Orgalime, the European engineering industries association, and ANEC, the European consumer voice in standardisation, are deeply concerned that the Commission’s Directorate-General for Environment is in the process of developing a harmonised 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) approach. This could mean that the proposed methodology and its use in policy making may increase complexity and costs while providing questionable benefit, if any, for industry or the consumer.

The initiative is now undergoing impact assessment in the context of DG Environment’s proposal for a Communication on ‘Unlocking the Single Market for Green Products’. The adoption of the final methodological guide by the European Commission is planned for December 2012, while its integration into relevant policy instruments, including the Eco design Directive, is under consideration as a possible next step.

Stephen Russell, ANEC Secretary-General, remarked: “Our in-depth review1, published earlier this year, concluded that LCA methodology has unique advantages when analysing the environmental performance of products. Nevertheless, it also has significant shortcomings, including dependency on numerous subjective choices, lack of adequate data and limited precision. Hence information for consumers, based on LCA indicators, is not helpful and, indeed, constitutes a step in the wrong direction. LCA alone cannot suitably characterise all environmental impacts. ANEC believes sound environmental assessments require a mix of tools, taking into account the strengths and weaknesses of each.”

Adrian Harris, Orgalime Director General, said: “LCA can be a useful tool for companies’ own product innovation and development processes, and it can be helpful for identifying life cycle stages with the highest contributions to overall life cycle impacts. However, it is not meant for comparability of different products, as is the ultimate purpose of DG Environment’s draft methodology. Used in this way, the door is open to unfair competition and market distortion as consumers will base their buying decisions on misleading information. A level playing-field for companies, however, needs reliable and easy-to understand tools for providing product information to consumers, including on environmental parameters, as the Energy Label has successfully demonstrated.”

Both organisations call on the Commission to pause and re-think its envisaged Communication and related approach to environmental assessment, environment footprint labelling and policy making - in particular when it enters into areas that are already regulated, notably through the Ecodesign and Energy Labelling Directives. These use environmental assessment methodologies that have shown their usefulness in practice for many years.

1 "Environmental assessment goes astray. A critique of environmental footprint methodology and its ingredients", May 2012” (http://tinyurl.com/dyh6npo)

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Notes for the Editor:

Orgalime in brief

Orgalime, the European Engineering Industries Association, speaks for 37 trade federations representing some 130,000 companies in the mechanical, electrical, electronic, metalworking & metal articles industries of 23 European countries. The industry employs over 10.2 million people in the EU and in 2011 accounted for some €1,666 billion of annual output. The industry not only represents more than one quarter of the output of manufactured products but also a third of the manufactured exports of the European Union. More information: www.orgalime.org

Contact person at ORGALIME: Adrian Harris, Tel: +32 2 706 82 40, Email: adrian.harris@orgalime.org

ANEC in brief

ANEC is the European consumer voice in standardisation, representing and defending consumer interests in the process of standardisation and certification. ANEC was set up in 1995 as an international non-profit association under Belgian law and represents consumer organisations from 33 countries. ANEC is funded by the European Union and the EFTA Secretariat, while national consumer organisations contribute in kind. Its Secretariat is based in Brussels. More information: www.anec.eu

Contact person at ANEC: Stephen Russell, Tel: +32 2 743 24 70, Email: anec@anec.eu