Requirements on Consumer Information about Product ... - ANEC

Consumer Information about PCF
- subsequent discussion by a panel of experts;
- final decision by an “environmental jury” on which relevant stakeholder groups are
represented;
- certified award process and checking of the criteria for products marked with the
ecolabel.
Drawing up of Product Category Rules for particularly relevant products is essential
The main challenge of PCF meant for communication is to define the whole framework in a
way that all products belonging to one product group can be calculated in an as much as
possible defined way to assure the same approach even if the studies are performed by
different experts. This requires e.g. the same goals, the same system boundaries, the same
calculation rules and similar data quality for different studies. With a general ISO standard
this can not be achieved as it only provides generic rules. Therefore it is essential for the
future that product category rules (PCRs) will be developed that ensure a comparable
proceeding within one product group. Such PCRs would have to be defined and adopted at
the European level. Given the many different product groups this will take time and needs
prioritisation.
Basing on PCF it is not possible at the moment to perform product comparisons of multiple
products carried out on behalf of different clients and by different practitioners as well as
public comparison with competing products in ways that are acceptable under competition
law (e.g. through reporting of CO2e values or use of CO2e labels).
Methodological restrictions when using the LCA / PCF approach
For the PCF approach the same is true as for the general LCA approach: The assessment of
the whole life cycle is a strength compared to other techniques. The approach can be used to
compare products with similar function but differing production and/or operating technologies.
Still the methodology has some restrictions that have to be kept in mind when applying it:
Like LCA also PCF is per definitionem a purely quantitative tool. As it has to be requested
that at least a screening analyses on other environmental impacts then greenhouse gases
has to be performed in a PCF study, the same problems occur as with LCA. Current LCAapproaches
cannot exhaustively cover site-specific aspects: as greenhouse gases have a
global impact and no site-specific one, this weakness does not apply to PCF studies in the
narrow sense. As for LCA, the variability and reliability of data may represent a problem
concerning data quality (e.g. time-related, geographical and technology coverage), data
origin, effort of data acquisition and possibly fast changes of supply chains. Spatial and
temporal variations are theoretically no obstacle for the applicability of LCA / PCF in product
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