingdom, Food Standard Agency’s chief scientific advisor has recently urged the development of a unified eco-labelling system to harmonise the different methodologies that currently exist.

In the European Union, the Commission announced in its communication on the European Green Deal that companies that make environmental claims will have to justify them to objectively assess their impact on the environment. This was further confirmed in the Circular Economy Action Plan, and the roadmap for the Regulation was published in July 2020. The publication of this initiative, initially scheduled for March 2022, is now expected for the end of November.

This initiative will require companies to substantiate their claims about the environmental footprint of a product by using standard methods for quantifying them.

A harmonised methodology to calculate the environmental footprint of products in the European Union will both protect the consumer against the use of false or misleading environmental claims (i.e., greenwashing) by making sure that the claims are reliable, comparable and verifiable across the European Union and ensure the uniform use of these claims within the European market.

As the unique method of quantification to measure the environmental performance of a product, the Commission has proposed the Product Environmental Footprint (PEF).

The PEF method uses the life cycle of a product, the Life Cycle Assessment (LCA), to quantify the relevant environmental impacts of a product. The LCA goes along the entire value chain, from raw material extraction to end-of-life, to measure the environmental performance of a product.

Sixteen impact categories are used to calculate the product environmental footprint profile of a product. They include ozone depletion, human toxicity, water and soil use, and eutrophication. Thus, some specific criteria, such as the impact of a product on biodiversity, or the ecosystem, are not categories in their own but are simply included in other categories, such as climate change or land use.

Once this initiative is published, it remains to be seen whether this method is effective in practice.

Indeed, for some product categories, such as food, this methodology may have some shortcomings. For example, the use of pesticides is not taken into account in the calculation, nor are production methods. This means that the score could be the same for intensive and organic farming. In addition, the PEF method will not allow for the distinction between certain food categories such as an animal product and its plant equivalent, a time when this distinction is becoming increasingly important.

While these issues are unlikely to be resolved in the context of the initiative on the environmental performance of products and enterprises, they will – hopefully – be discussed in the context of another key initiative announced in the Farm to Fork strategy: the new initiative on the sustainability of European Union food system.