report on 2018 product and organisation …...financial institutions in europe and worldwide using...

1

Report on

2018-2019 stakeholder consultations

regarding the potential future use of the

Product and Organisation Environmental

Footprint methods

Date: 27/04/2020

Version: 1

Note The introduction, description of the

stakeholder event and analysis of the

business survey were prepared by Ecofys,

a Navigant company. The report on the

Environmental Footprint sections of the

public consultation on a product policy

framework for the circular economy was

prepared by COWI.

The report was prepared by the

Directorate-General for the Environment

of the European Commission

2

Disclaimer The information and views set out in this

report are those of the stakeholders

responding to the consultations and do not

necessarily reflect the official opinion of

the European Commission.

3

Table of Contents

1 INTRODUCTION ............................................................................................................................ 5

2 THE STAKEHOLDER EVENT ...................................................................................................... 6

2.1 Background information ..................................................................................................................... 6

2.2 Programme of the stakeholder event ................................................................................................... 6

2.3 Report of the meeting.......................................................................................................................... 8

3 STAKEHOLDER SURVEY – TARGETED ONLINE CONSULTATION .............................. 10

3.1 Process .............................................................................................................................................. 10

3.2 Analysis of the outcomes of the business and sectoral business associations survey ....................... 11

3.2.1 General .................................................................................................................................. 11

3.2.2 Importance of environmental information ............................................................................ 12

3.2.3 Experience with environmental information ......................................................................... 13

3.2.4 Use of the PEF and OEF method .......................................................................................... 18

3.2.5 Potential use of the PEF and OEF methods for providing environmental

information ............................................................................................................................ 20

3.2.6 Other comments .................................................................................................................... 24

3.2.6.1 Additional comments (free text) ...................................................................................... 24

3.2.6.2 Position papers ................................................................................................................. 25

3.3 Analysis of the outcomes of the investors/ financial institutions survey .......................................... 26

3.3.1 General .................................................................................................................................. 26



3.3.4 Use of the PEF and OEF methods ......................................................................................... 29

3.3.5 Other comments .................................................................................................................... 31

3.4 Analysis of the outcomes of the method and initiative owners’ survey ............................................ 31

3.4.1 General .................................................................................................................................. 31




3.4.5 Other comments .................................................................................................................... 38

3.4.5.1 Additional comments (free text) ...................................................................................... 38

3.4.5.2 Position papers ................................................................................................................. 38

3.5 Analysis of the outcomes of the public administrations and international organisations

survey ................................................................................................................................................ 38

3.5.1 General .................................................................................................................................. 38


3.5.3 Use of the PEF and OEF method .......................................................................................... 41

3.5.4 Other comments .................................................................................................................... 45

3.6 Analysis of the outcomes of the NGO survey ................................................................................... 46

3.6.1 General .................................................................................................................................. 46




3.6.5 Other comments .................................................................................................................... 51

4 ANALYSIS OF THE PUBLIC CONSULTATION ..................................................................... 52

4.1 Participants in the survey .................................................................................................................. 52

4.2 Selection of responses to questions relevant to the Environmental Footprint context ...................... 54

4.2.1 Effectiveness of EU product policies – consumption and procurement ................................ 54

4

4.2.2 Information on products and environmental labelling .......................................................... 55

4.2.3 Misleading environmental claims ......................................................................................... 62

4.3 Opinions on the Environmental Footprint methods .......................................................................... 64

4.4 Environmental information on products and organisations .............................................................. 65

4.5 Providing reliable, comparable and comprehensive environmental information .............................. 67

4.6 EU-wide product group and sector-specific rules ............................................................................. 68

4.7 Strategic sectors for product- or sector-specific calculation rules ..................................................... 70

4.8 Communication requirements related to environmental information for products and

organisations ..................................................................................................................................... 71

4.9 Availability of environmental footprint information on products ..................................................... 74

4.10 Additional comments on the Environmental Footprint methods ...................................................... 75

5 CONCLUSIONS ............................................................................................................................. 77

5.1 Synthesis of consultation activities ................................................................................................... 77

5.2 Key policy-related results per consultation ....................................................................................... 78

5.3 Synthesis of outcomes from all consultations ................................................................................... 80

5.3.1 On environmental information .............................................................................................. 80

5.3.2 On the use of environmental methods and initiatives ........................................................... 81

5.3.3 On policy options .................................................................................................................. 82

5.3.4 On options for communicating results .................................................................................. 85

Annex 1 Detailed listing of final comments and position papers ............................................. 87

Annex 2 Background document for the consultations .............................................................. 96

Annex 3 Questionnaire – consultation targeted to business and business

associations .................................................................................................................................. 107

Annex 4 Questionnaire – consultation targeted to investors and financial

institutions ................................................................................................................................... 130

Annex 5 Questionnaire – consultation targeted to public administrations and

international institutions ............................................................................................................ 148

Annex 6 Questionnaire – consultation targeted to method and initiative owners ............... 168

Annex 7 Questionnaire – consultation targeted to NGOs ...................................................... 188

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1 INTRODUCTION

The European Commission is currently evaluating potential ways forward for the application of

the the Product Environmental Footprint (PEF) and Organisation Environmental Footprint (OEF)

methods in existing or new policies. The public consultation within the context of this project

aimed to gather views of relevant stakeholders on possible options for the further use of the

methods and to collect evidence and opinions on underlying issues related to environmental

information and green markets.

The consultation process in this project consisted of a half-day stakeholder event in Brussels

(26 April 2018), a targeted online consultation (12 November till 18 December 2018) and a

open public consultation as part of a wider questionnaire on a product policy framework for the

circular economy (running from 29 November 2018 to 24 January 2019). All consultations

gathered inputs from specific stakeholder groups, either through break-out sessions (stakeholder

event) or specific surveys (stakeholder survey).

The background document distributed alongside the consultations is available in Annex 2.

The following stakeholders were identified and consulted during the project (see Table 1).

Table 1 Overview of consulted stakeholders

Stakeholder group Scope Potential role related to the policy

Businesses

Large companies as well as small- and

medium-sized enterprises in Europe

and worldwide, including industry

associations

Applying PEF and OEF method and

communicating environmental

performance of products or

organisations, decide on their purchases,

and improve the environmental

performance of the product or company

considering impacts throughout the

value chain

Investors Financial institutions in Europe and

worldwide

Using OEF profiles/communication of

companies to take investment decisions

Method and

initiative owners*

Developers of methods, and

organisations behind private labels and

certification schemes

Potentially implement PEF and OEF or

elements thereof in existing initiatives

Consumers** Consumers in Europe Using PEF profiles/communication of

products to make purchasing decisions

Public authorities Public authorities at European and

Member State level

Design and development of policy

options

Implement policy options

Monitoring and assessing impacts

Use OEF and PEF

profile/communication for procurement

decisions (Green Public Procurement)

Use the PEF method as a basis for their

product policies / national labels

NGOs NGOs, other Monitoring and assessing impacts * The perspective of method and initiative owners was investigated in the online survey only

** The consumer perspective was investigated during the stakeholder event and during the public consultation

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2 THE STAKEHOLDER EVENT

2.1 Background information

A stakeholder event was held on 26 April 2018 9.30 to 13.30 in Brussels. The aim of the event

was to understand the concerns and opinions of stakeholders when moving from vision to action

with regard to implementing PEF and OEF in existing or new policy instruments.

Stakeholders were keen on participating in the event. In total, 88 stakeholders participated. Even

more stakeholders registered but could not join the event due to the maximum capacity of the

event, e.g. capacity of room and number of moderators.

Table 2 shows the types of stakeholders that participated in the event. Businesses were well

represented by 41 participants in total. Public authorities were represented by 17 participants. No

investors joined the event. Consumers were represented by the European Community of

Consumer Co-operatives. Various NGO’s and research institutes participated as well (22

participants in total).

The event consisted of plenary sessions and five break-out sessions. Each break-out session

focused on the perspective of a certain stakeholder: businesses, investors, consumers, public

authorities and other. Although the perspective of a specific stakeholder was taken, various

stakeholders could join the break-out sessions. For example, businesses may have an opinion on

the consumer perspective, or public authorities may have an opinion on the business perspective.

Table 2 Participants of the stakeholder event

Stakeholder group Organisation type Number of participants

Businesses

Industry/ sector organisation 22

Large company 11

SME or related association 8

Investors 0

Consumers European Community of Consumer

Co-operatives 1

Public authorities Public authorities 17

Other

NGO/ civil society 12

Research institute / university 10

Other 7

Total 88

2.2 Programme of the stakeholder event

The programme of the stakeholder event is presented in

7

Table 3. The event started with an introduction, addressing the highlights of the final PEF/OEF

conference, an explanation of the problem definition and an introduction to the considered policy

options. After the plenary session, the participants split up in 5 break-out groups, each presenting

a different stakeholder perspective (consumers, businesses, investors, public administration and

other), to discuss the problem definition and potential policy options. After the break, each group

presented the main outcomes of the group sessions. The event was finalised with a discussion

focusing on a number of questions.

8

Table 3 Programme of the stakeholder event at 26 April 2018

Time Program

09.30

Introduction

Welcome & aim of the day

Highlights of the final PEF/OEF conference

Explanation of the problem definition

Presentation on the policy context

Introduction to the policy options

10.30

Break-out session in 5 groups:

Group 1. What is needed to enable consumers to make well-informed decisions

on (green) products?

Group 2. How could public administrations implement and use the

Environmental Footprint methods and information_

Group 3. How can companies distinguish themselves or their products on

sustainability?

Group 4. How can harmonised environmental metrics support well-informed

investment decisions by companies and financial institutions?

Group 5. How can the proposed policy options support more sustainable

consumption and production in Europe?

12.00 Coffee break

12.20 –

13.30

Plenary session

Recap of all 5 break-out groups

Moderated live discussion

2.3 Report of the meeting1

In general, it can be concluded that most participants agree that sufficient access to

environmental performance of products and organisations can change purchase and investment

decisions, but reliable and consistent information is not available at present. The large number of

available methods (but also labels and initiatives) should be reduced. Using PEF and OEF as

basis for green claims is welcomed but there seem to be some concerns about the maturity of the

methods to fulfil this purpose. A large number of stakeholders invested time and money in the EF

pilot phase2 and they would like the Commission to follow-up with policy measures. They ask

the Commision to come up with robust policy measures and to communicate about this clearly.

Main findings per stakeholder group are summarised below.

Consumers

Consumers’ purchase decisions are influenced by the environmental performance of products and

organisations, but sufficient environmental information is not available, or such information is

not trusted. The trust in information differs per label; information from governmental information

schemes is trusted better than unverified company claims.

The integration of PEF/OEF methods in existing policy measures like EU Ecolabel will probably

not have much impact because consumers typically do not know what is behind the EU Ecolabel.

When discussing the use of PEF/OEF methods as an instrument supporting green claims,

stakeholders mentioned that PEF/OEF methods are well-developed but that work still needs to be

done with regard to communication and data reliability.

1 The full report of the meeting is available at the address

https://ec.europa.eu/environment/eussd/smgp/pdf/Report_EFstkhevent_26042018.pdf

2 https://ec.europa.eu/environment/eussd/smgp/PEFCR_OEFSR_en.htm

https://ec.europa.eu/environment/eussd/smgp/pdf/Report_EFstkhevent_26042018.pdf

https://ec.europa.eu/environment/eussd/smgp/PEFCR_OEFSR_en.htm

9

Businesses

Businesses recognise that the demand for green products is growing. Most companies know the

environmental impact of their own operations, but do not know the environmental impact in their

supply chain. In general, climate impact is better known than other environmental impacts. SMEs

may have more difficulty to measure their environmental performance. Most companies also

agree that there are too many methods to measure the environmental performance of companies.

Companies welcome PEF method as the only methodology for green claims, and to make PEF

mandatory if a company wants to make a green claim. It was also discussed that PEF/OEF

methods are not mature enough at the moment. Companies also expect that the interest for

PEF/OEF will be lost in absence of clear policy measures.

Public administration

There is agreement that there is a growing interest in Green Public Procurement (GPP), but there

is not enough information available. Three challenges were identified for further development of

GPP: 1) lack of information when developing policies, 2) administrative burden and complexity

when implementing policies, and 3) monitoring is main issues in policy follow-up. A reduction in

the number of labels is seen as necessary.

Investors

Most participants agreed that companies with a sound environmental strategy will also perform

better economically. There is growing interest in environmental information on companies, but

investors do not have access to sufficient information. There is an overload on information from

various initiatives which is not comparable.

Policy options should fulfil the need of investors to get reliable, consistent insights in the long-

term green ambitions of companies. Integration of OEF into the Eco-Management and Audit

Scheme (EMAS)3 is not expected to be a game-changer for investors, because EMAS has a low

number of subscribed companies and is voluntary. A new instrument on green claims could make

a difference but this largely depends on how the instrument will be designed.

3 https://ec.europa.eu/environment/emas/

https://ec.europa.eu/environment/emas/

10

3 STAKEHOLDER SURVEY – TARGETED ONLINE CONSULTATION

3.1 Process

Five stakeholder groups were targeted with tailored online surveys in the period 12 November to

18 December 2018. Questions were drafted by the European Commission. Ecofys, a Navigant

company, provided input to the questionnaires and uploaded them to the EUsurvey, the

Commission online tool for consulting stakeholders. Surveys ranged from 22 questions for

investors to 40 questions for businesses. Each survey largely followed the same structure:

Introduction into the topic of PEF/OEF pilot phase as well as potential policy options

Personal information

Future use of the environmental footprint:

Importance on environmental information

Experience with environmental information

Use of PEF and OEF methods

Potential use of PEF and OEF methods for providing environmental information

In total, 223 stakeholders responded to the survey4. The table below shows the number of

respondents per stakeholder group. Businesses are well-represented by 180 respondents. The

other stakeholder groups have a lower number of respondents and it is questionable if these

samples are large enough to be representative. This report provides a detailed analysis of the

results of the businesses survey. All answers of the businesses survey and the other surveys are

included in Annex 1.

Consumers were covered through the public consultation on the product policy framework for the

circular economy contains a section on the Environmental Footprint (info:

http://ec.europa.eu/environment/eussd/smgp/), therefore they were not subject to a specific

targeted consultation. The analysis of the results of that public consultation are available in

chapter 4.

Table 4 Number of respondents per stakeholder group

Stakeholder group Scope Number of

respondents

Business and sectoral/

businesses organisations

Large companies as well as small- and medium-sized

enterprises in Europe and worldwide, including

industry associations

180

Investors/ financial

institutions Financial institutions in Europe and worldwide 5

Method and initiative owners Developers of methods, and organisations behind

private labels and certification schemes 19

Public administrations and

international organisations

Public authorities at European and Member State

level 12

NGO’s NGO’s, other 8

Total 224

4 All contributions from the targeted consultation, exported from the Eusurvey tool, are available for

download at https://ec.europa.eu/environment/eussd/smgp/pdf/Targetedcons_reply_export.zip.

http://ec.europa.eu/environment/eussd/smgp/

https://ec.europa.eu/environment/eussd/smgp/pdf/Targetedcons_reply_export.zip

11

3.2 Analysis of the outcomes of the business and sectoral business

associations survey

3.2.1 General

The questionnaire for Business and Sectoral/ Business Associations was filled in by 180

respondents, mainly representing company or business organisations (55%) and business

associations (37%). The respondents covered both SMEs (56% up to 250 employees) and large

organisations (42% above 250 employees), producing or representing final products (32%),

intermediate products (12%) or both (38%).

Figure 1. Number of respondents by organisation size

The respondents covered a broad range of sectors, including agriculture, apparel & footwear,

chemicals, construction products, electrical & electronics, food & beverages, materials (e.g.

metals, plastics) as well as retail & wholesale. The other category includes the financial sector;

ceramics; personal care (e.g. cosmetics, detergents); paints and coatings; handicrafts; hygiene and

health; packaging, paper and other wood-based products; pet food; automotive; electricity; heat

and gas, services sectors and consultancies.

Figure 2. Number of respondents by sector

Most of the respondents were from the EU (91%), with 3% from the rest of Europe, 3% from

South and North America, and one participant each from Africa, Oceania and Asia.

Micro (1 to 9

employees)27%

Small (10 to 49 employees)

19%Medium (50 to 249 employees)

10%

Large (250 or more employees)

42%

No Answer2%

Number respondents by organisation size

0

2

3

3

15

16

30

33

34

46

46

55

55

0 10 20 30 40 50 60

No Answer

Insurance

Banking

Tourism

Retail & wholesale

Apparel & footwear

Chemicals

Electrical & electronics

Agriculture

Construction products

Materials (e.g. metals, plastics)

Food and beverages

Other

# respondents

Number of respondents by sector

12

The respondents are largely active on the worldwide market (worldwide: 63%, only EU: 23%,

only national: 14%). Almost all companies and organisations have at least one person responsible

for environmental concerns (94%)5 and are member of a sectoral association (72%).

Environmental efforts of companies focus on both the products and the company (66%). For 25%

of the respondents, environmental considerations are the main driver for the business. 20% of

them link remuneration to environmental performance. Over half of the companies know the

environmental performance of their products (61%) and their supply chain (58%) and strive to

improve it. Half of the respondents operate an environmental management system, and 57% has

an environmental policy.

66% of respondents focus environmental efforts on both the products and the company. 8%

focuses on products, and 3% on the company.

As illustrated later in this section on the “Use of PEF and OEF methods”, the largest part of the

respondents was involved in the pilot phase. Companies with varying sizes were represented in

the pilot phase.6. This implies that most companies were familiar with the PEF and OEF methods,

and that the answers may be skewed towards companies that are well-informed.

3.2.2 Importance of environmental information

Respondents stress the importance of environmental information, i.e. companies should apply

environmental criteria when choosing suppliers (78% agree), companies should measure their

environmental performance (91% agree).

However, they also highlight that there are too many methods (72% agree) and labels (76%

agree) for products. A similar picture is observed for corporate methods (54% agree) and

reporting initiatives (53% agree). In addition, about half of the respondents (49%) observe that

there can be insufficient information on the environmental performance of products or

organisations. Respondents think that consumers care more and more for environmental

performance (>80% agree).

Expectations regarding financial institutions (e.g. banks) are less clear: 34% of respondents prefer

to work with financial institutions that have a good environmental reputation, whilst more than

half (55%) are undecided on the subject. 54% say that investors and banks should apply

environmental criteria when deciding where to invest, whilst 41% of respondents are undecided.

The following aspects of environmental information on products are generally considered

important:

Information considering all environmental impacts of the product during its whole life cycle

(very important: 47%; quite important: 35%)

Information directly linked to the product (e.g. environmental impacts of ingredients,

packaging, energy use, etc.) (very important: 29%; quite important: 56%)

The most relevant environmental impacts for the product (very important: 21%; quite

important: 54%)

Production type (e.g. organic, covered by environmental management system) (very

important: 18%; quite important: 48%)

Information pointing to environmentally excellent products (very important: 17%; quite

important: 33%)

5 Micro enterprise: 90%, small enterprise 88%, medium enterprise 100% and large enterprise 97%.

6 Micro enterprise: 78%, small enterprise 73%, medium enterprise 33% and large enterprise 76%.

13

The following aspects of environmental information on products are generally considered as less

important:

Information on single environmental impact issue (e.g. climate change) (not important:

13%; less important: 49%)

Information on the environmental performance of the product in comparison to the

performance of the average product on the EU market (not important: 19%; less important:

28%)

3.2.3 Experience with environmental information

Misleading claims

Many respondents encountered claims that would qualify as misleading (66%), but only a limited

number filed a complaint (6%). The limited number of respondents that filed complaints explains

why statistics do not seem to reflect the significance of misleading claims.

In the respondents’ experience some (56%) or even many (18%) environmental claims are false.

In the 52% more detailed responses, the range given by stakeholders was between 20% and 95%.

Several stakeholder pointed out that it was difficult to quantify the percentage of false claims and

that it depended also on the definition of a false or misleading claim. Stakeholders expected

misleading claims to appear mainly in advertising and among labels, where only labels with a

robust 3rd party verification were considered as reliable. Some pointed out that sometimes claims

could be made more reliable by simply making more information available on the underlying

information – transparency on this is not sufficient.

109 respondents provided details on the types of misleading claims they encountered. We could

distinguish the following topics:

Claims based on comparability of products (e.g. claiming lower impact, incomplete claims,

inconsistent comparisons, basis of comparison chosen in a way to make a product look more

attractive, comparing without an adequate basis for comparison);

Claims of environmental advantages of environmentally “problematic” materials or

products;

Exaggerating the environmental benefits of a solution (e.g. claiming overall negative GHG

emissions for some bio-based materials);

“Pushing” only one specific (at times marginal) impact (e.g. related to packaging) instead of

all or considering the whole supply chain (e.g. declaring that an electric car is “zero CO2

emissions”, as there are emissions during the production of the car and emissions also

depend on the electricity used to recharge the car);

Unauthorised use of logos or certifications (e.g. cradle to cradle);

Claims that hide complex environmental issues or are based on exceptional conditions (e.g.

zero impact, zero waste, CO2 neutral);

Vague and unsubstantiated claims (e.g. ecological product, eco-friendly, save the Earth, all

natural, environment’s friend, environmentally friendly, 100% ecodesigned, green);

Claims with weak scientific basis (e.g. criteria not clearly defined or robust, cannot be

checked, not based on recognised evidence or data from weak or unknown sources);

Claims based on self-declaration or self-certification (e.g. forestry labels issued by

companies) or on private methods without supporting documentation;

Claims of compliance with legislation;

Some specific labels/ initiatives that according to respondents are misleading;

False claims on biodegradability or compostability;

14

False claims on ingredients/ materials (organic, virgin/recycled, “ecological” materials,

absence of a certain substance/ ingredient, whether relevant or not);

Recycling/ recyclability, whilst facilities are not available or only downcycling is possible;

False claims on renewable sourcing of materials;

Incorrect product names, misleading on product ingredients/ composition;

Feeling mislead as there is a too wide variety of different schemes, leading to confusion.

Respondents think that the availability of reliable and comparable environmental information

would trigger more growth on green markets (58% answers yes, 34% does not know).

Furthermore, the view is that companies with a sound environmental strategy will perform better

economically (56% answers yes, 39% does not know). Respondents have a mixed opinion on

whether there is a willingness to pay more for green products if claims are more reliable.

Methods and initiatives used by respondents and motivation

According to the respondents, many sectors have a high growth potential for products with better

environmental performance (see the figure below).

Figure 3. Sectors with highest growth potential for products with better environmental performance

Other sectors quoted by respondents included the innovation business, the transport &

automotive sector, buildings as a whole (rather than individual construction products), hygiene

products, cosmetics, non-woven materials, forest industry, power generation, packaging, the bio-

economy sector. According to some respondents, there is potential in all sectors.

Many respondents experience growing demand from customers (54% for SMEs7 and 72% for

large companies), which they are more or less able to satisfy (44% for SMEs8 and 58% for large

companies). However, some respondents indicate that they have greener products, but not in

sufficient quantities (13%) or that they do not have these products yet (7%).

104 respondents provided examples of requests from their consumers or clients. These included

using the circular economy approach (e.g. demand for refurbished products, circular

economy trade-off calculations);

7 Micro enterprise: 55%, small enterprise 58%, and medium enterprise 44%. 8 Micro enterprise: 45%, small enterprise 42%, and medium enterprise 44%

21

36

44

59

72

81

81

9194

99

99

117

118

0 20 40 60 80 100 120 140

Insurance

Banking

Other

Forestry

Tourism

Apparel & footwear

Retail & wholesale


Chemicals



Food and beverages

Agriculture

# respondents

Sectors with highest growth potential for products with better environmental performance

15

using certification or labels (well-known ecolabels – e.g. EU Ecolabel, Nordic Swan or

compliance letters related to ecolabels; cradle-to-cradle, ISO 14001, EPDs, LEED/BREAM,

TQBuilding, Klima.Aktiv, FSC, PEFC);

increased request for green public procurement;

products with less packaging (lower packaging weight, bulk, refill) or questions regarding

packaging materials and their end of life;

requests regarding specific ingredients (e.g. safe/ benign chemicals, sustainable palm oil,

natural/ plant-based, organic);

products with less emissions (also indoor) or with higher energy efficiency;

eco-friendly alternatives, phasing out of specific materials;

alternatives for synthetic pesticides in agriculture and horticulture, interest in pasture-fed,

non-GMO, pesticide-free products;

recyclability and recycled content;

biodegradable products;

sustainable sourcing – increased awareness of sustainability along the supply chain;

increased demand for LCAs/ EPDs, sometimes with associated with comparative product

assessment (full LCA and EPDs, simplified LCA scores, carbon footprint, share of a

specific life cycle stage in overall impact);

provide more information on environmental and social impact/ sustainability (e.g.

sustainability report, general information on the environment, carbon neutrality, water use,

sustainability profile of product innovations, environmental questionnaires – e.g.

ECOVADIS, more transparency and credibility);

provide full material declarations;

evidence for environmental assets.

55% of the 180 respondents think that their clients are satisfied with the environmental

information they provide; 29% thinks that they are partially satisfied and 1% says clients are not

satisfied. Those replying “partial” or “no” provided information on what clients would like to see

in their opinion. These included a standardised EU label – harmonised information, comparative

information (between products or on the evolution of the performance of a specific product), a

simple impact score, information on general environmental performance, making sure all aspects

are considered and quantified, having the information on more products, full material

declarations, information on biodegradability, toxicity and other product features, EPD-like

approaches.

50% of the 180 respondents report that clients ask questions about the labelled products or the

aspects that the label covers.

The figure below presents the certifications/labels used by respondents (several answers could be

given).

16

Figure 4. Labels most frequently used by respondents

Among other certifications, the following were mentioned:

general/ applicable to all products: cradle-to-cradle, ISO 14001 (environmental management

system), EU Eco-Management and Audit Scheme, ISO 14006 (ecodesign), ISO 2600 (social

responsibility), ISO 14044 (life cycle assessment), EPDs, recycled content declaration,

Austrian Ecolabel, Swiss Ecolabel, Nature Plus, Alliance for Water Stewardship standard,

Ökoprofit, Ecocert;

product-, sector or ingredient-specific: Oekotex Standard, RSPO, PEFC, Biobased Product,

volatile organic compound emission declaration, LEED (green buildings), BREEAM

(sustainability for infrastructures, masterplanning and buildings), EN 15804 (EPDs/

construction), ResponsibleSteel, Concrete Sustainability Council, Sundahus, Dubo Keur,

biofuels environmental standards, AISE charter for Sustainable Cleaning, Natrue

(cosmetics), Cosmebio, Energy Star, EPEAT (green electronics), self-evaluation of the

sustainability of wineries by Bodegas de Argentina, organic, Roundtable on Sustainable

Palm Oil, International Sustainability and Carbon Certification (deforestation-free supply

chains), UTZ (sustainable farming), Paper Profile, NF Environment (furniture).

In terms of the methods used, these include standards (e.g. ISO 14040 - 44, ISO 14045, ISO

14025, ISO 14067, ISO 5001, EN 15804, BXP 30 -323, IEC 62430), other similar methods (e.g.

Water Footprint, Environmental Footprint, energy audits), methods underlying labelling (e.g.

Swiss Ecolabel, cradle-to-cradle, Energy Star), certifications (e.g. FSC, Rainforest Alliance),

reporting methods/ organisation-level tools (Global Reporting Initiative, UN Global Compact

indicators, WBCSD water tool, ISO 14001, EMAS, Ökoprofit, GHG Protocol, Natural Capital

Protocol, Environmental Reporting Guidelines of the Japan Ministry for the Environment,

environmental profit and loss accounts, Sustainability Accounting Standards Board indicators,

CSR reports), rankings (SJSI Robecosam, Corporate Kinghts), indicators internal to the

company.

Out of the 180 responses to this question, 99 report that they are using Life Cycle Assessment

(based on ISO 14044 –LCA, ISO 14025 - EPDs, PEF or undeclared method).

37

45

24

46

18

30 28

75 76

49

0

10

20

30

40

50

60

70

80

17

Initiatives in which respondents participate include:

initiatives based on commitment (e.g. UN Global Compact and CEO Water Mandate,

Science Based Targets, Responsible Care Program for the chemical industry, Dutch Energy

Saving Agreement, RE 100 – renewable energy, climate change levy agreement, VinylPlus),

reporting initiatives (e.g. Carbon Disclosure Project, Global Reporting Initiative, Task Force

on Climate-related Financial Disclosures, Worldsteel Climate Action Programme),

indices (e.g. Ecovadis CSR ratings, Dow Jones Sustainability Index, German Sustainability

Index),

labelling initiatives (e.g. French environmental labelling initiative, Committee for the Blue

Angel),

initiatives by partnerships or platforms

cross-sectoral (Sustainability Consortium, Green Economy Observatory, Forum for

Sustainability through Life Cycle Innovation, World Business Council for Sustainable

Development, SEDEX – responsible supply chains, CE 100 network of the Ellen

MacArthur Foundation, ISEAL alliance, Circular Economy Stakeholder Platform,

Environmental Footprint pilot phase, Sustainable Brands, Net Zero Initiative, Circular

Society, Coalition for Energy Savings, WWF Climate Savers, Responsible Business

Alliance);

sectoral (e.g., Sustainable Apparel Coalition, Global Fashion Agenda, Better Cotton

Initiative, Food SCP Roundtable, FAO LEAP partnership, Sustainable Agriculture

initiative, Palm Oil Innovation Group, Sustainable Palm Oil Forum – FONAP,

Roundtable on Sustainable Palm Oil – RSPO, Bonsucro - better sugar cane initiative,

Dairy Sustainability Framework, Beverage Industrial Environmental Roundtable,

Global Feed LCA Institute, Together for Sustainability – chemical industry, New

Plastics Economy of the Ellen MacArthur Foundation, Global Plastics Alliance, Institut

Bauen und Umwelt e.V., Ecoplatform – construction, EU Circular Economy for

Flexible Packaging, WWF Global Forest & Trade Network, EV100, Responsible

Minerals Initiative).

80 respondents to the questionnaire were individual companies (44%). Among these, most are

using several methods or are involved in several initiatives: 74% uses two or more methods and

51% participates in two or more initiatives.

Figure 5. Number of methods and initiatives used by individual businesses responding to the questionnaire

(colours indicate number of methods or initiatives used, columns indicate number of individual business respondents using a

specific number of methods or initiatives)

2

4

15

12

18

9

15

12

8

5

8 8

45

3

0

2

01

00

2

4

16

0

2

4

6

8

10

12

14

16

18

20

No of methods used No of initiatives used

0 1 2 3 4 5 6 7 8 9 10 n.a.

18

The next question asked respondents to estimate the yearly cost of participating in the initiatives

or using the methods stated. Only a few respondents provided figures. The costs reported ranged

between €5 000 and €2 million. The costs depend on whether companies use several methods or

are partners in several initiatives with membership fees (in some cases membership fees only

amount to €100 000); on the number of products covered; on whether the cost of internal

expertise is covered by the estimate or not; on whether monitoring costs are included (e.g. supply

chain monitoring).

The results of the survey show the variety of certifications/ labels used in this small sample of

businesses.

The reasons for applying the methods or using the initiatives are mainly to improve the

environmental performance of the product or organisation (25% out of 180 responses). The

second most important reason is interest from clients (18%), to show commitment towards

stakeholders (13%) and expected growth in the market of green products (10%). None of the

respondents quoted better management of suppliers or cost reduction as motivations.

Among the other motivations given were a combination of the motivations quoted by the

question (26), client requirements (pre-conditions), company values/ importance of the issue, EU

legislation, to stimulate the harmonisation in measuring environmental performance, to increase

product innovation, as applying the methods are the core business of the respondent.

40% of respondents ask their suppliers for a specific certification, label or method from their

suppliers. 22% asks information but does not specify the required content. Those asking for a

specific approach quote ISO or EN standards (either environmental or sector-specific), other

recognised methods or initiatives (GHG Protocol, water footprint, Carbon Disclosure Project),

compliance with specific sectoral standards, tools or labels (e.g. COTANCE Social &

Environmental standard, Leather Working Group label, OiRA Tannery tool, Bonsucro,

Roundtable for Sustainable Palm Oil, FSC, PEFC, MSC, Ecovadis, organic), environmental

initiatives, certificates or labels (UTZ Certified, Rainforest Alliance Certified, EU Ecolabel,

Nordic Swan, Blue Angel, Swiss Ecolabel, EPDs), compliance with a code of conduct set up by

the company, compliance with minimum requirements, sustainability audits, information on

certifications acquired or sustainability data (e.g. on raw materials, biodegradability, toxicity,

primary data at farm level, LCA data), compliance with specific legislation (e.g. REACH,

RoHS).

24% of SMEs (102 responses) receive information requests form clients. 21% of respondents

produce products with environmental features, and 12% plans to do so.

3.2.4 Use of the PEF and OEF method

The Environmental Footprint pilot phase

The Environmental Footprint pilot phase was in place between 2013-18, with the following

objectives:

to set up and validate the process of the development of product/sector group-specific rules

(Product Environmental Footprint Category Rules – PEFCRs and Organisation

Environmental Footprint Sectoral Rules – OEFSRs, respectively);

to test different compliance and verification systems, in order to set up and validate

proportionate, effective and efficient compliance and verification systems;

to test different business-to-business and business-to-consumer communication vehicles in

collaboration with stakeholders.

19

The role of PEFCRs and OEFSRs is to translate the general rules of PEF and OEF into specific

product group or sector rules. These rules are meant to set methodological choices in a way that

they result in reproducible and consistent calculation results, and, where possible, enable

comparisons between the environmental performance of products or of organisations.

PEFCRs and OEFSRs developed during the pilot phase are available at the link

https://ec.europa.eu/environment/eussd/smgp/PEFCR_OEFSR_en.htm.

Over 72% of the respondents were involved in the PEF or OEF pilot, either as part of the

technical secretariats9 (37%) or as stakeholder (34%). This applies to both SMEs and large

companies. About one third of the respondents10 did already apply the PEF (32%) or OEF

method (2%). Key reasons for this were:

Demonstrating market leadership (73% of respondents that applied or consider applying

PEF/OEF methods);

Expecting EU policies related to the method (84% of respondents that applied or consider

applying PEF/OEF methods);

Supporting a common method for measuring environmental performance (92% of

respondents that applied or consider applying PEF/OEF methods);

Understanding differences with other approaches (73% of respondents that applied or

consider applying PEF/OEF methods).

Other motivations included creating rules for “fair play” and following closely methodology

development.

Respondents that were not involved in the PEF or OEF pilot, were not using the methods for

various reasons, varying from having no PEFCR or OEFSR available (9%) to wanting to wait for

policies (12%) or legislation (6%). The main motivation was already applying another method

(21%). 8% declared that it was not of interest for their company.

Additional reasons for not using the methods included waiting for final results of the pilot phase

to judge if advantageous respectively to currently used methods, having a certification already,

low number of requests for such information, the PEF not being considered a tool for business-to-

consumer communication, considering the method too theoretical, high costs of participation in

the pilot phase.

The following new features of the PEF are considered generally as very useful or quite useful:

Secondary data are available for free to users of the PEFCRs (73%);

PEFCRs list secondary data to be used (67%);

PEFCRs pre-identify most relevant environmental impacts, processes and life cycle stages

for the product group (66%).

Data quality requirements vary based on environmental relevance and access to data (63%);

Primary data gathering is focused on a limited number of specific processes (56%).

The environmental performance of the average product on the market (41%) and the possibility

to compare the Environmental Footprint profile of the product with the benchmark (39%) scored

less high.

9 A group of volunteering businesses and other stakeholders, called Technical Secretariat, developed the

PEFCRs and OEFSRs.

10 Nearly no difference observed among micro (37%), small (36%), medium (11%) and large enterprises

(37%) in the application of PEF and OEF..

https://ec.europa.eu/environment/eussd/smgp/PEFCR_OEFSR_en.htm

20

3.2.5 Potential use of the PEF and OEF methods for providing

environmental information

Providing reliable environmental information

According to the respondents, the Commission (79%), Member States (54%) and the private

sector (87%) should have a large role ensuring the availability of reliable environmental

information on products and organisations. The role of NGOs is considered as less important

(37%).

Among other solutions provided by respondents, we quote the backing of scientific institutions,

governmental organisations of third countries, international organisations (e.g. FAO), EPD/ PEF

programme operators, auditing companies, retailers as first contact points for the consumer and

co-operation between all stakeholders.

The following aspects are considered generally as very important or quite important in providing

reliable, comparable and comprehensive environmental information:

Clear rules on how to develop product group and sector-specific calculation rules (90%);

Product group and sector-specific calculation rules (88%);

Use of a solid verification system (85%);

Requiring the gathering of primary data for specifically defined processes that are most

relevant from an environmental point of view and where primary data can be accessed

(83%);

Availability of common, free average (secondary) data (83%);

Calculation tools enabling non-experts to carry out analysis (62%).

Availability of a benchmark per product group (considered by 42% as very important) and the

availability of a metric that allows to compare companies’ environmental performance within a

sector (considered by 41% as very important) scored less high on this element.

Developing product- and sector-specific rules

Respondents think that the private sector, supervised by the Commission and with input from

stakeholders (36%), or the Commission with input from the private sector and other stakeholders

(20%) are best suited to develop EU-wide product group and sector-specific rules. According to

the respondents, the Commission should bear the costs of providing free average (secondary) data

(57%). Alternatively, it can be co-funded by the Commission and the private sector (21%).

Among other solutions proposed, we quote the ISO, standardisation supervised by the

Commission, trade associations supervised by the Commission and with input from stakeholders

(including Member States and international organisations such as the FAO), not to develop these

at all or leave the decision to business.

According to respondents, the best solution for providing free average (secondary) data to use in

EF measurement would be for the Commission to bear the cost (at least “good” for 79% of

respondents). This is the solution to which 57% of respondents marked “best”. 60% think that co-

funding by the Commission and the private sector would be an at least a good solution, 21%

would see the private sector to do so. Only 8% think that it is not important to provide free

secondary data.

According to 31% of respondents, the Commission should work on specific strategic sectors,

based on a combination of factors (environmental impact and importance to the EU economy).

21

26% chose that the decision should be left to industry and 19% would prioritise based on

environmental impact.

Policy options related to PEF

Part of the actions related to the PEF and OEF method are considered to be effective to trigger

the use of environmental information. For others, the opinions vary. The list below provides the

actions related to the PEF method that could trigger the use of environmental information.

Findings are differentiated for micro, small, medium and large enterprises.

Actions considered generally effective (scoring very effective and effective):

Provide requirements on how to communicate on the Environmental Footprint (it is not

mandatory to communicate environmental information, but if communicated, these have to

comply with specific requirements) (62%, out of which micro 63%; small 48%, medium

50%, large 70%).

The Commission encourages the use of the Environmental Footprint methods for measuring

and communicating environmental information on a voluntary basis (59%, out of which

micro 59%; small 60%, medium 61%, large 58%).

Prescribe the use of the PEF in case communicating environmental information (it is not

mandatory to communicate environmental information, but if communicated, the

information has to rely on the PEF method) (54%, out of which micro 57%; small 39%,

medium 44%, large 59%).

Prescribe the use of the PEF for measuring and communicating life cycle environmental

performance (49%, out of which micro 49%; small 30%, medium 50%, large 54%).

Use the PEF in the development of EU Ecolabel criteria (48%, out of which micro 47%;

small 30%, medium 50%, large 55%).

Use PEF for defining Green Public Procurement criteria (47%, out of which micro 47%;

small 33%, medium 50%, large 53%).

Actions considered generally not effective (scoring not effective) or varying opinions:

Delegate the management of a voluntary Environmental Footprint scheme to a 3rd party

(63%, out of which micro 39%; small 45%, medium 33%, large 36%).

Use PEF benchmarks (performance of the average product) as thresholds to access the EU

Ecolabel scheme (varying opinions, no clear trend observed).

Use PEF information to demonstrate compliance with the EU Taxonomy of Sustainable

Investments11 (varying opinions, 33-42% of the respondents had no opinion across micro,

small, medium and large enterprises).

Use PEF benchmarks as thresholds for accessing Green Public Procurement (medium (50%)

and large (46%) enterprises score high on very effective and effective, while small

enterprises score high on not effective (33%) and micro enterprises score high on no opinion

(35%).

Use PEF information to check the accuracy of environmental claims when applying the

Unfair Commercial Practices Directive (varying opinions).

Create an EU repository of PEF results for products (participation voluntary or mandatory

depending on the policy) (not considered effective by micro (27%) and small (36%)

enterprises, while opinions vary for medium and large enterprises).

Other policy ideas for the use of PEF include awareness raising about PEF, using tax incentives,

focusing on the use of PEF in a business-to-business context on a voluntary basis, refine

11 https://ec.europa.eu/info/business-economy-euro/banking-and-finance/sustainable-finance_en

https://ec.europa.eu/info/business-economy-euro/banking-and-finance/sustainable-finance_en

22

communication-related aspects (e.g. consumer friendliness of impact categories), increase the

robustness of the method, abandon PEF and rely on the ISO standard 14040. Some of the ideas

focussed on a specific sector: to rely on the EN 15804 for construction-related EPDs.

Policy options related to OEF

None of the actions related to the OEF method to trigger the use of environmental information

were considered to be very effective or effective. For most actions, respondents had no opinion

(most often micro and small enterprises) or the opinions varied among respondents (for medium

and large enterprises). The results are summarised below:


and communicating environmental information on a voluntary basis (37% at least effective,

28% at least slightly effective, 36% no opinion). This is the option with the highest

percentage on “very effective”, 19%.

Use OEF indicators in the EU Eco-Management and Audit scheme (EMAS) reporting (high

score on “no opinion” for micro and small enterprises, varying opinions for medium and

large enterprises; 22% at least effective, 11% at least slightly effective, 52% no opinion).

Provide an EU registry of OEF results for companies (participation voluntary or mandatory

depending on the policy) (high score on “no opinion” for micro and small enterprises,

varying opinions for medium and large enterprises; 23% at least effective, 27% at least

slightly effective, 50% no opinion).

Promote more harmonized reporting based on (but not limited to) the OEF for the

environmental pillar of non-financial reporting (high score on “no opinion” for micro and

small enterprises, varying opinions for medium and large enterprises; 21% at least effective,

29% at least slightly effective, 50% no opinion).

Create an EU rating scheme for environmental performance of companies, based on (but not

limited to) the OEF (high score on “no opinion” for micro and small enterprises, considered

not effective by medium (44%) and large (29%) enterprises; overall, 16% at least effective,

34% at least slightly effective, 50% no opinion). This is the option with the highest

percentage on “not effective at all”, 24%.

Delegate the management of a voluntary Environmental Footprint scheme to a 3rd party

(high score on “no opinion” for micro and small enterprises, varying opinions for medium

and large enterprises; 12% at least effective, 45% at least slightly effective, 43% no

opinion).

Measures in favour of SMEs

Small (42%), and medium (50%) enterprises think that micro enterprises should be exempted

from legislative requirements, while micro enterprises (12%) and large enterprises (25%) do not

think so. Micro (76%), small (67%), medium (78%) and large enterprises (68%) agree that

calculation tools for non-experts should be made available. Sectoral and trade organisations

would be best to develop these tools according to micro (8%), small (15%), medium (22%) and

large (22%) enterprises (total scores: 47% at least effective, with 17% considering this the best

solution). The second best solution would be the Commission to develop such tools, according to

micro (35%), small (27%), medium (28%) and large (42%) enterprises (37% at least effective,

with 6% considering this the best solution). Other actors that could have a role in this according

to respondents would be tools developed on a free market and with EC certification; partnership

between the Commission and the private sector or a combination of stakeholders (e.g. public,

business associations and businesses coordinated by the Commission; or led by international

organisations such as the UN or the FAO). One commenter would like to see standardised tools.

23

Among other measures in favour of SMEs, we quote that simplified provisions should apply (e.g.

exemptions from primary data requirements); to make available skilled help/ consultancy and

related financial support; to rely on existing labels. A few comments pointed out that methods

should be user friendly for all companies, including SMEs and pointed out the importance of a

level playing field.

EU Ecolabel and the food sector

21% of respondents would extend the scope of the EU Ecolabel to food, feed and drinks, 19%

would not do so and 60% was unsure.

Among the motivations given for extending the scope, stakeholders mentioned that there was

customer request for this and they were concerned about these sectors, that it would help

consumers’ choice, that it would point to the environmentally sound products, it would help

trigger data transfer along the supply chain, that the agricultural sector influences environmental

impacts considerably, it could strengthen GPP, or because the EU Ecolabel should cover all

sectors and is a credible tool.

Among the motivations given for not extending the scope, stakeholders mentioned that the PEF

score would be enough, that health concerns would need to be the focus, that the EU Ecolabel did

not consider performance, that a label for these sectors should consider sustainability, that

ecolabel schemes are expensive. Some referred back to the decision of the EU Ecolabelling

Board not to cover these product groups.

Among those answering “not sure”, motivations included that the EU Ecolabel did not seem to

provoke high interest, some were unsure about the feasibility from a methodological and

technical point of view (e.g. food is too complex and variable), that they were unsure about the

relationship between the EU Ecolabel and the organic label or afraid that it would create

confusion, that there were too many labels applicable to the sector already, or that the EU

Ecolabel should include LCA results regarding production to enable this enlargement of scope;

that the EU Ecolabel only covers top performers and most of the market remains without a label

to compare products.

Communication requirements

The various communication requirements for products listed are generally considered as

effective, such as:

Mandatory verification (communicating information is voluntary, verification is mandatory)

(60%) (micro 67%, small 48%, medium 50%, large 63% enterprises). This was the option

where the percentage of respondents indicating “very effective” was the highest (22%).

Defining and monitoring compliance with communication principles (53%) (micro 51%,

small 45%, medium 50%, large 59% enterprises).

Encourage to transfer PEF information along the supply chain (e.g. through barcodes) (46%)

(micro 51%, small 30%, medium 44%, large 48% enterprises).

Prescribe a format for communicating to consumers (to use e.g. on a label, on-shelf

information, online etc.) (45%) (micro 41%, small 24%, medium 44%, large 64%

enterprises). This was the option with the second highest percentage of “very effective”

responses (19%), but also the one considered “not effective at all” by the highest share of

respondents (27%).

Among other comments, one stakeholder pointed out that accurate methods and third party

verification would be more important than laws. Another stakeholder argued for prescribing the

24

transfer of PEF information along the supply chain, to allow to take it into consideration instead

of applying a “lowest price” criterion. A few stakeholders found it difficult to provide input on

communication aspects, some of them suggesting that PEF should not be used in such a context.

On products, information should be available on or near the product and online (29%) for micro

(18%), small (27%), medium (44%) and large enterprises (34%).

Figure 6. Opinions on where PEF information should be available

Stakeholder provided further ideas on where the information should be available. According to

some respondents, this should be the responsibility of companies, and that the reply depended

from the product. Other vehicles mentioned were product website, commercial documentation,

EPDs, to take a narrative approach (e.g. report results of measures). A few respondents argued

against labels or expressed a preference to focus on business-to-business communication.

Verification of information is considered to be very important according to the respondents and

would be best done by third-party verification bodies (60% at least moderately agrees) or

Member States (53% at least moderately agrees). The statement “no need for verification, self-

declarations are sufficient” met with the disagreement of 71% of the respondents.

For organisations the prescription of minimum information content, without prescribing the

format was ranked highest (44%). Prescribing a reporting format was judged to be at least

effective by 38% of respondents. A few stakeholders provided additional remarks on

organisation-related communication requirements. They suggested a standardised reporting

format developed by industry and accepted by authorities; that organisations should have the

freedom to decide on what to communicate; to prescribe minimum information content and

format, with detailed information available at request; to use OEF for self-monitoring.

3.2.6 Other comments

3.2.6.1 Additional comments (free text)

70 participants provided additional comments at the closure of the questionnaire.

In general, stakeholders supported the drive for methodological harmonisation. Many of the

commenters expressed their preference for global, rather than EU solutions, pointing to ISO

standards as the way to go ahead.

12

7

27

53

32

23

0

10

20

30

40

50

60

Directly on theproduct

Near theproduct

Online On or near theproduct and

online

Other No opinion

25

Regarding the method, some technical issues were raised, mainly related to environmental impact

assessment methods, calling for globally accepted/ reliable approaches for several impact

categories (especially regarding land use and eco-toxicity). A few stakeholders also pointed to

complexities in the method that would hamper easy application.

There were several contributions from the construction sector. All of them were expressing

support for the use of the revised EN 15804 standard for applying PEF in the construction

industry and they all urged to consider assessment at building, rather than on component level.

The paints sector sees the PEF as a positive development and a better tool for environmentally

friendly consumer choices. Plastic pipes thinks that the method can work for them only if raw

materials are covered by primary data. The automotive industry thinks that LCAs are a good tool

for improvement of environmental performance, but that the complexity of automobiles does not

allow for comparisons between different cars.

Regarding communication, on the one hand, simplicity without over-simplification, on the other

hand relying on existing tools (labelling standards or existing EU labels) were mentioned. A few

commenters pointed out that the effect of EF information on purchasing decisions is still not

proven.

Most of the commenters argued for a voluntary application of the PEF method. In case of a

mandatory application, a few commenters stressed the importance of applying PEFCRs, and the

need of simplicity to enable application by SMEs. Some new policy ideas were raised, including

the use of taxation and fees, enlarging the concept to include economic and social aspects,

including transparency on material content.

A detailed list of the main inputs is provided in Annex 1.

3.2.6.2 Position papers

Stakeholders provided 18 position papers12.

Overall, most position papers appreciated the harmonisation brought by the EF methods, their

contribution to increased transparency and to common rules. The pilot phase was judged to be

useful, but for some of the projects the scope was seen as not satisfactory.

Some of the limitations of the methods were mentioned. Some of the impact categories were not

considered sufficiently mature (mainly toxicity, abiotic resource depletion, land use, water and

biodiversity were cited). Some stakeholders would like to see further issues covered (e.g. plastics

and micro-plastics, infinite recyclability in a closed loop, food waste avoidance, co-product

allocation methods across sectors, etc.). Another limitation cited was uncertainty (and the need to

have a way to assess the uncertainty of PEF studies).

The most appreciated new features brought by the EF methods were the Circular Footprint

Formula (especially by bringing consistency in calculating the environmental benefits of

recycling) and consistency with some international approaches (e.g. FAO LEAP).

There is a call to improve the availability of secondary datasets.

In terms of sector-specific insights, one of the papers stated that for durable and energy intensive

goods PEF brings little added value respectively to the Energy Label, as energy consumption

proves to be the design factor driving performance. For the cosmetics industry, creating an EU

market average would be misleading as performance varies based on ingredients and main

12 Available for download at https://ec.europa.eu/environment/eussd/smgp/pdf/2019_positions_input.zip.

Please note that position papers delivered as “confidential” are not shared.

https://ec.europa.eu/environment/eussd/smgp/pdf/2019_positions_input.zip

26

impacts are in the use stage. The batteries industry calls the attention to the fact that there are

important data gaps for electronics components.

Many of the papers are supporting voluntary use of the method and several argue for internal use

(e.g. for improvement, supply chain management, etc.). Regarding external uses, use in business

to business relations is the most quoted. Some voices support the use of PEF in the context of the

Unfair Commercial Practices Directive, as a means to check the accuracy of environmental

claims, whilst others see it more supporting the EU Ecolabel or EMAS, and in some cases, GPP.

Further ideas for supporting existing policies included the Eco-Design Directive (use PEF in

preparatory studies and for setting minimum requirements), in greening the Common

Agricultural Policy, 2050 long term strategy for a climate neutral Europe, bio-economy strategy

and the Circular Economy action plan.

From the point of view of communication, several stakeholders would like to see flexibility on

the format. Several would like to see rather the improvement of products over time rather than a

comparison of performances. Others see the prescription of a minimum content as useful.

A more detailed listing of the positions is provided in Annex 1.

3.3 Analysis of the outcomes of the investors/ financial institutions survey

3.3.1 General

The questionnaire for investors and financial institutions was filled in by 5 respondents. Out of

these, two were active in banking, one was an asset manager, one insurance and one an

institutional investor. 4 of the respondents were based in Austria and one in Germany; two of

them were active EU-wide (insurance, banking), two internationally (institutional investor and

banking) and one on the national market only (asset manager). The representativeness of the

results for this group of stakeholders is very limited.

Two respondents are aware of Life Cycle Assessment, and two are aware of the Environmental

Footprint methods specifically; one of them followed the pilot phase as a stakeholder.

Respondents had a good knowledge of the issues underlying the questionnaire.


Two respondents strongly agreed that there are too many methods for measuring organisations’

environmental performance; one agreed and one was undecided and one disagreed. Four

respondents agreed that quantified information on environmental performance is insufficient – on

this, the fifth respondent strongly disagreed.

Four respondents prefer to invest in companies with a good environmental reputation. One was

undecided. All respondents agree that

environmental performance in the supply chain is important (3 strongly agree, 2 agree);

the environmental performance of a company’s products are important to judge a company’s

environmental reputation (3 strongly agree, 2 agree);

they expect companies with a sound environmental strategy to perform better economically

(3 strongly agree, 2 agree) and market opportunities for companies producing green

products or services to grow (2 strongly agree, 2 agree and one is undecided);

all companies should measure their environmental performance (3 strongly agree, 2 agree);

investors and banks should apply environmental criteria when deciding where to invest (4

agree, 1 strongly agrees).

27

Regarding the importance of different types of environmental information, respondents deemed

the most important

information directly linked to the organisation (e.g. operations that are owned) (3 very

important, 2 quite important);

information only related to the most relevant environmental impacts (those cumulatively

contributing to 80% of the total impact) (3 very important, 2 quite important);

comparative information based on a common metric (3 very important, 1 quite important, 1

no opinion);

environmental impacts in the supply chain of the organisation (3 very important, 1 quite

important, 1 less important);

information considering environmental impacts generated when producing the company’s

product portfolio (3 quite important, 1 very important, 1 less important).

Respondents assigned less importance to

information on a single environmental issue (1 very important, 2 quite important, 1 less

important and 1 not important).

Regarding different approaches to providing environmental information, the following were

considered the most important by respondents:

a common reporting format on environmental impacts (2 very important, 3 quite important);

environmental information should be available for all companies (2 very important, 3 quite

important);

environmental information should be available on all products (1 very important, 4 quite

important).

Opinions were more diverse regarding the following features:

a single method for measuring environmental performance, applied in the EU (3 very

important, 1 quite important, 1 less important);

compare the environmental performance of products with the same main function (e.g. two

pairs of trousers) (1 very important, 3 quite important, 1 less important);

environmental information should be reproducible (1 very important, 3 quite important, 1

less important).

Less importance was assigned to the fact of having environmental information verified by an

independent 3rd party (2 quite important, 3 less important).


All respondents thought that the availability of reliable, comparable environmental information

would trigger more growth on green markets. Respondents estimated the potential for growth of

different sectors according to the figure below (other corresponds to real estate):

28

Figure 7. Sectors with the highest growth potential for products with better environmental performance

All five respondents require environmental information from companies.

Figure 8. Type of information required from companies

Respondents who indicated more details about the approach used specified that for the

calculation of GHG emissions they required the use of a database (e.g. Ecoinvent), as indices

they used industry-based ones. The “other” approach is a questionnaire, where every supplier or

business partner is requested to answer.

Two respondents use the information for assessing the company’s environmental performance,

one to keep record of it, one to assess whether the company meets the minimum thresholds

conditional to investing. One respondent stated that information was not available, therefore not

used.

The method used by the respondent requiring GHG emission information is based on databases

such as Ecoinvent, including scope 1 and 2 information. The one respondent requiring

performance within a sustainability index relies on industry-based indices.

3

3

3

3

3

3

2

2

2

1

1

1

0

0 1 2 3 4

Agriculture

Apparel & footwear

Chemicals

Food and beverages


Tourism

Banking



Forestry

Insurance

Other

Retail & wholesale

# respondents

4

4

3

2

1

1

1

1

0

0

0 1 2 3 4 5

Existence of an EMS

Environmental or sustainability report

Qualitative: env strategy

Global Reporting Initiative indicators

Environmental credentials on products

GHG emissions

Performance within a sustainability index

Other

Reply to a questionnaire

Life Cycle Assessment indicators

# respondents

29

According to respondents, the following developments are most needed so that environmental

considerations are systematically built into decision-making in the financial sector:

Monetisation of impacts (4 very effective, 1 effective);

Information on the most relevant environmental impacts and processes in a given sector (3

very effective, 2 effective);

Comparable performance results on environmental impacts relevant for a sector (3 very

effective, 2 effective).

3.3.4 Use of the PEF and OEF methods

Two respondents were interested to reply only to questions related to organisations, three

respondents were interested in both organisation and product aspects.

On the question of who should have an important role in ensuring the availability of reliable

information on products and organisations, the European Union (5 very important), Member

States (4 very important, 1 quite important) and rating agencies (input provided under “other”)

were the most important actors, followed by the private sector (4 quite important, 1 less

important) and NGOs (1 quite important, 4 less important).

The elements deemed most necessary for providing reliable, comparable and comprehensive

environmental information were the following:

Clear rules on how to develop product group and sector-specific calculation rules (very

important 3, quite important 2).

Product group and sector-specific rules (very important 2, quite important 3).

Availability of a metric that allows to compare companies’ environmental performance

within a sector (very important 2, quite important 3.

Availability of common, free average (secondary) data (very important 2, quite important 3)

Use of a solid verification system (very important 1, quite important 4).


relevant from an environmental point of view and where primary data can be accessed (quite

important 5).

Opinions were more varied regarding the:

Availability of a benchmark (performance of the average product per product group) (very

important 3, quite important 1, less important 1).

Calculation tools enabling non-experts to carry out the analysis (very important 2, quite

important 1, less important 2).

Respondents think that the Commission should develop product group and sector-specific rules,

with input from the private sector and other stakeholders (chosen as best option by 3 respondents

and as good by 1). The option of development by the private sector, supervised by the

Commission and with input from stakeholders (1 best, 3 good, 1 less appropriate) and

standardisation organisations (2 best, 1 good, 2 less appropriate) are the other solutions deemed

among the best. The least acceptable solution is to leave the development to the private sector

with input from stakeholders (3 good, 3 less appropriate). Industry associations were suggested as

best actor under the heading “other” by one of the respondents.

Respondents think that the cost of providing free average (secondary) data should be borne by the

Commission (4 best, 1 good). The rest of the options were not deemed good by the respondents:

co-funding by the Commission and the private sector (1 good, 4 less appropriate), the private

sector (1 good, 1 less appropriate, 3 worse). The option “it is not important to provide free

average (secondary) data was deemed worse (4 worse, 1 no opinion).

30

The list of actions related to PEF, in order of effectiveness as indicated by participants, is the

following:


and communicating environmental information on a voluntary basis (3 very effective, 2

effective).


Investments (3 very effective, 2 effective).



comply with specific requirements) (2 very effective, 3 effective).


performance (1 very effective, 3 effective, 1 no opinion).

Prescribe the use of the PEF in case communicating environmental information (it is not


information has to rely on the PEF method) (2 very effective, 1 effective, 1 slightly

effective, 1 not effective).

Use the PEF in the development of EU Ecolabel criteria (2 very effective, 2 effective, 1 no

opinion).


Ecolabel scheme (2 very effective, 2 effective, 1 no opinion).

Use PEF for defining Green Public Procurement criteria (1 very effective, 2 effective, 2 no

opinion).

Use PEF benchmarks as thresholds for accessing Green Public Procurement (1 very

effective, 2 effective, 2 no opinion).


depending on the policy) (4 effective, 1 no opinion).


Unfair Commercial Practices Directive (3 effective, 1 slightly effective, 1 no opinion).

Delegate the management of a voluntary Environmental Footprint scheme to a 3rd party (2

effective, 2 slightly effective, 1 not effective).

For the OEF, in order of effectiveness as indicated by participants, is the following:


limited to) the OEF (4 very effective, 1 effective).

Promote more harmonised reporting based on (but not limited to) the OEF for the

environmental pillar of non-financial reporting (3 very effective, 2 effective).


depending on the policy) (2 very effective, 3 effective).




Use OEF indicators in the EU Eco-Management and Audit scheme (EMAS) reporting (1

very effective, 2 effective, 1 slightly effective, 1 no opinion).



All respondents think that prioritisation of sectors should be based on considerations combining

environmental impact and importance for the EU economy.

31

In terms of communication requirements, the following were considered effective (the number of

respondents to this question is 3):

Defining and monitoring compliance with communication principles (2 very effective, 1

effective).

Prescribe the format for communicating to consumers (1 very effective, 2 effective).

Prescribe a format for communicating to business partners (1 very effective, 2 effective).

Fines for breaching communication principles (1 very effective, 1 effective, 1 slightly

effective).

Mandatory verification (2 effective, 1 slightly effective).

Encourage to transfer PEF information along the supply chain (1effective, 1 slightly

effective, 1 no opinion).

Prescribe minimum information content, without prescribing the format (2 slightly effective,

1 not effective).

Opinions on the approach to verifications were varied. The option of giving Member States the

responsibility to monitor that the information communicated complies with the requirements was

the most acceptable to respondents (1 strongly agree, 2 moderately agree, 2 moderately disagree),

followed by verification by an independent third party (3 moderately agree, 2 moderately

disagree). Not providing verification was the least acceptable (1 moderately agree, 2 moderately

disagree, 2 strongly disagree).

In terms of the availability of Environmental Footprint information on products, on or near the

product and online was the most voted option (2 replies out of 3 respondents), followed by only

directly on the product (1 vote).

Communication requirements considered most effective for organisations were:

Focusing on a common method per sector (4 very effective, 1 effective).

Prescribe a reporting format (5 effective).

Prescribe minimum information content, without prescribing the format (3 effective, 2

slightly effective).


No additional comments (free text) or position papers were provided.

3.4 Analysis of the outcomes of the method and initiative owners’ survey

3.4.1 General

This questionnaire was filled in by 19 method/ initiative owners: one investor-led, 5 multi-

stakeholder led, 5 other business-led, 3 standardisation bodies, 3 consultancies, one

Environmental Product Declaration (EPD) programme operator, and one education/ research

facility. Most of the respondents are active at international level (11), four are active at EU level

and four at national level. The organisations were based in the EU (18) or Europe (1). The

number of respondents cannot be considered representative for the whole stakeholder group, but

respondents are varied in terms of the types of initiatives represented.

In terms of the type of methods and initiatives represented, one was investor-led, 5 are multi-

stakeholder led, 5 are other business-led, 3 are standardisation bodies, 3 are tied to consultancies,

one to a programme operator for EPDs, and one to education and research.

32

In terms of the sectors covered, respondents cover comprehensively the following (several

answers were possible):

Figure 9. Sectors covered by respondent methods and initiatives

Most of the respondents were managing methods/ initiatives based on Life Cycle Assessment

(LCA, 18) and Environmental Product Declarations (EPDs, 16). The most covered types of

methods/ initiatives included also product-related information (12), certification (11), multi-

criteria methods/ initiatives (10) and organisation-level reporting (7). The least represented types

of initiatives were single indicator based (4), focussed on best in class products or organisations

(3), company rating schemes (3), non-LCA based including cradle-to-cradle, circular footprint

and additional environmental information (2); and one scheme dealing with CO2 neutrality, and

one with a comprehensive index. From the answers we may conclude that most respondents are

managing several methods/ initiatives.


Most respondents (89%) agree that there are too many labels on the environmental performance

of products, whilst in terms of the number of methods, their opinion is more divided (7

respondents agree, 5 strongly agree, 4 are undecided and 3 disagree).

Opinions are less clear on the number of methods for measuring companies’ environmental

performance: most respondents are more undecided (10 respondents, corresponding to 53% of

replies – 10/53%). On the number of reporting initiatives opinions are varied (1 strongly agrees, 8

agrees, 8 are undecided and 2 disagree).

According to respondents, environmental information is important for market actors. There is

strong agreement on the statement that companies should apply environmental criteria when

choosing their suppliers (13 strongly agree and 6 agree = 100% in agreement). 89% of

respondents strongly agree that companies should measure their environmental performance,

with the rest that agrees with this statement. Investors and banks should apply environmental

criteria when deciding where to invest (84% in agreement, rest undecided). 89% of respondents

agree that consumers care more and more for environmental performance.

In terms of the importance of different types of environmental information on products,

respondents highlighted the importance of the following:


(17/ 89% of replies) very important, 2/ 11% quite important – 100% chose very or quite

important).

15

14

9

9

8

6

6

5

3

3

3

2



Chemicals


Agriculture

Apparel & footwear

Food and beverages

Retail & wholesale

Insurance

Tourism

Other

Banking

33

Information directly linked to the product (17/ 89% respondents chose very or quite

important).

The most relevant environmental impacts for the product (those cumulatively contributing

to 80% of the total impact (16/ 84% chose very important or quite important).

Production type (e.g. organic or covered by an environmental management system; 14/ 74%

of respondents chose very important or quite important).

Information pointing to environmentally excellent products (11/ 57% very important or

important, 3/ 15% less important or not important).

The following options were considered less important or triggered varied answers:


performance of the average product on the EU market (e.g. better, average, worse) (10/ 53%

for less or not important, 8/ 42% for very important or quite important).

Information on a single environmental issue (14/ 74% less important or not important, 5/

26% quite important).


Most respondents encountered environmental claims that were misleading (13/ 68%), but with

one exception, they didn't file a complaint. Almost half of the respondents (9/ 47%) think that

some environmental claims are false and 4 (21%) that many are false, whilst none thinks that

most of the environmental claims are false.

Those that gave details on the type of misleading environmental claims they encountered

mentioned self-declarations (e.g. best in class, x% better without mentioning a reference year),

information focussing on a single or few environmental issues, labels that don’t consider

environmental performance throughout the life cycle, labels that choose the criteria in an

arbitrary/ not science based manner, labels that are not transparent, comparative life cycle

assessment for products that do not have the same function, claims on being organic or

recyclable, vague statements (e.g. green shampoo with vegetable DNA). One respondent

considered that most of the claims are correct, but remain unclear, difficult to understand and/or

to interpret.

The opinion of respondents regarding the percentage of claims that are misleading ranged

between 5% and 80%.

The overwhelming majority (18, 95%) of respondents think that the availability or reliable,

comparable environmental information would trigger more growth on green markets. The

category “other” corresponds to mobility.

16

15

11

11

11

7

7

5

5

5

4

3

3



Agriculture

Food and beverages


Chemicals

Retail & wholesale

Apparel & footwear

Banking

Forestry

Tourism

Insurance

Other

34

Figure 10. Sectors with growth potential (no of answers)

Most respondents experience growing demand for the application of the method or initiative (17,

89%). The number of companies applying the method is variable: 5 are used by less than 100

companies, one more than a hundred, one more than 300, two between 500 and 1000 and three

1000 or more. Companies are typically represented in a scheme through several products.

Most respondents did not wish to provide information on the cost of the method/ initiative. We

have information on the fees related to one of the initiatives (€750), which does not include the

cost of carrying out the LCA; and one that manages access to tools based on a membership fee,

which is variable based on company revenue and starts at $3,000 a year (this fee also does not

include additional costs internally to the company applying the tools).

The purposes for using the method/ initiative indicated by respondents were the following:

Figure 11. Purposes for using methods/ initiatives

Other purposes mentioned by respondents were using it for environmental design and product

innovation purposes (3 answers), for reducing greenhouse gas emissions, to apply EU legislation

related to buildings, for procurement, for assessment schemes and to support science-based

targets.


In terms of respondents’ awareness of the Environmental Footprint methods and related topics,

16 (84%) respondents are aware of LCA, 10 (53%) followed the Environmental Footprint pilot

phase as stakeholders, 6 (32%) were members of a Technical Secretariat during the pilot phase,

and 7 (37%) were aware of the pilot phase but were not involved.

8 respondents (42%) consider to apply the PEF or OEF as a basis for their method or initiative.

Only 3 would not consider to do so, whilst the others are undecided or did not provide a reply.

Respondents deemed the following new features of the PEF method as useful:

Secondary data are available for free to users of Product Environmental Footprint Category

Rules (13/68% very useful, 4/21% quite useful).

Product Environmental Footprint Category Rules list secondary data to be used (10/53%

very useful, 7/37% quite useful).

Product Environmental Footprint Category Rules pre-identify most relevant environmental

impacts, processes and life cycle stages for the product group (6/32% very useful, 8/42%

quite useful).

17

12

11

7

5

4

Communication purposes (on environmentalcredentials of products or organisations)

Enhancing good reputation

Internal performance tracking

Other

Participate in rankings

Get access to investors

35

Primary data gathering is focussed on a limited number of specific processes (6/32% very

useful, 6/32% quite useful).

Data quality requirements vary based on environmental relevance and access to data (6/32%

very useful, 6/32% quite useful).

Features about which respondents’ opinions were varied included:

The environmental performance of the average product on the market (representative

product/ benchmark) is stated in the Product Environmental Footprint Category Rules

(2/11% very useful, 7/37% quite useful, 8/42% neutral, 2/11% less useful);

It is possible to compare the Environmental Footprint profile of the product with the

benchmark (5/26% very useful, 7/37% quite useful, 6/32% neutral).


information on products and organisations, the private sector was deemed the most important (15

very important, 3 quite important, 1 less important), followed by the European Union (9 very

important, 4 quite important, 2 less important). Member States (4 very important, 3 quite

important, 8 less important, 1 not important) and NGOs (2 very important, 4 quite important, 8

less important, 1 not important) were considered least important. Among other actors, European

standardisation organisations, trade organisations, multi-stakeholder initiatives and academia

were mentioned.



Product group and sector-specific calculation rules (95% very important).

Use of a solid verification system (89% very important, 11% quite important).

Clear rules on how to develop product group and sector-specific calculation rules (68% very

important, 26% quite important).

Availability of common, free average (secondary) data (89% very important or quite

important).


within a sector (68% very important or quite important).


relevant from an environmental point of view and where primary data can be accessed (58%

very important, 11% quite important).


Availability of a benchmark per product group (21% very important, 21% quite important,

58% less important).

Calculation tools enabling non-experts to carry out the analysis (16% very important, 21%

quite important, 31% less important, 16% not important).

Respondents think that standardisation organisations are best placed to develop product group

and sector-specific rules (53% best, 26% good, 21% less appropriate). Also the other options are

deemed to be at least good by more than half of the respondents: the private sector with input

from stakeholders (26% best, 37% good, 32% less appropriate); the private sector, supervised by

the Commission and with input from stakeholders (21% best, 32% good, 47% less appropriate);

the Commission, with input from the private sector and other stakeholders (5% best, 47% good,

16% less appropriate, 32% worse). No other actors were suggested.

Respondents think that the cost of providing free average (secondary) data should be borne by the

Commission together with the private sector (68% best, 16% good, 10% less appropriate). The

option of the Commission bearing the cost was considered second best (21% best, 58% good,

16% less appropriate). The option deemed as least appropriate for bearing costs was the private

36

sector (11% best, 16% good, 68% less appropriate). Most respondents think that not providing

such data is the worse option (74% agree with this statement).


following:



comply with specific requirements) (4 very effective, 11 effective, 3 slightly effective, 1 not

effective at all).

Create an EU repository of PEF results for products (9 very effective, 5 effective, 2 slightly

effective, 3 not effective at all).

Prescribe the use of the PEF in case communicating environmental information (7 very

effective, 6 effective, 3 slightly effective, 3 not effective at all).

Use PEF for defining Green Public Procurement criteria (5 very effective, 6 effective, 7

slightly effective, 1 not effective at all).


Unfair Commercial Practices Directive (4 very effective, 6 effective, 3 slightly effective, 2

not effective at all).

Use the PEF in the development of EU Ecolabel criteria (2 very effective, 8 effective, 3



performance (6 very effective, 4 effective, 3 slightly effective, 5 not effective at all).




Investments (1 very effective, 7 effective, 2 slightly effective, 1 not effective at all, 8 no

opinion).


Ecolabel scheme (2 very effective, 6 effective, 5 slightly effective, 3 not effective at all).

The European Commission encourages the use of the Environmental Footprint methods for

measuring and communicating environmental information on a voluntary basis (3 very



very effective, 3 effective, 8 slightly effective, 5 not effective at all).

For the OEF, in order of effectiveness as indicated by participants is the following:


limited to) the OEF (7 very effective, 4 effective, 2 not effective at all, 6 no opinion);


environmental pillar of non-financial reporting (7 very effective, 4 effective, 1 slightly

effective, 2 not effective at all, 5 no opinion);


depending on the policy) (5 very effective, 4 effective, 2 slightly effective, 2 not effective at

all, 6 no opinion);


very effective, 5 effective, 3 slightly effective, 1 not effective at all, 6 no opinion);


measuring and communicating environmental information on a voluntary basis (2 very

effective, 4 effective, 5 slightly effective, 2 not effective at all, 6 no opinion);

37


very effective, 5 effective, 4 slightly effective, 3 not effective at all, 6 no opinion).

One idea was raised in addition to the options listed, suggesting to make EMAS a prerequisite for

publishing OEF information, in particular considering EMAS verification.

Most respondents are unsure whether the scope of the EU Ecolabel should be extended to food,

feed and drinks (12), whilst 5 think that it should be, and 2 think not.

Regarding potential measures to benefit SMEs, most respondents would like to see calculation

tools for non-experts (9 responses). There was no clear indication from respondents as to who

should develop calculation tools, with a slight preference noted for the Commission (26%

choosing best or good) and sectoral/trade associations (26% choosing best or good). Suggestions

for other stakeholder that could step in would be companies with the support of the Commission

or multi-stakeholder initiatives.

8 respondents think there should be no specific provisions for SMEs, whilst two think that micro

companies should be exempted from legislative requirements. An additional suggestion was

made to support SMEs when introducing the method.

Most respondents think that the Commission should work on specific strategic sectors, defined

based on a combination of economic factors and importance for the economy (8 respondents),

followed by the option to leave prioritisation to the industry (6 respondents).

The communication requirements considered most effective for organisations were:


(16 very effective, 2 effective, 1 not effective at all).

Encourage to transfer PEF information along the supply chain (e.g. through barcodes) (7

very effective 9 effective, 1 slightly effective, 1 not effective at all).

Prescribe a format for communicating to business partners (6 very effective, 10 effective, 3

slightly effective).


information, online etc.) (7 very effective, 7 effective, 3 slightly effective, 1 not effective at

all).

Prescribe minimum information content, without prescribing the format (10 very effective, 3

effective, 3 slightly effective, 2 not effective at all).


effective, 4 slightly effective).

Fines for breaching communication principles were considered to be less effective (63%).

Most respondents see independent third parties as the most appropriate actors for verifying

information (84%). The least acceptable solution is not to have verification at all (74%), followed

by monitoring by Member States (63% moderately disagree with this option).


product and online was the most voted option (13 replies), followed by only online (3) and only

directly on the product (2). One respondent suggested that different options should be available

depending on the type of product and the purchaser (e.g. in business-to-business relations

information provided directly on the product is less useful).

For specific communication requirements for organisations, respondents thought that prescribing

a minimum information content was the most effective (8 very effective, 1 slightly effective, 3

not effective at all), followed by prescribing a reporting format (4 very effective, 4 effective, 4

slightly effective, 1 not effective at all). One participant added that only verified and certified

information should be allowed.

38


3.4.5.1 Additional comments (free text)

11 respondents provided additional comments.

In general, the important work of harmonisation, consistency and comparability brought about by

the EF methods was widely recognised.

The main improvements required according to stakeholders were to constantly update and

improve secondary data, with the contribution of stakeholders. For construction products, the

importance of the building level analysis and the use of EN 15804 were pointed out.

On the verification, several stakeholders indicated their preference for the use of the ISO

standards 14025, suggesting that EPD programme operators should manage it.

On the topic of communication, the importance of third party verified information was

highlighted. For the OEF, the synergies with EMAS environmental statements was emphasised.

One stakeholder thought that consumers were ready for decision-making based on holistic

environmental indicators.

One stakeholder suggested to use the PEFCRs as input for prioritising action in other policies

(e.g. trade, extension of the Eco-design Directive to technical standards on material composition

if this is relevant for reducing the EF of a product category).

A more detailed listing of the comments provided is available in Annex 1.

3.4.5.2 Position papers

Stakeholders provided two position papers13.

The papers highlight the importance of LCA-based data for public and private procurement, eco-

design of products and continuous improvement of industrial processes.

For the construction sector, they recommend the use of EN 15804 and emphasise the importance

of building and civil engineering works level. They recommend that verification requirements be

based on ISO 14025 and schemes such as EMAS and to rely on the expertise of existing

verification and certification bodies. Specifically, one paper recommends to consider the paper

“Audit and verification guidelines for ECO EPD Programme operators” and would like to see a

single verification system through the alignment between EPDs and PEF.

3.5 Analysis of the outcomes of the public administrations and international

organisations survey

3.5.1 General

The questionnaire targeted to public administrations and international organisations was filled in

by 12 respondents. Out of these, one came from an international organisation (based in Belgium),

one from a public administration at local level (from Slovakia), one from a public administration




39

at regional level (from Italy) and 9 from public administrations at national level (from Belgium,

Finland, France, Germany, the Netherlands, Sweden, Argentina and Brazil).

Figure 12. Sectors covered by respondents

Most of the respondents were directly involved in the work on the Environmental Footprint (10).

Many of them are active in the EU Ecolabel (7) and Green Public Procurement (7) and Life

Cycle Assessment in policy-making or implementation (7). Some of the respondents are involved

in other ecolabels (2), carbon reporting (3) and environmental, social and governance (ESG)

reporting (4) and on the EU organic label (1).

Examples of activities included participation in PEF pilots, LCA studies, labelling programmes

and related governance bodies, circular economy in Green Public Procurement and a pilot

programme on displaying environmental information with volunteering sectors.


Most respondents agreed strongly (4) or agreed (6) with the statement that there are too many

methods on the environmental performance of products. On the number of labels, 7 respondents

agreed strongly and 4 respondents agreed that there are too many of them, one disagreed.

Regarding methods for measuring the environmental performance of companies, three

respondents strongly agree or agree that there are too many, whilst two are undecided, one

disagrees and one strongly disagrees. The picture is varied respectively to the number of

reporting initiatives, where 5 respondents agree with the statement that there are too many of

them, whilst 5 are undecided, one disagrees and one strongly disagrees.

The majority of respondents agree with the statements:

Companies should measure their environmental performance (10 strongly agrees, 2 agree).

Companies should apply environmental criteria when choosing their suppliers (9 strongly

agrees, 3 agree).

Investors and banks should apply environmental criteria when deciding where to invest (8

strongly agree, 4 agree).

Not enough information is available on the environmental performance of products/

organisations (7 strongly agree, 5 agree).

Consumers care more and more for environmental performance (2 strongly agree, 9 agrees,

1 undecided).

11

5

4

3

2

2

1

1

1

0

0 1 2 3 4 5 6 7 8 9 10 11 12

Environmental policy

Climate policy

Energy policy

Research/ innovation policy

Agriculture

Consumer policy

Financial policy

Industrial/ economic policy

Other

Trade policy

40

Regarding the importance of different types of environmental information, respondents deemed

the most important:


performance of the average product on the EU market (e.g. better, average, worse) (9 very

important, 2 quite important, 1 less important).

Information pointing to environmentally excellent products, so as to choose the best

products (e.g. through ecolabels such as the EU Ecolabel) (8 very important, 3 quite

important, 1 not important).

Information directly linked to the product (e.g. ingredients) (6 very important, 6 quite

important).

Production type (e.g. organic) (6 very important, 4 important, 2 quite important).


(resources, manufacturing, transport, use, waste or recycling, etc.) (5 very important, 4 quite

important, 2 less important).

The most relevant environmental impacts for the product (those cumulatively contributing

to 80% of the total impact) (5 very important, 4 quite important, 3 less important).

Information on a single environmental issue (1 very important, 5 quite important, 5 less

important).

Most respondents have encountered misleading claims (11). 4 have the experience that many

environmental claims are false, and 8 that some of them are false. The examples respondents

gave were cosmetics products, on the biodegradability of plastic packaging (as this is not relevant

for the current methods for waste treatment, 2 respondents); self-labelling without third party

verification (2 respondents); calculations based on life cycle inventory data that were completely

wrong; statements such as 100% natural, eco-friendly, free of CFC; sustainable biofuel and

biomass14. Two respondents pointed out that claims are normally not incorrect, but not

sufficiently comprehensive (talking about one aspect and ignoring other important ones). Another

respondent suggested that enforcing compliance with standards would be the first step. One

respondent estimated that 40% of claims are false or misleading. One of the respondents

regularly produces a report on advertisements and the environment, which identified that 5% of

the claims was false among those examined.

The great majority of respondents (11) think that the availability of reliable, comparable

environmental information would trigger more growth on green markets. They also think (10)

that companies with a sound environmental strategy perform better economically.

14 All contributions from the targeted consultation, exported from the Eusurvey tool, are available for

download at https://ec.europa.eu/environment/eussd/smgp/pdf/Targetedcons_reply_export.zip.

https://ec.europa.eu/environment/eussd/smgp/pdf/Targetedcons_reply_export.zip

41


Under the heading other, a respondent suggested the energy market (electricity and heat).

4 respondents require a specific certification or method or label when requiring environmental

information from suppliers; 3 require environmental information but don’t specify what should

be the content; 4 don’t require environmental information from suppliers. Examples for

certifications and labels required include best class under the EU energy label, FSC or PFC for

wood products, ecolabels (e.g. Blue Angel, EU Ecolabel and type 1 ecolabels); others use the EU

and national GPP guidelines and action plans.

3.5.3 Use of the PEF and OEF method

4 respondents were involved in the EF pilot phase as members of a Technical secretariat, most of

them (7) followed the pilot phase as stakeholders. Three are aware of the Environmental Pilot

phase but were not involved. Most respondents (9) know about Life Cycle Assessment.

Five respondents are consider to apply the PEF or OEF method, whilst 7 did not apply it and

don’t consider to. Among the reasons for not applying (yet) the methods, they quoted the lack of

PEFCRs or OEFSRs for their product/ sector (3), waiting for policies applying the methods (2),

the application of other methods (2) and no interest for the organisation (4).

Respondents deemed the following new features of the PEF method as useful:


Rules (11 very useful, 1 quite useful).


impacts, processes and life cycle stages for the product group (8 very useful, 4 quite useful);


benchmark (8 very useful, 4 quite useful).

Product Environmental Footprint Category Rules list secondary data to be used (6 very

useful, 5 quite useful, 1 neutral).


product/ benchmark) is stated in the Product Environmental Footprint Category Rules (6

very useful, 5 quite useful, 1 neutral).

Primary data gathering is focussed on a limited number of specific processes (4 very useful,

5 quite useful, 3 neutral).

Data quality requirements vary based on environmental relevance and access to data (4 very

useful, 4 quite useful, 4 neutral).

11

10

7

7

7

7

6

5

5

4

2

2

2

Food and beverages

Agriculture

Banking




Apparel & footwear

Chemicals

Tourism

Forestry

Insurance

Retail & wholesale

Other

42


information on products and organisations, the Commission was deemed as most important (12

very important), followed by Member States (11 very important, 1 quite important) and the

private sector (6 very important, 6 quite important). Opinions on the role of NGOs on this subject

were varied (2 very important, 3 quite important, 5 less important, 2 not important). Academia

(2) and research organisations (1) were mentioned as other actors that could play an important

role.



Product group and sector-specific calculation rules (10 very important, 2 quite important).

Availability of common, free average (secondary) data (11 very important, 1 important).

Clear rules on how to develop product group and sector-specific calculation rules (9 very

important, 3 quite important).

Use of a solid verification system (9 very important, 3 quite important).


relevant from an environmental point of view and where primary data can be accessed (8

very important, 4 quite important).

Availability of a benchmark per product group (5 very important, 5 quite important, 2 less

important).


within a sector (4 very important, 6 quite important, 2 less important).

Calculation tools enabling non-experts to carry out the analysis (4 very important, 5 quite

important, 3 less important).

There is no clear preference for who should develop EU-wide product group and sector-specific

rules: most appropriate actors are the Commission, with input from the private sector and other

stakeholders (3 best, 6 good, 2 less appropriate, 1 worse); the private sector, supervised by the

Commission and with input from stakeholders (3 best, 5 good, 3 less appropriate, 1 worse);

followed by standardisation organisations (2 best, 6 good, 3 less appropriate). Respondents

consider the private sector with input from stakeholders as the last appropriate option (1 best, 1

good, 5 less appropriate, 5 worse).

Respondents think that the cost of providing free average (secondary) data should be shared

between the Commission and the private sector (9 best, 2 good, 1 less appropriate). The option of

the Commission bearing this cost was deemed second best (4 best, 5 good, 3 less appropriate).

The least appropriate option was to let the private sector bear the cost (2 best, 3 good, 6 less

appropriate, 1 worse). Most respondents think that not providing such data is the worse option

(10 worse, 2 good).


following:



comply with specific requirements) (5 very effective, 7 effective).

Prescribe the use of the PEF in case communicating environmental information (3 very

effective, 8 effective, 1 slightly effective).


performance (5 very effective, 5 effective, 2 slightly effective).

Use PEF for defining Green Public Procurement criteria (2 very effective, 8 effective, 2 not

effective at all).

43



no opinion).

Use the PEF in the development of EU Ecolabel criteria (3 very effective, 6 effective, 1

slightly effective, 1 not effective at all, 1 no opinion).





all, 4 no opinion).


Investments (2 very effective, 7 effective, 2 slightly effective, 1 not effective at all, 8 no

opinion).


Ecolabel scheme (2 very effective, 4 effective, 5 slightly effective, 1 not effective at all).



effective, 6 slightly effective, 3 not effective at all).


effective, 3 slightly effective, 6 not effective at all, 1 no opinion).

Ideas provided under the heading “other” included to use the PEF as a mandatory label to avoid

that it becomes yet another label. If the PEF label is voluntary, the respondent’s preference would

go to developing the already established labels (e.g. the EU Ecolabel). The respondent called the

attention to the fact that not all environmental claims can be proven through the EF methods.

Another respondent deemed that voluntary labels were a good starting point, but mandatory

measures are probably needed for greening the internal market.

For the OEF, in order of effectiveness as indicated by participants is the following:


environmental pillar of non-financial reporting (1 very effective, 7 effective, 2 slightly

effective, 2 no opinion).


very effective, 7 effective, 2 slightly effective, 2 no opinion).



all, 1 no opinion).





limited to) the OEF (3 very effective, 2 effective, 4 slightly effective, 1 not effective at all, 2

no opinion).



The great majority of respondents (11) think that calculation tools for non-experts are needed to

support SMEs. Two respondents think that micro companies should be exempted from legislative

requirements, one suggests that no specific provisions are necessary. One respondents suggested

that the key measure was that the Commission ensures harmonisation and level playing field.

44

In the opinion of respondents, the Commission is best placed to develop calculation tools (3 best,

7 good, 1 less appropriate, 1 no answer); followed by public administrations coordinated by the

omission (2 best, 4 good, 3 less appropriate, 2 worse) and sectoral/ trade associations (1 best, 5

good, 5 less appropriate, 1 no answer). The least appropriate solution is to leave the development

to individual businesses (2 good, 45 less appropriate, 5 worse, 1 no answer). Among other

solutions, respondents suggested that the Commission in cooperation with research organisations

and sectoral organisations (1), or the Commission in cooperation with sectoral/ trade associations

(1) take up this task, or market actors / individual businesses supervised by of public authorities

(1).

Most respondents (8) think that the Commission should work on specific strategic sectors based

on a combination of factors (environmental impact and importance for the economy). 4

respondents would prefer to prioritise based on potential environmental impact.

Regarding the extension of the EU Ecolabel to food, feed and drinks, answers were varied: 3

respondents suggested to do so, 3 not to go down that route, and 6 were not sure. The motivations

for replying “yes” were to provide the right to consumers to make a choice or to enable covering

products such as biofuels. Those replying “no” motivated the answer by suggesting to extend the

EU organic label with additional criteria (1), or to simply stick with the current organic label,

considering that the main impact, agriculture, was covered by it (1). Those not sure were also

motivated by the existence of the organic label and warned not to trigger competition with it (1),

or by the consideration that there were many labels already, suggesting that harmonisation (1) or

comparison (1) was needed, but that they were not sure that doing this through Ecolabel was the

best choice.

The communication requirements considered most effective for products were:

Encourage to transfer PEF information along the supply chain (e.g. through barcodes) (6

very effective, 5 effective, 1 slightly effective).




(5 very effective, 4 effective, 3 slightly effective).


information, online etc.) (5 very effective, 4 effective, 1 slightly effective, 1 not effective at

all, 1 no opinion).


effective).

Prescribe a format for communicating to business partners (1 very effective, 5 effective, 4

slightly effective, 2 no opinion).

Prescribe minimum information content, without prescribing the format (5 effective, 5


One respondent suggested another solution, namely to adapt the format for communication to

products, sectors and target groups.

Most respondents see independent third parties as the most appropriate actors for verifying

information (6 strongly agree, 6 moderately agree). The least acceptable solution is not to have

verification at all (10 strongly disagree, 2 moderately disagree), followed by monitoring by

Member States (8 strongly agree, 2 moderately agree, 2 moderately disagree).


product and online was the most voted option (5 replies), followed by only directly on the

product (4) and only online (1) and only near the product (1). One respondent suggested that

different options should be available depending on the type of product and the purchaser (e.g. in

45

business-to-business relations information provided directly on the product is less useful). Two

respondents suggested that the information should be on the product and online, considering also

the product and target group. One respondent stressed that many studies concluded that the most

effective way of communicating was on or near the product, with more detailed information

available via barcodes or QR codes.

On specific communication requirements for organisations, respondents thought that prescribing

a reporting format would be most effective (3 very effective, 7 effective, 1 slightly effective, 1 no

opinion); followed by prescribing a minimum information content (1 very effective, 5 effective, 4

slightly effective, 1 not effective at all, 1 no opinion). One respondent suggested that the format

could include minimum mandatory criteria (e.g. an official logo), but remain flexible on other

aspects that could be communicated.


Two respondents provided additional reflections. One emphasised the need to consider the use of

PEF as additional information source for policy instruments across the board (e.g. Eco-design

Directive, food processing). Also, they pointed to environmental impacts that would need to be

covered as additional information (e.g. risks-related aspects with specific limit values,

biodiversity).

The other commenter drew the attention to environmental performance benchmarks and indices

as being important.

Additional thoughts were provided by one stakeholder, the European Environmental Bureau,

with the caveat that this was not to be considered as a position paper15.

The document takes a comprehensive look at the potential future uses of the PEF and OEF

methods. In essence, it recommends to use it

In business-to-business relations (information exchange, supply chain collaboration and

innovation).

In complementing and supporting (not replacing) existing product criteria (e.g. EU Ecolabel,

GPP, minimum product requirements under the Eco-design, complemented by other

additional environmental certification schemes).

In assessing self-declared green claims on produce as a required source of information for

substantiating green claims.

The organisation recommends not to use the PEF for direct communication to consumers, nor to

replace existing product policy criteria. It also warns against applying it too early to sustainable

finance, as they do not consider any of the initiatives mature enough for this purpose. On food,

they warn against confusion with the organic label, whilst they think that PEF could support

information on additional aspects (e.g. packaging of organic produce).

In terms of the process, EEB calls for more diversity of the actors involved, especially for

consumer and environmental organisations. If this is guaranteed, PEF should be obligatory for

placing a product on the EU market belonging to a category covered by a PEFCR and wishing to

communicate environmental claims about it.




46

3.6 Analysis of the outcomes of the NGO survey

3.6.1 General

The questionnaire was filled in by 8 respondents: 3 environmental organisations, 2 associations, 1

NGO, 1 company/business organisation and 1 consumer organisation.

All organisations are based in the EU: 3 in Belgium, 2 in Portugal, 1 in Spain, 1 in Austria and 1

in France. 5 of the organisations are registered in the EU Transparency register. 5 micro (1 to 9

employees) and 3 small (10 to 49 employees) organisations responded to the questionnaire. 4 of

the organisations focus on the environment, 2 on consumers and 2 on wine. 3 of the organisations

are active nationally, 2 locally, 2 EU wide and 1 worldwide.


The respondents stress the importance of environmental information. All respondents agree that

companies should measure their environmental performance.

The vast majority (7 out of 8 respondents) agrees with the statement that there are too many

methods on environmental performance on the market. Most respondents (5) think that there are

too many labels indicating the environmental performance of a product.

The majority (6) agrees that there are too many methods to measure a company’s environmental

performance. Respondents did not agree whether there were too many reporting initiatives on

environmental performance (3 agreed, 3 were undecided and 2 disagreed). The majority (5)

strongly agrees that companies should use environmental criteria when choosing their suppliers.

Half of the respondents (4) were undecided whether there was not enough information on the

environmental performance of a product and organisations. 5 prefer to work with financial

institutions (e.g. banks) that have a good environmental reputation (2 disagree, 1 undecided)

In addition, the majority (5) agrees that investors and banks should take into account

environmental criteria when investing. All respondents agree that consumers will care more and

more for environmental performance.

3 respondents think environmental information linked to a product (i.e. environmental impact of

ingredients, packaging, energy, etc.) is very important. Two think it is quite important and three

less important.

7 respondents find the production type (e.g. organic, covered by environmental management

system) either important or very important. Only 1 found it less important.

Half of the respondents find information considering all environmental impacts of the

product during its whole life cycle very important. The other 4 see it as less important.

The majority (5) finds information on single environmental impact issue (e.g. climate

change) quite important. The remaining three less important.

Half of the respondents find the most relevant environmental impacts for the product quite

important. The other half less important.

Most respondents (6) find the information on the environmental performance of the product

in comparison to the performance of the average product on the EU market less important.

Half of the respondents see information pointing to environmentally excellent products very

important. The rest of the answers were divided.

47


5 out of 8 respondents found encountered environmental claims that were misleading, but none of

them filed a complaint. Personal examples for false green claims were provided by 3

respondents:

Certified organic products that come from other parts of the world and have to travel miles

and miles to arrive to your home;

When information is inaccurate or when it does not provide relevant information to inform

the consumer about the environmental performance of a product/service.

Half of the respondents had the experience that many (4) or some (2) environmental claims are

false.

Respondents think that the availability of reliable and comparable environmental information

would trigger more growth on green markets (5 answered yes, 3 do not know). Furthermore, the

general view is that companies with a sound environmental strategy will perform better

economically (5 answered yes, 3 do not know).

According to the respondents, many sectors have a high growth potential for products with better

environmental performance (see the figure below). Many respondents (6) experience growing

demand for agriculture. In the view of the respondents, the electrical & electronics sector and

also the food & beverages sector profits from better environmental performance. 7 out of 8

respondents indicated that they experience growing demand for greener products.



In terms of respondents’ awareness of the Environmental Footprint methods and related topics, 2

of the respondents were members of one of the Technical Secretariats developing Product

Environmental Footprint Category Rules during the EU Environmental Footprint Pilot phase.

Another 3 followed the EU Environmental Footprint pilot phase as a stakeholder. 2 were aware

about the Environmental Footprint methods, but were not involved. Two respondents indicated

that they knew about the Life Cycle Assessment. Only one respondent was not aware of the

work.

6

5

5

4

4

3

3

2

2

2

2

2

2

0 1 2 3 4 5 6 7

Agriculture


Food & beverages

Banking

Other


Materials (e.g. metal, plastics)

Apparel & footwear

Chemicals

Insurance

Retail & wholesale

Tourism

Forestry

48

Respondents deemed the following new features of the PEF method as useful respectively to the

traditional LCA:


Rules (3 very useful, 3 quite useful, 1 neutral, 1 no answer).

Product Environmental Footprint Category Rules list secondary data to be used (1 very

useful, 4 quite useful, 2 neutral, 1 no answer).


impacts, processes and life cycle stages for the product group (5 quite useful, 2 neutral, 1 no

answer).

Features about which respondents’ opinions were varied included:

Data quality requirements vary based on environmental relevance and access to data (3 quite

useful, 4 neutral, 1 no answer).


product/ benchmark) is stated in the Product Environmental Footprint Category Rules (3

quite useful, 3 less useful, 1 not useful at all, 1 no answer).


benchmark (2 quite useful, 1 neutral, 3 less useful, 1 not useful at all, 1 no answer).

Primary data gathering is focussed on a limited number of specific processes was seen as neutral

by most respondents (5 neutral, 2 less useful, 1 no answer).


information on products and organisations, the European Union and Member States were deemed

the most important, followed by the NGOs and the private sector (both mostly seen as quite

important). Additionally, research institutions and universities were mentioned as very important.



Product group and sector-specific calculation rules (5 very important, 2 quite important, 1

not important).


relevant from an environmental point of view and where primary data can be accessed (5

very important, 2 quite important, 1 not important).

Use of a solid verification system (5 very important, 2 quite important, 1 not important).

Clear rules on how to develop product group and sector-specific calculation rules (4 very

important, 3 quite important, 1 not important).

Availability of common, free average (secondary) data (3 very important, 4 quite important,

1 not important).

Calculation tools enabling non-experts to carry out the analysis (3 very important, 3 quite

important, 1 less important, 1 not important).



within a sector (1 very important, 4 quite important, 3 not important).

Availability of a benchmark per product group (1 very important, 3 quite important, 3 less

important, 1 not important).

Respondents think that the Commission, with input from the private sector and other stakeholders

is best placed to develop product group and sector-specific rules (4 best, 3 good, 1 no answer).

Standardisation organisations were voted to be on the second place (2 best, 2 good, 3 less

appropriate, 1 no opinion). The private sector with input from stakeholders was generally seen as

49

inappropriate (2 good, 5 less appropriate). Nevertheless, the private sector supervised by the

Commission is seen as a better solution (2 good, 3 less appropriate, 2 worse, 1 no opinion). No

other actors were suggested.

Most respondents think that the cost of providing free average (secondary) data should be borne

by the Commission (2 best, 3 good, 2 less appropriate). The option of the Commission bearing

the cost together with the private-sector was considered second best (4 good, 3 less appropriate).

The option deemed as least appropriate for bearing costs was the private sector (1 best, 2 good, 4

less appropriate). Half respondents think that not providing such data is the worse option (4 agree

with this statement). Only two respondents agreed that it was not important whether this data was

free.


following:



not effective at all, 1 no opinion).


performance (4 effective, 3 slightly effective, 1 not effective at all).

Create an EU repository of PEF results for products (1 very effective, 3 effective, 1 slightly


Use the PEF in the development of EU Ecolabel criteria (3 effective, 3 slightly effective, 1


Prescribe the use of the PEF in case communicating environmental information (3 effective,

2 slightly effective, 3 not effective at all).


measuring and communicating environmental information on a voluntary basis (3 effective,

1 slightly effective, 4 not effective at all).

Use PEF for defining Green Public Procurement criteria (1 effective, 3 slightly effective, 1




comply with specific requirements) (1 very effective, 1 effective, 1 slightly effective, 5 not

effective at all).

Use PEF benchmarks as thresholds for accessing Green Public Procurement (2 slightly

effective, 3 not effective at all, 3 no opinion).


slightly effective, 5 not effective at all Use PEF benchmarks (performance of the average

product) as thresholds to access the EU Ecolabel scheme (2 slightly effective, 5 not effective

at all, 1 no opinion).

6 out of 8 respondents had no opinion on the use of PEF information to demonstrate compliance

with the EU Taxonomy of Sustainable Investments.

For actions implementing the OEF, the order of effectiveness as indicated by participants is the

following:


environmental pillar of non-financial reporting (4 effective, 1 slightly effective, 1 not

effective at all, 2 no opinion).



50


and communicating environmental information on a voluntary basis (4 slightly effective, 3



limited to) the OEF (4 slightly effective, 3 not effective at all, 1 no opinion).

The following were considered as not effective at all by half of respondents:




depending on the policy) (1 effective, 4 not effective at all, 3 no opinion);

No other actions were suggested by the respondents.

When it comes to SMEs, half of the respondents think that there should be calculation tools for

non-experts available. The other half thinks that there are no specific provisions necessary for

SMEs. One of the respondents suggested that PEF and OEF shall remain voluntary tools to be

used by companies to improve their EF and to have a common reference to communicate

environmental performance. For SMEs or micro-companies further support shall be developed

but no exemptions would be necessary in this voluntary framework.

When asked who should develop these calculation tools, the Commission was perceived as the

best option (1 best, 3 good, 4 no answer). When it comes to public administrations, the responses

were mixed (2 good, 2 worse, 4 no answers). Sectoral/trade associations were seen as less

appropriate by 3 respondents and as good by 1. In regards to individual businesses, the answers

were mixed (1 good, 3 worse) as also for individual businesses (1 good, 3 worse). No other entity

was suggested by the respondents.

The majority of respondents (5) thinks that the Commission should work on specific strategic

sectors based on a combination of factors (environmental impact and importance for the EU

economy). The majority of respondents (5) are against extending the scope of the EU Ecolabel to

food, feed and drinks.

When asked about the communication requirements related to environmental information,

mandatory verification (communicating information is voluntary, verification is mandatory) was

seen as most effective. (4 very effective, 1 slightly effective, 2 not effective at all, 1 no opinion).

Following communication requirements were generally perceived as effective for the PEF:

Defining and monitoring compliance with communication principles was generally seen as

an effective communication tool (1 very effective, 3 effective, 3 slightly effective, 1 no

opinion).


effective, 2 not effective at all, 1 no opinion).

Prescribing a format for communicating to consumers (to use e.g. on a label, on-shelf

information, online etc.) (1 very effective, 3 effective, 3 not effective at all, 1 non effective).

Prescribing a format for communicating to business partners (1 very effective, 2 effective, 2

slightly effective, 3 no opinion).

Transferring PEF information along the supply chain (e.g. through barcodes) (3 effective, 1


Prescribing minimum information content, without prescribing format (4 slightly effective,

3 not effective at all, 1 no opinion).

When asked which of the following approaches to verification should be used with reference to

information produced based on PEF/OEF methods, the mixed results were received:

51

An independent third party (whose costs are covered by who is producing the information)

should verify the information meets requirements before it is communicated (2 moderately

disagree, 4 strongly agree, 2 no opinion).

Member States should be responsible for monitoring that the information communicated

complies with the requirements (2 moderately disagree, 5, moderately agree, 1 no opinion).

No need for verification, self-declarations are sufficient (4 strongly disagree, 3 moderately

disagree, 1 no opinion).

Half of the respondents (4) suggested that PEF information should be available only online (e.g.

linked to the product with a QR code or barcode). 1 suggested the information to be available

directly on the product. Other suggestions included: a voluntary communication scheme and not

making PEF information available.

Prescribing a reporting format was seen as a more effective communication requirements for

organisations (e.g. companies) (3 effective, 2 not effective, 3 no opinion) than prescribing the

minimum content without prescribing the format (1 effective, 2 slightly effective, 2 not effective,

3 no opinion). No other communication requirement was suggested.

1 respondent stated that they are opposed to direct use of PEF as a consumer label and in favour

of type 1 Ecolabels and certain existing specific labels e.g. organic farming. It is important that

labels are a sign of excellence. Labelling everything with scores would be very confusing to the

consumer, and may bring incorrect information.


As an additional free text comment, one stakeholder commented that they were against the use of

the PEF as a consumer label. The difficulties emphasised are understanding by the consumer,

verification and chances for unfair competition. They prefer existing type I ecolabels and specific

labels such as the organic label and highlight the concept of tying labelling to excellence.

Three stakeholders provided position papers.

The papers recognised the role of PEF in harmonising and streamlining LCA, but called the

attention to some of the limitation and challenges of the methods (e.g. not capturing certain

environmental impacts, especially if those are not covered by LCA indicators, uncertainty in

results, and difficulties of verification). They called for using the methods for internal assessment

and improvement. In terms of external communication, they especially drew the attention to the

risk of damaging other, well-established labels such as the EU Ecolabel and other ISO Type I

labels – and called for using the PEF for supporting these rather than creating competition for

them.

The option of using the PEF for fighting green claims under the Unfair Commercial Practices

Directive was judged positively, with the condition that there are no PEF marks or labels

introduced.

A more detailed listing of the views expressed in the position papers is available in Annex 1.

52

4 ANALYSIS OF THE PUBLIC CONSULTATION

An open consultation took place on a product policy framework for the circular economy

between 29 November 2018 and 24 January 2019. The questionnaire focused on whether and

how EU policies and regulations should promote the circularity of products, including questions

on specific product categories. The questionnaire also sought stakeholder views on specific

aspects related to the Environmental Footprint methods and their potential policy use, including

communication aspects.

The analysis of the results was carried out by Milieu Consulting16. This chapter quotes the

findings related to the Environmental Footprint and related to questions that are relevant for their

potential future policy applications. On the latter, the results were further selected and edited

from an Environmental Footprint perspective.

4.1 Participants in the survey

The public consultation generated a strong interest from a broad range of individuals and

organisations across the EU and beyond. In total, 642 responses were received, four of which

were blank, resulting in 638 responses considered in this analysis.

Figure 15. Distribution of replies by category of stakeholder (n=638)17

Respondents could choose whether to respond to the section of the questionnaire dedicated to the

Environmental Footprint: 291 stakeholders decided to do so. The composition of respondents to

this specific section was the following:

16 Full report:

https://op.europa.eu/en/publication-detail/-/publication/805144ba-6412-11ea-b735-

01aa75ed71a1/language-en/format-PDF/source-122384796

17 Respondents were classified according to six categories. ‘Other’ includes respondents from trade

unions and other types of stakeholders.

https://op.europa.eu/en/publication-detail/-/publication/805144ba-6412-11ea-b735-01aa75ed71a1/language-en/format-PDF/source-122384796

https://op.europa.eu/en/publication-detail/-/publication/805144ba-6412-11ea-b735-01aa75ed71a1/language-en/format-PDF/source-122384796

53

Figure 16. Distribution of replies by category of stakeholder in the section dedicated to the Environmental Footprint (n=291)18

Respondents were asked a range of statements to gauge their level of awareness of

Environmental Footprint methods. A large majority of industry respondents (68%) are aware of

Life Cycle Assessment. Industry respondents are less aware of the EU Environmental Footprint

pilot, with 47% stating that ‘I am aware of the EU Environmental Footprint pilot phase, but was

not involved’ and 36% stating that ‘I (or my organisation) followed the EU Environmental

Footprint pilot phase as a stakeholder’.

Figure 17. Q.4.2: Please select the statement(s) that applies to you (n=288)

18 ‘Other’ includes respondents from trade unions (1) and other types of stakeholders. NGOs include

NGOs, consumer organisations (1) and environmental organisations (1).

Academic/research institution; 8; 3%

Industry; 100; 34%

Citizens; 151; 52%

Public authorities; 10; 3%

NGOs; 16; 6%Others; 6; 2%

54

4.2 Selection of responses to questions relevant to the Environmental

Footprint context

In this chapter, we provide information on responses to a selection of questions that are relevant

to reflections on the environmental footprint, but were part of the general section (no. of

respondents = 638).

4.2.1 Effectiveness of EU product policies – consumption and procurement

An option regarding “ensuring consumers have information on the impacts of products so they

can choose the best environmentally performing products (e.g. energy labelling, EU Ecolabel)”

was presented. 632 stakeholders marked an answer on this option, with 86.2% thinking that this

option was at least somewhat effective (49.1% very effective; 37.2% somewhat effective). Other

options considered most effective were public authorities giving priority to environmental

friendly products when buying products (Green Public Procurement, 89.2% at least somewhat

effective); providing consumers with information on the durability and repairability of products

(85.5% at least somewhat effective); supporting longer product lifetimes through better and

cheaper repair options (83.8% at least somewhat effective); encouraging sharing and reuse of

products (81.9% at least somewhat effective).

Figure 18. Q.4.2: Q1.3: Which of the following approaches do you consider an effective way to achieve the goals described at the

beginning of this section? Consumption/procurement phase (% who stated ‘very effective’ or ‘somewhat effective’)

55

Among the additional stakeholder input regarding the effectiveness of the EU product policy

framework, a great variety of responses were provided. Among these, those directly relevant for

the Environmental Footprint context included “promoting awareness-raising/education

campaigns on the whole lifecycle of products”, “ensuring that the entire value chain is

addressed”, “focusing on environmental performance, quality and solutions rather than on

products (i.e. assessing building level performance in terms of function/solution)”.

4.2.2 Information on products and environmental labelling

This section of the questionnaire (section 2) focused on respondents’ views on the adequacy of

product environmental information, and particularly environmental labelling.

Figure 19. Q2.1: To what extent do you agree with the following statements? (% who stated ‘strongly agree’ or ‘agree’)

56

Question 2.1 asked respondents for their views on the environmental aspects of products,

particularly their views on environmental information. They reported very strong support for

products that can be easily repaired. A large majority of respondents stated that they prefer

products with environmental labels, with 86.5% agreeing or strongly agreeing with the statement,

‘I prefer buying products with labels stating that they perform well in terms of their impact on the

environment’. A similar proportion (83.4%) of respondents agreed that they are willing to pay

more for a product if they can be sure it is more sustainable. There was also strong support for an

EU role in verifying information on product labels. Only 7.6% stated that price is the only aspect

that influences their purchasing.

Notwithstanding this positivity, the responses indicated some areas of concern with products. A

large majority of respondents reported concerns about premature obsolescence of products, with

88% of respondents agreeing with the statement ‘I have the impression producers purposely

make products that do not last long’. A majority of respondents (60%) also reported that they

consider there to be too many different and confusing environmental labels. In terms of trust in

environmental information, respondents are more likely to distrust information provided by

producers themselves than environmental labels.

57

Figure 20. Q2.2: How important is it to you that the following information is made available on products? (% who replied ‘very

important’ or ‘quite important’)

Respondents were also asked how important certain categories of product information are to

them (Question 2.2). Respondents showed very strong support for including information on

products relating to their ingredients and components. There was also strong support (over 80%

of all respondents) for information on: life expectancy of products; recyclability; reparability;

place of manufacture; production type; and the lifecycle environmental impacts of products.

Respondents were asked if they would like more environmental information beyond that

displayed on the product itself (Question 2.5). Just under half of citizens replied ‘yes’ (45%),

which is consistent with the overall response for this statement (39%). This was closely followed

by 32% of citizens who responded with ‘only if it is easily accessible and understandable’. Less

important was the statement, ‘Only if it is provided by organisations independent from the

producer’, with only 20% of citizens preferring this option. These views are consistent with

overall views for these statements.

Figure 21. Q2.5: Would you like to have more environmental information beyond what is displayed on the product itself (e.g.

online)? (n=638)

58

Familiarity with existing labels

The responses clearly indicate that respondents are most familiar with the EU Energy Label, with

almost 90% of respondents in all stakeholder groups responding that they are either very or

somewhat familiar with the label. Respondents were much less familiar with the EU Tyre Label,

with only 28% of all stakeholders reporting familiarity with this label.

Figure 22. Q2.3: Are you familiar with this label? (% who responded ‘very familiar' or 'somewhat familiar')

When asked about their knowledge of different labels, most respondents (88%) expressed

familiarity with the EU Energy label. It should also be noted that while a large percentage of

respondents who answered this question indicated knowledge of the EU Tyre label, a relatively

low proportion (288) of all respondents actually answered this question.

59

Figure 23. Q2.3: Do you know which aspects are covered by this label (% who reported at least some knowledge)

When asked about their preferences for products bearing the selected labels, respondents showed

the most support for products with the EU Energy label.

Figure 24. Q2.3: Would you prefer products with this label?

Question 2.3 (open question) asked respondents to provide any additional reflections on

environmental labels, with 150 taking the opportunity to reply. These responses broadly mirrored

the sentiments reported in Questions 2.1 and 2.3 (closed). For example, a large number of

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comments pointed out that labels can be confusing or difficult to understand, there are too many

of them, and some are not trustworthy. Some additional themes or nuances also emerged:

Labels are not always suited to certain kinds of transactions, such as B2B transactions or

online purchases.

Achieving label certification can be challenging, especially for small producers.

Capturing the full impact of a product on the circular economy can be challenging.

Labels alone are not sufficient to limit environmental impact, and other measures, including

regulation, are also needed.

Labels are considered useful for addressing the environmental impacts of important

products.

Environmental labels can be more effective when they are linked to a tangible benefit for

consumers, such as energy efficiency or durability.

The criteria for labels should be based on robust science.

Concerns about certain specific labels, particularly labels on the sourcing of natural

resources (e.g. RSPO, FSC, MSC), appear to undermine the confidence of some consumers

in all environmental labels.

The questionnaire asked respondents whether, as consumers, they were satisfied with

environmental information on products (Question 2.5). A small minority of respondents (7% of

citizens, 8% of all respondent groups) expressed satisfaction with product environmental

information, with most respondents only partially satisfied or unsatisfied.

Figure 25. Q2.4: As a consumer, are you satisfied with the environmental information on products? (n=585)

Respondents who reported that they were unsatisfied or only partially satisfied were asked to

provide further details of the information they considered lacking, with 377 choosing to reply.

Many responses centred around five central themes:

The environmental information on products is generally insufficient to support consumer

decision-making.

Respondents want more information on certain specific themes.

Information that is provided is too difficult to understand.

Consumers do not generally trust environmental information about products.

There are too many labels and they are too difficult to compare.

A large number of respondents highlighted that information is insufficient to support consumer

decision-making, although these comments were typically rather general. Many considered that

more products and product categories should be labelled, with specific mention made of: textiles;

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food; electrical and electronic equipment (phones, laptops); toys; cosmetics; detergent; and

furniture. A civil society organisation pointed out that there is still lack of information on the

majority of products placed in the market, and there is not a lot of clarity on the applicability of

some labels either.

A significant number of respondents reported that they would like more comprehensive

information on multiple aspects of a product’s environmental credentials. Of these, many

mentioned specific information on:

impact of products over their entire lifecycle, including a product’s lifecycle CO2 emissions

and/or environmental footprint (42 responses);

the appropriate treatment or impact of products in the post-consumer phase, including the

recyclability of products (38 responses);

a product’s expected lifetime and/or durability (26 responses);

the resources used in products, including the source of resources (22 responses);

the impacts of products during the production phase (13 responses);

the social impacts of a product, particularly the labour conditions of workers involved

during its production (12 responses);

environmental impacts of transporting products to retailers and/or consumers (11

responses);

chemical composition of products (8 responses).

Other aspects on which consumers would like further information included: country of

origin/production; microplastics; information about components; impacts during the use-phase

(e.g. energy efficiency); biodegradability; animal welfare; vegan/vegetarian nature of products;

health; safety risks; GMOs in products; packaging; farming methods; and impact on

oceans/fisheries.

A number of respondents reported that information on labels is too difficult to understand and

confusing for consumers:

I find there is not enough information, the information is not clear or the information is confusing

among many products, which is why I think it would be important to clarify this type of

information (citizen).

I do not find it easy to understand what information the label indicates (citizen).

Many times, criteria are not comprehensive or unclear, verification is often dubious (industry).

On the issue of confusing labels, respondents also reported that there are too many labels, making

them difficult to compare. These respondents reported that harmonisation would improve clarity

for consumers. Some supported a single environmental label or score for products, or a ranking

of products, to support comparability of products.

There is a very wide variety of different labels, and many citizens still do not know which label

stands for what standards (citizen).

There are too many labels that seem to be competing with each other (citizen).

There are so many products that a ranking system would be great - or a website with top 10

environmentally friendly product lists hosted by the EU - it would be great if consumers didn't

have to do all the research (citizen).

A simple system that we are all educated on - too many labels and information at present so it's

easier to ignore them all (citizen).

I would like a label that states the impact compared to similar products, highlighting the

ingredients or practices that make this product worse/better than others (e.g. through ‘traffic

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light’ colour coding). This should include ingredients, packaging, production, and transport

(citizen).

A significant minority of responses to the open question focused on the trustworthiness of labels.

These respondents reported that they often do not trust labels or environmental information of

products, and called for transparency in labels.

There's not enough publicity on the way producers are controlled after having acquired the label

(citizen).

Too many ‘greenwashing’ and ‘independent’ labels (citizen).

There are hidden elements to labelling. A product may have an RSPO label on it for example, but

reports show that this may not be 100% accurate as to whether or not the palm oil used in the

product is in fact certified. This diminishes consumer confidence in the label, as producers seem

to look for ways to hide the true impact of their products (citizen).

Lack of trust due to lack of standardisation and calculation methodologies (industry).

We believe that this information is currently only mandatory on some categories of products, and

many products have unverified labels which confuse and mislead consumers. The wide range and

miscellaneous labels contribute to mistrust (civil society).

Other issues were reported by small numbers of respondents:

Education and/or awareness-raising activities are needed to boost consumer literacy of

environmental information.

Labels are not useful for online purchases.

In some cases, information is not available until after purchase (e.g. inside packaging or in

product user manuals).

Labelling is not sufficient to address the environmental impact of products, and regulations

(including product bans) or price signals are also needed.

Environmental Product Declarations (ISO 14025) provide more useful information.

Information requirements should be tailored to specific product categories.

Labels are useful for providing information about products that perform well but more

information is needed about harmful products.

4.2.3 Misleading environmental claims

Respondents were asked whether they had encountered labels or environmental information they

considered misleading (Question 2.6). Almost half (285 of the 579 who answered the question)

replied yes. They were then asked if they had filed a complaint (Question 2.7): around 8%

reported that they had, while over 40% reported that they would have like to make a complaint

but didn’t know how.

When asked to provide details about their experiences with misleading labels and environmental

information, respondents either reiterated their views on the overall reliability of environmental

claims or they focused on issues concerning specific labels, specific types of environmental

claims, or specific types of products.

In terms of concerns about specific types of labels, producers’ or retailers’ own labels were the

labels most frequently cited in experiences with misleading claims. Respondents also mentioned

negative perceptions of other labels, including Member State-specific labels (e.g. the Nordic

Swan or French eco-packaging label).

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Concerns were raised about the RSPO, FSC and MSC labels, with a number of respondents

arguing that these labels create a false impression that palm oil, forest products or fish products

can be harvested sustainably. A number of respondents claimed that organic labelling could also

be misleading, as it may create that the impression that organic products are more sustainable

overall. Finally, some respondents reported that product labels like the CE and Green Dot labels

are often mistaken for ecolabels.

A significant number of respondents reported concerns about vague and misleading

environmental claims, e.g. the use of terms such as ‘natural’, ‘eco’, ‘green’ or ‘sustainable’ on

product packaging.

Some particular themes emerged with respect to environmental issues being misrepresented on

products. Examples included the reliability of claims on the biodegradability of products, with a

small number of respondents experiencing false claims in this respect. Concerns were reported on

claims of recyclability of products, with some respondents claiming that products (or their

packaging) are labelled as recyclable when in fact they cannot be recycled in many locations.

There were also concerns that products labelled as containing recycled content are often mistaken

by consumers to be recyclable.

Respondents reported experiences of misleading environmental claims on:

the chemical composition of products;

the country of origin of products;

animal welfare aspects, including animal testing claims;

the plastic or synthetic content of products.

For specific product categories, a diverse range of products were mentioned, such as food,

cleaning products, toothpaste, packaging, textiles, steel products, bamboo products, lighting, and

green energy.

A very small number of respondents recounted experiences of having made a complaint about

misleading product information or labels, or expanded on their reasons for not making a

complaint. These cases included:

A consumer organisation pursuing an unsuccessful complaint regarding vague

environmental claims.

An NGO testing products against energy use claims and reporting non-compliance to

authorities.

A regulator successfully ensuring that the EU Ecolabel was removed from paper products

that did not meet the criteria.

A citizen reporting a false claim to a professional association, with the result that the

producer was cautioned.

An industry association referring a matter to an Ecolabel competent body.

In a small number of responses, the cost and effort of making a complaint was mentioned as a

barrier to taking action. In a number of more general comments, some respondents spoke of their

impression that there is no legal prohibition against misleading environmental claims.

There are no ;legal’ criteria for using marketing messages that use claims like ‘green’, ‘protects

the environment’ or ‘low CO2 emissions’, so they may not have any meaning (public authority).

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4.3 Opinions on the Environmental Footprint methods

Respondents were asked to rate their level of agreement with a series of statements on what the

Commission should do with the common PEF and OEF methods and the 22 category/sectoral

rules developed during the pilot phase. The majority of industry stakeholders stated that they

would prefer the EU to ‘continue supporting the development of product/sector rules on a

voluntary basis but without any direct application in existing or new policies’, with 69% agreeing

strongly or moderately with this statement. A similar proportion (64%) of industry respondents

agreed strongly or moderately with the EU using ‘the PEF/OEF methods and product/sector

specific rules as common knowledge basis in existing or new policies’. This is consistent with the

overall response of 75% for this statement.

Industry stakeholders were less inclined to agree with statements that the EU should: ‘delegate

the management of a voluntary Organisation Environmental Footprint (OEF) scheme to a 3rd

party’, ‘create an EU rating scheme based on OEF results for companies and organisations’, and

‘delegate the management of a voluntary Product Environmental Footprint (PEF) scheme to a 3rd

party’. Only 11-19% of industry respondents agreed strongly or moderately with these

statements.

16%

40%

23%

20%

75%

66%

29%

69%

19%

11%

64%

45%

7%

24%

26%

25%

84%

83%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90%

Stop the work and leave the eventual implementationof the methods to stakeholders

Continue supporting the development ofproduct/sector rules on a voluntary basis but without

any direct application in existing or new policies

Delegate the management of a voluntary ProductEnvironmental Footprint (PEF) scheme to a 3rd party

Delegate the management of a voluntaryOrganisation Environmental Footprint (OEF) scheme

to a 3rd party

Use the PEF/OEF methods and product/sectorspecific rules as common knowledge basis in existing

or new policies

Review existing policies related to the environmentalperformance of products and/or organisations

making them compliant with the PEF/OEF methods

Overall Industry Citizens

65

Figure 26. Q4.3: What should the Commission do now with the new harmonised PEF and OEF methods and the 22

category/sectoral rules developed during the pilot phase?

Citizens were most interested in ‘providing requirements on how to communicate’, on ‘using the

PEF and OEF methods and product/ sector-specific rules as a common knowledge base in

existing or new policies’ and ‘developing new policies related to the environmental performance

of products and/or organisations compliant with the PEF/OEF methods (e.g. on misleading green

claims and proliferation of environmental labels)’.

4.4 Environmental information on products and organisations

Respondents were asked who should take responsibility for making reliable environmental

information on products and organisations available. The majority of industry stakeholders (88%)

agreed strongly or moderately that it should be companies and their associations who take

responsibility for this role. This is in contrast with overall responses, which strongly or

moderately prefer that the EU take this role (88%). Overall preferences were also higher for

Member States (61%) and NGOs (40%), with industry stakeholders much less inclined to select

these entities, particularly in the case of NGOs (9%).

68%

62%

52%

73%

43%

29%

14%

54%

84%

80%

80%

85%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90%

Develop new policies related to the environmentalperformance of products and/or organisationscompliant with the PEF/OEF methods (e.g. onmisleading green claims and proliferation of

environmental labels)

Create an EU repository of PEF results for products

Create an EU rating scheme based on OEF results forcompanies and organisations

Provide requirements on how to communicate toconsumers, businesses and other stakeholders (e.g.

NGOs) on the Environmental Footprint

Overall Industry Citizens

66

Figure 27. Q4.3: Q4.4: Who should take the responsibility of making reliable environmental information on products and

organisations available?

Question 4.4 also asked respondents to specify who else should be responsible for making

reliable environmental information available for products and organisations. A broad range of

responses were received:

citizens;

consumers;

a system like the Globally Harmonized System of Classification and Labelling of

Chemicals (GHS);

consumer protection organisations;

environmental and economic experts;

a global competent independent body;

media;

producers;

public bodies;

regional states, municipalities or the World Health Organisation (WHO);

research institutes and universities;

scientists/statisticians;

think tanks.

While some respondents defined who the other types of organisations or entities should be, others

took the opportunity to develop their responses to the closed questions. Of these, a common

response across all stakeholder groups was the involvement and collaboration of a combination

of actors with the EU, NGOs or national governments taking the lead. For example, a

considerable number of NGOs and business associations stated that the process should involve

business sectors with the EU leading. EU citizens and business associations preferred either

national governments, NGOs and business associations to take the lead, in close cooperation with

the EU, producers or NGOs.

Sample comments on the responsibility for making reliable environmental information available

for products and organisations

Should not be purely company’s responsibility, all players in the value chain have responsibility

in making reliable environmental information on products available (company/business

organisation).

67

The development of reliable environmental information on products and organisations should be

a multi-stakeholder process, organised and led at EU level (NGO).

Depends on the products/solutions and circumstances but industry should always take the lead

(business association).

Non-profit NGOs, in close collaboration with the EU, that have very strong anti-lobbying

policies/rules (i.e. to prevent lobbying from organisations). I do not believe the EU is very good

at avoiding the influence of lobbyists (EU citizen).

4.5 Providing reliable, comparable and comprehensive environmental

information

Respondents were asked to rate the level of importance for a series of statements related to the

provision of reliable, comparable and comprehensive environmental information. A large

majority rated product group and sector-specific calculation rules (90.6%) and clear rules on how

to develop product group and sector-specific calculation rules (90%) as either very or quite

important. This was closely followed by using a solid verification system (88%) and availability

of common, free average (secondary) data (78.3%). The least important aspect was to do with

calculation tools enabling non-experts to carry out the analysis. A lower share of respondents

(60.9%) rated this aspect as either very or quite important.

There are slight differences in the views between stakeholder groups. Industry was the least

inclined to believe that ‘availability of a metric that allows to compare companies’ environmental

performance within a sector’ is an important factor in providing reliable, comparable and

comprehensive environmental information (38%). Similarly, only 55% of public authorities rated

this aspect as either very or quite important. Industry was also the least inclined to consider the

‘availability of a benchmark product group which allows to determine if a specific product is

performing better or worse than this average’ as very or quite important (42%). Public authorities

provided high scores for most factors, as did civil society organisations, except for the statement

on ‘requiring the gathering of primary (company-specific) data for specifically defined processes

that are most relevant from an environmental point of view and where primary data can be

accessed’. Only 67% of civil society organisations considered this aspect very or quite important.

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Figure 28. Q4.3: Q4.4: Q4.5: How important do you rate the following elements for providing reliable, comparable and

comprehensive environmental information? (% who selected ‘very important’ or ‘quite important’)

4.6 EU-wide product group and sector-specific rules

Respondents were asked to rate who is best suited to develop EU-wide product group and sector-

specific rules. Responses were fairly evenly split, with a slightly higher preference for the

‘European Commission with input from the private sector and other stakeholders’ (33%). This

was closely followed by ‘other’ (30%), ‘standardisation organisations based on EU rules’

(26.7%) and the ‘private sector supervised by the European Commission and with input from

other stakeholders’ (26.4%). The ‘private sector with input from other stakeholders’ (10.4%) had

the lowest score of ‘best’ responses.

These views are consistent across stakeholder groups, with slight variations. Industry was the

least likely to select the ‘European Commission with input from the private sector and other

stakeholders’ (17.3%) and ‘standardisation organisations based on EU rules’ (16.3%). Instead, its

preference tilted more towards the private sector. Of all stakeholders, industry rated ‘the private

sector, supervised by the European Commission and with input from other stakeholders' (41.8%)

and the ‘private sector with input from other stakeholders’ (16.7%) as the best suited. While

public authorities were more inclined to select ‘standardisation organisations based on EU rules’

(40%), citizens (42.8%), civil society organisations (41.7%) and academic and research institutes

69

(37.5%) more often selected ‘the ‘European Commission with input from the private sector and

other stakeholders’ as the best suited.

Figure 29. Q4.3: Q4.4: Q4.5: Who should develop EU-wide product group and sector-specific rules? (% who responded 'best')

Question 4.6 also asked respondents to specify who else should be responsible for developing

EU-wide product group and sector-specific rules. The responses were broad and varied, mirroring

the suggestions provided for Question 4.5:

International Standardization Organisation (ISO);

research institutes that work closely with industry;

independent public bodies in Member States;

scientists and statisticians;

media;

a global independent body;

citizens;

trade associations;

independent consumer associations;

industry associations;

Nobody (as these rules have already been developed by industry).

As with Question 4.4, a common response across all stakeholder groups was the involvement of a

combination of actors in developing EU-wide product group and sector-specific rules. However,

responses differed in terms of who should take the lead. For example, academics prefer the EU,

NGOs and academia develop rules, with input from industry. Business associations and

companies suggested industry or private sector involvement, either in terms of leading the

development of rules or working in close collaboration with international actors such as the EU.

In a small number of cases, business associations suggested that no new rules should be

developed, as methods have already been set by industry. Citizens were more likely to suggest

their involvement in the development of rules in collaboration with NGOs, the EU, academia and

standardisation bodies, with only limited involvement from the private sector.

Sample comments on who should develop EU-wide product group and sector-specific rules

70

All stakeholders should be involved. It should remain the responsibility of companies within a

framework/rules set by the European Commission and taking into account expectations of

relevant stakeholders. It should be developed with companies so as the outcome is implementable

(trade union).

EU-wide product group and sector-specific rules should ideally be set at centralised level by the

European Commission or, alternatively, by a recognised, unbiased standardisation body working

on observing EU product quality frameworks (EU citizen).

There should be dialogue between the EU, the private sector and an international organisation,

such as the FAO (company/business organisation).

Only a public initiative that guarantees full and impartial application by individuals can succeed

and be credible (NGO).

4.7 Strategic sectors for product- or sector-specific calculation rules

Respondents were asked if they believe the European Commission should focus on specific

strategic sectors when developing product or sector-specific calculation rules. Just under half of

respondents replied yes, but their views were divided between those who prefer a combination of

factors (43.5%) and those who prefer the focus to be on potential environmental impact (41.4%).

These views are consistent across groups of stakeholders, with some slight variations. More

citizens (57%) and civil society organisations (47%) selected the European Commission, based

on potential environmental impact, with industry (56%), public authorities (55%) and academic

and research institutes (50%) more likely to select the European Commission, based on a

combination of factors.

Figure 30. Q4.3: Q4.4: Q4.5: Do you think that the European Commission should focus on specific strategic sectors when

developing product or sector-specific calculation rules? (n=278)

Question 4.7 also asked respondents to specify any strategic sector that the European

Commission should focus on. Responses were varied, focusing on a combination of sectors,

industries and - in some cases - substances specific to certain industries. Common examples

included:

technology (mobiles phones and computers);

textiles (apparel and footwear);

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agriculture (animal feed);

transport;

automotive and tyre industry;

tourism;

building materials;

energy;

plastics (single-use; BPA and plastic components);

pesticides;

electrical appliances;

furniture;

steel and metals;

chemicals (new and hazardous);

GMO additives and food in nanotechnologies;

education;

edutainment;

radiating equipment and infrastructures.

Although out of scope, a significant number of comments related to food and drink (packaging)

as a key sector to address, given its impact on the environment. Other comments emphasised that

all products and sectors should be addressed as they all interlink, or the focus should be on

sectors that:

contribute to the most pollution and energy consumption;

are most relevant in transitioning to the circular economy;

have the greatest potential to improve resource efficiency.

Sample comments on strategic sectors that the EC should focus on

Sectors with large carbon footprint, waste processing in relation to transformation to a circular

economy with opportunities for: 1. inhibiting the depletion of natural resources, 2. significant

CO2 reduction. Risk: pressure on phasing out Substances of Very High Concern

(academic/research institute).

European Commission should focus on all products/sectors, sectors may (and indeed) evolve

very fast so they should focus on all sectors because all are potential high-impact sectors and are

interlinked (EU citizen).

I think that such rules should be established successively for all sectors (EU citizen).

Those which have the greatest opportunity to improve resource efficiency (business association).

4.8 Communication requirements related to environmental information for

products and organisations

Respondents were asked to rate the most effective types of communication requirements for

environmental information for products and organisations. The table below shows that a large

majority of respondents (79.4%) believe that ‘defining and monitoring compliance with

transparency, availability and accessibility, reliability, completeness, comparability and clarity’ is

either a very effective or effective communication requirement. This was closely followed by

‘prescribing minimum information content and a format for communicating to consumers, and

one for communicating with business partners’ (68.5%) and ‘fines for breaching any of the

communication principles’ (67.3%). Only 38.5% of respondents believe that ‘prescribing

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minimum information content, without prescribing the format’ is a very effective or effective

communication requirement.

Q4.8: What communication requirements related to environmental information would be most

effective in your opinion for products and organisations?

Very

effective Effective

Not very

effective

Not

effective

at all

No

opinion/don’t

know

Defining and monitoring

compliance with the following

communication principles:

transparency, availability and

accessibility, reliability,

completeness, comparability

and clarity (n=277)

49.5% 30% 4% 6.5% 10.1%

Fines for breaching any of the

communication principles

(n=275)

26.9% 40.4% 9.1% 4.7% 18.9%

Prescribe minimum

information content, without

prescribing the format (n=275)

5.8% 32.7% 34.9% 8.4% 18.2%

Prescribe minimum

information content and a

format for communicating to

consumers, and one for

communicating with business

partners (to use e.g. on a label,

on-shelf information, online, on

product declarations, in

reporting etc.) (n=273)

27.1% 41.4% 10.3% 5.9% 15.4%

Encourage to transfer PEF

information along the supply

chain through barcodes (e.g.

EPR schemes) (n=272)

22.4% 40.1% 7.7% 4% 25.7%

Mandatory verification

(communicating information is

voluntary, verification is

mandatory) (n=267)

31.1% 33% 10.1% 6.7% 19.1%

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Figure 31. Q4.8: What communication requirements related to environmental information would be most effective in your opinion

for products and organisations? (% who responded with ‘very effective’ or ‘effective’)

These views are consistent across stakeholder groups, with slight variations. Only 60% of

industry stakeholders rated ‘defining and monitoring compliance with transparency, availability

and accessibility, reliability, completeness, comparability and clarity’ as very effective or

effective. Compared to other groups of stakeholders, industry tended to give lower scores of

effectiveness across most communication requirements, except for ‘prescribing minimum

information content, without prescribing the format’ (60%) and encouraging ‘to transfer PEF

information along the supply chain through barcodes (49%). Industry (58%) and citizens (47%)

both provided lower scores of effectiveness on prescribing ‘minimum information content and a

format for communicating to consumers, and one for communicating with business partners’. Of

all stakeholders who responded to this question, public authorities gave the lowest scores of

effectiveness for ‘prescribing minimum information content, without prescribing the format’,

with only 18% considering this a very effective or effective communication requirement.

Question 4.8 was followed by an open question that asked respondents to specify any other

communication requirements. Many took the opportunity to elaborate on the replies they gave to

the closed question, with comments focusing on improving existing communication

requirements, correcting gaps or maintaining the status quo. Generally, EU citizens emphasised

the need to make communication requirements consistent and harmonised, to assist with ease of

understanding, e.g. harmonising scores and fines to allow for comparability, or using one

consistent format on the minimum requirements to avoid complexity. A significant number

suggested correcting gaps in the communication between business partners along the value chain,

e.g. using blockchain technology to transfer information. Some citizens and academics suggested

maintaining the status quo by retaining environmental product declarations (EPD) to transfer

information along the value chain, as this is considered the most appropriate tool for B2B (it

offers detailed explanations).

Many prefer to keep all reporting requirements voluntary, as this enable companies to retain

some flexibility in choosing the type of information and channels for communicating information

to consumers, e.g. at or beyond the point of sale, or through online tools or advertising. Others,

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including businesses, suggested that PEF and OEF can only serve as voluntary instruments in

B2B, as the methodology is too complex for comparisons between products.

Other comments by EU citizens suggested aligning communication requirements with ISO

standards, in particular for label type III (environmental product declarations, or EPDs) and

emphasising the importance of transparency by ensuring that environmental claims made about

products are backed up with evidence. Comments by NGOs and academics focused on targeting

information requirements according to audience needs as opposed to using one harmonised

format. They also suggested introducing random checks to verify compliance, in combination

with fines.

Sample comments on communication requirements

As a voluntary scheme, the PEF shall not result in mandatory requirements on the reporting of

information to consumers. Companies shall be granted the freedom to choose the means and

channels (how and where) they find most appropriate to provide environmental information to

consumers – e.g. at the point of sale, beyond the point of sale, via advertising, online tools, just to

mention a few examples (EU citizen).

Show a single environmental score identical for ALL products (EU citizen).

[…] we are in favour of unannounced checks (verification) in combination with high fines in case

of transgressions (NGO).

The Ecodesign Directive and energy labelling legislation already establish a regulation and

labelling system for energy-related products (environmental organisation).

Compulsory comprehensive environmental information to consumers (easy to understand) and

companies (in a more detailed manner - for procurement) (academic/research institution).

Harmonisation is really important to make this work (company/business organisation).

4.9 Availability of environmental footprint information on products

Respondents were asked where information on environmental footprint on products should be

made available. There is a slight preference for this information to be placed directly on the

product (43.2%) rather than making it available online (40.3%). These views are consistent

across stakeholder groups. Public authorities (100%) and industry (87%) are more inclined to

have this information available online. Academic and research institutions are equally divided in

their views, with 88% stating that it should be directly on the product as well as online. Citizens

(89%) and civil society organisations (90%) prefer to have this information directly on the

product.

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Figure 32. Q4.8: Q4.9: Where should Environmental Footprint information on products be made available? (n= 232)

Question 4.9 was followed by an open question that asked respondents to specify any other

communication channels. Comments tended to be mixed and varied. Some were more specific in

defining what the ‘other’ types of channels should be, suggesting, for example, other advertising

channels such as catalogues and leaflets. However, most respondents suggested that it should be a

combination of all or two channels, depending on the type of product and/or target group. For

example, some suggested that it is more appropriate for information on intermediate products to

be online while for end-consumer products it could be both online and on/near the product.

Others suggested that producers should decide where the information should be and they should

avoid placing all information in one place. A small number of companies and business

associations suggested that this information should not be made available to consumers, as it is

complex and will create more confusion in deciding which products to choose.

Sample comments on the availability of environmental footprint information on products

- Online communication (e.g. with a QR code)

- Narrative approach (e.g. ‘the environmental performance is now 20% better because we

changed aspect A’) (business association).

Nowhere. Due to the methodological constraints of the LCA approach, Environmental Footprint

cannot provide sound information to help consumers in choosing an environmentally friendly

product. Among the limitations of the LCA approach are: lack of precision, limited

comparability, difficulty in identifying superior products or omission of relevant environmental

aspects (consumer organisation).

Not all information should nor can be on the product itself. Some visual, summarised info could

be on the product, some additional other information could be made available on the producer

website (access could be facilitated through a QR code on the product). This is already done

today (company/business organisation).

Online. But it is not a suitable tool to communicate to the consumer because it is too complex. It

serves the B2B market (NGO).

4.10 Additional comments on the Environmental Footprint methods

The final question for the section on the Environmental Footprint asked respondents to provide

any further comments, explanations or suggestions relating to particular methods. Most repeated

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comments made earlier in this section and focused on improving the availability and

comparability of environmental information. Some examples include:

Communication on environmental information should ensure it is targeted to the needs of

different end-users and focus on the right information (e.g. how CE is implemented rather

than ‘is recycled’).

Accelerate the introduction of the PEF/ OEF for all sectors.

LCA of products should only focus on key areas of carbon, water, land and materials.

The tool should be voluntary, given that it is not suitable across all goods.

Awareness of environmental footprinting methods should be increased through campaigns,

forums and printed materials.

Use a common methodology that addresses all relevant sector-specific impacts (e.g.

forestry) and can be applied in all Member States.

Restrict benchmarking to finished and end-consumer products only.

Ensure PEF methods build upon or align with previous standards (e.g. ISO 14020+;

EN15804) to avoid duplication (e.g. EPD for construction materials).

Environmental footprinting should only be used in B2B or as a background document for

public administration.

Clarify how the methodology of footprinting is constructed.

Ensure that relevant sectors are consulted on product/sector calculation rules before PED

and OEFs are used in practice.

Provide a holistic view by linking to health and safety footprinting.

PEF and EF methodologies need to be further refined to ensure that criteria are robust and

cover certain environmental impacts (e.g. multiple recycling, littering and avoidance of food

waste).

Sample general comments on the Environmental Footprint methods

It is insufficiently clear what the starting point of the method is. Which elements does it include?

For example, is social inclusion included? This is necessary to be able to understand the results

(academic and research institution).

A single environmental score identical for ALL products allows the setting of priorities between

products and avoids the use of a reference product (EU citizen).

When policy development is required, it is important that PEF is developed for the specific

categories. Close cooperation with the sectors is very important. The calculation rules must be

drawn up in agreement with the sectors (environmental organisation).

Companies are already using a number of metrics to assess impacts of products. Any new tool

will create more burden and may not be the right tool that consumers need to make better

choices (EU citizen).

Make sure the OEF is strongly linked to [the Eco Management and Audit Scheme] EMAS, and

OEF information includes legal compliance information. Use the EMAS verifier approach also

for OEF (company/ business organisation).

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5 CONCLUSIONS

5.1 Synthesis of consultation activities

Input regarding potential future uses of the Environmental Footprint methods was gathered

through various channels:

The final conference of the Environmental Footprint pilot phase (23-25 April 2018);

A stakeholder meeting on potential future policy uses of the Environmental Footprint

methods (26 April 2018);

Targeted online consultation addressed to businesses and business associations, investors

and financial institutions, public administrations and international organisations, NGOs and

method/ initiative owners (12 November -18 December 2018);

A section of the public consultation on a product policy framework for the circular economy

(29 November 2018 - 24 January 2019).

The table below provides an overview of the number of stakeholders participating in the different

consultations:

Table 5 – Number of participants per consultation activity and stakeholder group

Stakeholder

group

Public

consultation

Targeted

consultation

Workshop Final

conference

Businesses and

business

associations

100 180 41 294

Investors d.k. 5 0 1

Public

administrations

and international

organisations

10 12 17 67

Methodology

owners

d.k. 19 d.k 8

NGOs 16 8 12 19

Citizens/

consumers

151 n.a. 1 n.a.

Other 14 0 17 67

Total 291 224 88 456

There were stakeholders that participated in several consultation activities. For the purposes of

this report it is important that a total of 39 respondents replied both to the public consultation and

the targeted consultation. This concerns 14 businesses / business associations, 3 NGOs, 3 public

administrations and 19 citizens.

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5.2 Key policy-related results per consultation

The final conference of the Environmental Footprint pilot phase was held between 23-25 April

2018 (492 participants). During the conference, several stakeholders expressed strong support for

the work done, and several industry sectors expressed their intention to start implementing the

PEFCRs and OEFSRs as soon as possible.

Many participants voiced their support for using the methods in the context of the Sustainable

Finance Action Plan, and in existing tools such as the EU Ecolabel, EMAS, Green Public

Procurement and the Unfair Commercial Practices Directive19.

In terms of future actions, an overwhelming majority of participants at the conference expressed

support for requiring the use of PEF for substantiating green claims – under such a scenario, there

would be no obligation to make environmental claims on products, but if a company wishes to do

so, they would need to use the PEF method to prove their claim.

A stakeholder meeting was held on the 26 April 2018 to further explore the views of

stakeholders on the future use of the methods. Whilst some participants argued that after the

efforts invested by businesses and other stakeholders in the pilot phase, a business as usual

scenario would not be acceptable, other participants thought that further development of the

method would be needed for the more ambitious policy applications.

Stakeholders saw added value in using the methods in existing instruments, especially the EU

Ecolabel, and most participants were favourable to using the PEF for substantiating

environmental claims made on a voluntary basis. Stakeholders raised that it would be

necessary to combine the integration of the methods in existing tools with an instrument for

using PEF for supporting environmental claims.

An online public consultation was open between 29 November 2018 and 24 January 2019.

Respondents considered that the most promising policy applications for the PEF and OEF

methods were to

use the PEF/OEF methods and product/sector specific rules as common knowledge basis in

existing or new policies (e.g. to support the development of EU Ecolabel criteria, Green

Public Procurement criteria, Sustainable Finance, Eco-management and Audit scheme, etc)

(75% thinks this would be very effective or effective);

provide requirements on how to communicate to consumers, businesses and other

stakeholders (e.g. NGOs) on the Environmental Footprint (73% thinks this would be very

effective or effective);

develop new policies related to the environmental performance of products and/or

organisations compliant with the PEF/OEF methods (e.g. on misleading green claims and

proliferation of environmental labels) (68% thinks it would be very effective or effective);

review existing policies related to the environmental performance of products and/or

organisations making them compliant with the PEF/OEF methods (66% thinks this would be

very effective or effective);

create an EU repository of PEF results for products (62% thinks this would be very effective

or effective);

create an EU rating scheme based on OEF results for companies and organisations (52%

thinks this would be very effective or effective).

Targeted online consultations were organised focussing specifically on the potential future uses

for the Environmental Footprint methods. They were developed for businesses and business

19 https://ec.europa.eu/info/law/law-topic/consumers/unfair-commercial-practices-law/unfair-

commercial-practices-directive_en

https://ec.europa.eu/info/law/law-topic/consumers/unfair-commercial-practices-law/unfair-commercial-practices-directive_en

https://ec.europa.eu/info/law/law-topic/consumers/unfair-commercial-practices-law/unfair-commercial-practices-directive_en

79

associations, investors and financial institutions, public administrations, NGOs and method/

initiative owners. Targeted consultations were open between 13 November and 18 December

2018. A total of 223 stakeholders replied to the questionnaire. Businesses and sectoral or business

organisations were the most represented (81%), followed by method and initiative owners (9%),

public administrations and international organisations (5%), NGOs (4%) and investors or

financial institutions (2%).

Respondents considered that the most promising policy applications for the PEF method were to:

provide requirements on how to communicate on the Environmental Footprint (it is not


comply with specific requirements)(65% thinks it would be very effective or effective);

prescribe the use of the PEF in case communicating environmental information (it is not


information has to rely on the PEF method) (57% thinks it would be very effective or

effective);

the Commission encourages the use of the Environmental Footprint methods for measuring

and communicating environmental information on a voluntary basis (56% thinks it would be


prescribe the use of the PEF for measuring and communicating life cycle environmental

performance (52% thinks it would be very effective or effective);

use the PEF in the development of EU Ecolabel criteria (50% thinks it would be very

effective or effective);

use PEF for defining Green Public Procurement criteria (49% thinks it would be very

effective or effective).

The most promising option with businesses and business organisations was the same as that of

the overall results (62%), however, the second most preferred option would be that the

Commission encourage the use of the methods (59%), followed by the prescription of the use of

PEF in case communicating environmental information (54%).

For investors and financial institutions, the most promising options are that of providing

requirements on how to communicate on the Environmental Footprint (100%), encouraging the

use of the methods (100%) and using PEF information to demonstrate compliance with the EU

taxonomy of sustainable investments (100%).

For public administrations, the most promising options remains that of providing requirements on

how to communicate on the Environmental Footprint (100%), followed by the prescription of the

use of PEF in case communicating environmental information (92%) and by the prescription of

the use of PEF for measuring and communicating life cycle environmental performance (83%).

For NGOs, the most promising options are that of prescribing the use of PEF for measuring and

communicating life cycle environmental performance (50%), the creation of an EU repository of

PEF products for products (50%) and the use of PEF information for checking the accuracy of

environmental claims when applying the Unfair Commercial Practices Directive (50%).

For method and initiative owners, the most promising option remains that of providing

requirements on how to communicate on the Environmental Footprint (79%), followed by the

creation of an EU repository of PEF products for products (74%) and by the prescription of the

use of PEF in case communicating environmental information (68%).

Respondents considered that the most promising policy applications for the OEF method were to:

the Commission encourages the use of the Environmental Footprint methods for measuring

and communicating environmental information on a voluntary basis (36% thinks it would be


80

promote more harmonised reporting based on (but not limited to) the OEF for the

environmental pillar of non-financial reporting (29% thinks it would be very effective or

effective);

provide an EU registry of OEF results for companies (participation voluntary or mandatory

depending on the policy) (28% thinks it would be very effective or effective);

Use OEF indicators in the EU Eco-Management and Audit scheme (EMAS) reporting (27%

thinks it would be very effective or effective).

Other policy options polled were to create an EU rating scheme for environmental performance

of companies, based on (but not limited to) the OEF (22%) and to delegate the management of a

voluntary Environmental Footprint scheme to a 3rd party (13%).

The most promising policy option with businesses and business organisations was that of

encouraging the use of the OEF for communicating environmental information on a voluntary

basis (36%), followed by the EU registry of OEF results for companies (23%) and the use of OEF

indicators in the EMAS (22%).

For investors and financial institutions, the most promising options are that of providing an EU

registry of OEF results for companies (100%), to promote more harmonised reporting based on

(but not limited to) OEF for the environmental pillar of non-financial reporting (100%) and to

create an EU rating scheme for the environmental performance of companies based (but not

limited to) the OEF (100%).

For public administrations, the most promising options are to promote more harmonised

reporting based on (but not limited to) OEF for the environmental pillar of non-financial

reporting (67%), to use OEF indicators in the EMAS (67%), followed by the provision of an EU

registry of OEF results for companies (50%).

For NGOs, the most promising option is to promote more harmonised reporting based on (but not

limited to) OEF for the environmental pillar of non-financial reporting (50%), followed by the

use of OEF indicators in EMAS reporting (13%) and the provision of an EU registry of OEF

results for companies (13%).

For method and initiative owners, the most promising policy options were to promote more

harmonised reporting based on (but not limited to) OEF for the environmental pillar of non-

financial reporting (58%) and to create an EU rating scheme for the environmental performance

of companies based (but not limited to) the OEF (58%), followed by using OEF indicators in

EMAS reporting (47%).

5.3 Synthesis of outcomes from all consultations20

5.3.1 On environmental information

Taking the results of the public consultation and of the targeted consultations, most respondents

at least agree with the statement that there are too many labels on the environmental performance

of products on the market (average of 70% at least in agreement), resulting in confusing

information. Participants to the stakeholder workshop also confirmed this finding.

The targeted consultations also enquired about the proliferation of methods for products (73% of

respondents see it as a problem) and for organisations (53% in agreement); and on reporting

20 Figures reflect the results of the public consultation and targeted consultations. Qualitative results

from the stakeholder workshop and final conference are added where appropriate.

81

initiatives (52% in agreement). The proliferation of methods was one of the reasons quoted for

feeling misled by environmental claims.

Respondents to the public consultation overwhelmingly prefer to buy products with labels stating

the environmental performance of products (89%). They declared that they mostly trust

information on environmental labels (72% average), which stands true also for citizens

responding to the consultation (74%). However, they have less trust in information provided by

producers themselves (46% respondents to the public consultation).

On average, most respondents to all consultations already encountered misleading claims (56%),

out of which only very few introduced a complaint (4%). The limited number of respondents that

filed complaints explains why statistics do not seem to reflect the significance of misleading

claims.

Among the information types, respondents to all consultations had the highest preference for

receiving information on production type (e.g. organic or made by a company that has an

environmental management system; 82% on average considered this information at least

important), followed by information on the whole life cycle of the product (80%) and

environmentally excellent products (e.g. similar to the EU Ecolabel, 76%). Communicating on a

single issue, e.g. on climate change, was considered at least important by more than half of

respondents (54%); comparisons to the average were thought important for 59% of respondents

to all consultations. For citizens, most important information elements were information on

ingredients/ components (96% considered it at least important, responding to the public

consultation); how and where the product and its components can be recycled (94%), information

on the life expectancy of a product (93%) and information on the environmental impacts of the

product during its whole life cycle (91%).

Respondents to the targeted consultations expected that more reliable information would trigger

more growth on green markets (81%). Businesses confirmed that they experience growing

demand for green products (61%).

5.3.2 On the use of environmental methods and initiatives

42% of respondents to the public consultation were at least aware of the Environmental Footprint

initiative, and 39% of them had knowledge on life cycle assessment. Among respondents to the

targeted consultation, LCA knowledge was higher (61%), 24% of respondents were actively

involved in the pilot phase and 35% was aware of the Environmental Footprint initiative.

Respondents to the consultation targeted to businesses reported using a wide variety of

certifications, labels and initiatives. Out of the 180 responses to this question, 99 report that they

are using Life Cycle Assessment (based on ISO 14044 –LCA, ISO 14025 - EPDs, PEF or

undeclared method). Among individual businesses responding, 74% uses two or more methods

and 51% participates in two or more initiatives. 40% of respondents ask their suppliers for a

specific certification, label or method from their suppliers. In line with this finding, most

methodology owners experience growing demand for the application of the method or initiative

they manage (89%). Also, all investors replying to the questionnaire require environmental

information from companies, which then they use for assessing the environmental performance

of their own portfolios, to invest in companies performing above a certain threshold or to keep

record of it.

Only a few respondents provided information on the cost of using methods or participating in

initiatives: these ranged between €5 000 and €2 million. The costs depend on whether companies

use several methods or are partners in several initiatives with membership fees (in some cases

membership fees only already amount to €100 000); on the number of products covered; on

82

whether the cost of internal expertise is covered by the estimate or not; on whether monitoring

costs are included (e.g. supply chain monitoring).

The targeted questionnaire explored which were the distinctive features of the Environmental

Footprint methods that were considered most useful: the provision of secondary data was the

most important for several stakeholder groups (73% of businesses, 89% of methodology owners

100% of public administrations and 75% of NGOs replying); that PEFCRs list the secondary data

to be used (67% of businesses, 90% of methodology owners, 92% of public administrations and

63% of NGOs); and that PEFCRs pre-identify the most relevant environmental impacts,

processes and life cycle stages for the given product category (66% of businesses, 74% of

methodology owners, 100% of public administrations and 63% of NGOs responding) and that

data quality requirements vary based on the environmental relevance and access to data (63% of

businesses, 64% of methodology owners, 64% of public administrations and 38% of NGOs).

In providing more detailed input, several stakeholders appreciated the methodological

harmonisation, increased consistency, comparability and transparency brought by the

Environmental Footprint methods. Several stressed that due to the international nature of supply

chains, international harmonisation would be needed and appreciated alignment with

international frameworks (e.g. the FAO LEAP initiative).

Some stakeholders pointed out the need to reduce methodological complexity – whilst others

would like to see further environmental issues included in the methods (e.g. microplastics,

allocation to co-products across sectors, etc), or to enlarge them to all pillars of sustainability

(including social, economic and environmental impacts). Some stakeholders would like to see

improvements to the currently considered impacts (e.g. on toxicity, biodiversity, resource use –

minerals and metals, land us and water);

Several stakeholders called for improving the availability and quality of secondary (average)

datasets and their regular update.

The top preference of different stakeholder groups for developing PEFCRs was for the

Commission to take lead, gathering the input from the private sector and other stakeholders (66%

of respondents to the targeted consultation and 67% of respondents to the public consultation

thought it at least a good solution), followed by standardisation organisations (60% of the

targeted consultation and 63% of the public consultation respondents) and the private sector,

supervised by the Commission and with input from stakeholders (58% of targeted consultation

and of the public consultation respondents).

5.3.3 On policy options

Considering the input from all events and questionnaires, stakeholders who replied to these

consultations expressed most support for using PEF by providing requirements on how to

communicate on the Environmental Footprint (it is not mandatory to communicate environmental

information, but if communicated, these have to comply with specific requirements), considered

at least effective by 84.6% of citizens responding to the public consultation, 73% of all

participants to the public consultation; 62% of businesses, 79% of methodology owners, 100% of

public administrations and investors, 25% of NGOs responding to the targeted consultations).

The second most preferred action was to use PEF for new policy, including for the substantiation

of environmental claims where making claims is voluntary, substantiating with PEF is mandatory

(considered at least effective by 84% of citizens responding to the public consultation, 73% of all

respondents to the public consultation; and 54% of businesses, 79% of methodology owners,

92% of public administrations, 60% of investors, 38% of NGOs responding to the targeted

83

consultation). This option was considered important by participants in the final conference and

the stakeholder workshop as well.

The following most preferred actions were the repository of PEF results (80% of citizens

responding to the public consultation, 62% of all respondents to the public consultation; 34% of

business, 74% of methodology owners, 75% of public administrations, 80% of investors and 50%

of NGOs responding to the targeted consultation); and using the Environmental Footprint

methods in support of existing instruments, as a common knowledge basis (EU Ecolabel, Green

Public Procurement, Unfair Commercial Practices Directive and EMAS; considered at least

effective by 84% of citizens responding to the public consultation, 75% of all respondents to the

public consultation; and 45% of businesses, 54% of methodology owners, 78% of public

administrations, 67% of investors and 33% of NGOs responding to the targeted consultation).

Figure 33. Summary of the percentage of stakeholder groups at least in agreement with best scoring PEF policy options

(PC = public consultation)

For the OEF, stakeholders who replied to these consultations expressed most support for

reviewing existing policies to include the OEF (options polled included indicators in the Eco-

Management and Audit Scheme and the as environmental pillar under the non-financial reporting

directive; considered at least as effective by 82% of citizens participating in the public

consultation and 66% of all participants in the public consultation; and by 22% of businesses,

53% of methodology owners, 67% of public administrations, 80% of investors and 32% of NGOs

participating in the targeted consultation).

The second most preferred action was to establish a rating scheme based on the OEF (considered

at least effective by 80% of citizens participating in the public consultation and 52% of all

participants in the public consultation; and by 16% of businesses, 58% of methodology owners,

42% of public administrations, 100% of investors and none of the NGOs responding to the

targeted consultation). The following most preferred action was a voluntary scheme based on the

OEF (considered at least effective by 24% of citizens responding to the public consultation, 40%

of all participants to the public consultation; and 37% of businesses, 32% of methodology

owners, 50% of public administrations, 60% of investors and none of the NGOs). It is important

to note, that the investors who replied, the main users of the results of the method a registry,

reporting and an EU rating scheme as very important – however, the number of investors

participating in the survey was very limited.

85%84%80%

84%

73%73%

62%

75%

62%

54%

34%

45%

79%79%74%

54%

100%

92%

75%78%

100%

60%

80%

67%

25%

38%

50%

33%

Requirement on how tocommunicate the EF

PEF in new policy/ green claimsRepository of PEF resultsEF in existing instruments

Citizens/ PC PC participants Business Methodology owners Public administrations Investors NGOs

84

Figure 34. Summary of the percentage of stakeholder groups at least in agreement with best scoring OEF policy options


In providing more detailed comments, many stakeholders called for a voluntary use of the

methods. Several argued for the importance of internal use or pointed out the importance of using

it in business-to-business relations.

In addition to the options quoted in the consultations, some stakeholders suggested to use the

methods in the Eco-Design Directive (use PEF in preparatory studies and for setting minimum

requirements), in greening the Common Agricultural Policy, using them in establishing taxes and

fees, in public and private procurement, 2050 long term strategy for a climate neutral Europe,

bio-economy strategy and the Circular Economy action plan. There were also suggestions to use

the PEFCRs as input for prioritising action in other policies (e.g. trade, product groups under the

Eco-Design Directive, technical standards on material composition to help reduce impacts).

The perspective of SMEs

SMEs experience the same challenges and opportunities as large companies: they experience the

growing demand from consumers for green products (54% of SMEs vs 72% of large companies),

21% of them produce products with environmental features, whilst 12% plans to do so. 24% of

SMEs responding receive requests to provide environmental information.

Small (42%), and medium (50%) enterprises think that micro enterprises should be exempted

from legislative requirements, while micro enterprises (12%) and large enterprises (25%) do not

think so. Micro (76%), small (67%), medium (78%) and large enterprises (68%) agree that

calculation tools for non-experts should be made available.

Among other measures in favour of SMEs, we quote that simplified provisions should apply (e.g.

exemptions from primary data requirements); to make available skilled help/ consultancy and

related financial support; to rely on existing labels. A few comments pointed out that methods

should be user friendly for all companies, including SMEs and pointed out the importance of a

level playing field.

82%80%

24%

0

66%

52%

40%

0

22%16%

37%

21%

53%58%

32%

58%

67%

42%

50%

67%

80%

100%

60%

100%

32%

0%0%

50%

OEF in existing policyRating scheme based on OEFVoluntary OEF schemeMore harmonised non-financial reporting


85

Sector-specific insights

Stakeholders provided sector-specific insight through their additional comments and position

papers.

One of the papers stated that for durable and energy intensive goods PEF brings little added value

respectively to the Energy Label, as energy consumption proves to be the design factor driving

performance. The batteries industry calls the attention to the fact that there are important data

gaps for electronics components.

For the cosmetics industry, creating an EU market average would be misleading as performance

varies based on ingredients and main impacts are in the use stage.

For the construction sector, they recommend the use of EN 15804 and emphasise the importance

of building and civil engineering works level.

5.3.4 On options for communicating results

Consumers responding to the public consultation expressed a preference for defining and

monitoring compliance with communication principles such as transparency, availability &

accessibility, reliability, completeness, comparability and clarity (91%). 80% would like to see

fines for breaching communication principles and 78% would favour policy to prescribe

minimum information content and a format.

Taking results from all consultation activities, respondents considered as most effective the

definition and monitoring of communication principles (an average of 68% considered it at least

effective), mandatory verification of information provided (an average of 64% considered it at

least effective) and encouraging to transfer PEF information along the supply chain through

barcodes (an average of 57% considered it at least effective).

Respondents to the public consultation and the targeted consultations expressed different

priorities for where the environmental information on products should be placed: respondents to

the public consultation preferred information directly on the product (50% of citizens and 38% of

all respondents), whilst targeted consultation participants would like to see a combination of

different solutions – on, near the product and online 34%).

In providing more detailed comments, several stakeholders would like to see flexibility on the

format, others see the prescription of minimum information content as useful. Some would like to

see reliance on existing tools (e.g. labelling standards or existing EU labels). Some would like to

focus on the improvement of products over time.

Stakeholders stress the need for simplicity without over-simplification. Whilst some stakeholders

think that consumers are ready to take decisions based on holistic environmental indicators,

others warn against using the PEF for communicating to consumers. They also warn against

confusion where labels already exist (e.g. the organic label for food products). Some stakeholders

critical of using the PEF for business-to-consumer communication would still support the option

of using the PEF for fighting green claims under the Unfair Commercial Practices Directive but

would like to avoid that a common PEF label is introduced.

86

Figure 35. Summary of the percentage of stakeholder groups at least in agreement with PEF communication options


For OEF, respondents to the targeted consultations would prefer to prescribe a reporting format

(average considering it at least effective 55%); 40% of respondents considered prescribing

minimum information content at least effective.

91%

40%

69%

80%

28%

78% 79%

64%63%67%

39%

69%

53%

60%

46%43%

34%

49%

63%

95%

84%

26%

68%74%

92%

75%

92%

75%

42%

75%

100%

67%

33%

67%

0%

100%

50%50%

38%

50%

0%

50%

Define and monitorprinciples

Mandatoryverification

Encourage transfervia supply chain

Fines for breachingprinciples

Minimuminformation content,

no format

Content and format


87

Annex 1

Detailed listing of final comments and position papers

BUSINESSES AND SECTORAL BUSINESS ASSOCIATIONS

Final comments (free text)

General:

Several commenters expressed support for the development of the methods (3) and for

greater methodological harmonisation (7).

Companies with a sound environmental strategy perform better rather on the long term,

they might be disadvantaged on the short term.

The countries where there is the biggest demand for product information on the basis

of LCA is where there is a strong framework (voluntary or by legislation) to calculate

the life cycle environmental impact of the buildings or where a legislation exists which

requests to provide LCA based information in the case a product is put on the market

with a green claim.

Sometimes there is a lot of environmental information available, but it is of different

quality and not very transparent.

Basing the proposals on the issue of misleading claims is not justified, as the statement

that “three in ten citizens have come across exaggerated or misleading statements” is

not convincing.

Consumers are aware that they have to interpret different labels in a different way.

Procedural issues

Make it easier to develop PEFCRs and OEFSRs to enhance take-up;

The PEF and OEF should be set into ISO standards.

Dialogue with industry is very important (2 comments).

Data-related issues:

All companies should collect primary data for all their own processes to enable

improvement work. Requirements for gathering primary data along the supply chain

should be limited as it is costly.

Leave the development of secondary data to sectoral associations as they have access

to information and are in a good position to provide trustworthy verification and

guarantee data confidentiality.

The quality of secondary data is important for their credibility. They should be reliable

and updated (2 comments). he data must be complete and the methodology appropriate,

validated and consistent for real-world good practice taking to account the structure of

a given sector.

Technical issues:

There are still a lot of issues related to the robustness of impact categories and datasets

and is still missing relevant topics, e.g. biodiversity, social aspects or local

circumstances.

PEF has to be based on solid scientific methods. For the impact categories human and

eco-toxicity this solid method does not exist. New developments, e.g. Proscale have to

be considered and evaluated.

88

Provide reliable and robust methods for the calculation of land use, which is currently

not appropriate for the forest industry, taking into account the input of industries and

their representative organisations (2 comments). This is necessary in case PEF and

OEF will be referred to/ used in other environmental evaluations (e.g. sustainable

finance).

Only globally accepted indicators should be included in impact assessments and single

indicators should not be used in any LCAs (3 comments).

Provide a definition of by-products clarifying whether they are to be considered

products or waste;

Value choices and political intent in PEF calculations should be transparent (3

comments).

PEF needs to be further developed prior to implementation.

Specific comments on the methods

Current issues or consumer concerns (e.g. on marine environment) need to enter LCA-

based environmental information quickly (2 comments).

Effective value chain sustainability approaches (responsible sourcing) needs to be

better integrated in measuring PEF (2 comments).

Issues with feasibility for companies that produce different product categories on the

same production site. Errors in data collection can have a huge impact on final results.

Comparability is not possible as the implementation of the method cannot be

standardised.

Definition of the representative products (benchmark): ensure that niche products with

potentially very good environmental performance are not at a disadvantage.

PEF is far from being an easy-to-use and easy-to-understand tool for companies and

consumers. Data requirements and the complexity of several impact categories make

data collection and modelling costly and complex.

Not really appropriate for the organisations.

The harmonisation that PEF brings is good as it suppliers and customers are using the

same LCA method, limiting the administrative burden in dealing with these; and as

using the same methods and data creates a level playing field in case results are

communicated.

It is important to harmonise the PEFCRs, the environmental impact categories for

business-to-consumer communication, 3rd party verification, data quality requirements

and database with free access.

Sector-specific comments

For paints, the PEF offers a more holistic approach considered a better criterion for the

consumer for choosing environmentally friendly products, especially as it also

considers the quality (durability) of paint and the full life cycle.

For the plastic pipes business raw materials are the determining factor, but the PEF

profile is currently calculated with generic raw material (HDPE, PVC) datasets.

Company-specific PEFs do not make sense in this context, a generic PEF would be

more appropriate.

For construction, consider the performance of the building (7 comments). Support for

the use of the revised version of EN15804 as a reference method for PEF in

construction products (10 comments). To apply PEF as well would represent a double

burden for the construction sector (2 comments).

For the forest-based construction products, TC350 standards works better than PEF.

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Automotive industry: LCAs can be a useful tool to address environmental issues and

are applied as internal environmental systems for systematically managing

environmental improvements in the automotive industry (3 comments). The

complexity of automobiles does not allow for comparisons of different car

manufacturers in the framework of a mandatory reporting scheme (3 comments).

Transparency is still lacking in several sectors regarding raw materials (e.g. wipes,

hygiene products).

Communication-related comments

Preference for limited information on products regarding production type (e.g. organic)

as detailed LCA information would not be understood by consumers.

For consumers, price and performance are in most cases the first criteria in purchasing

decision. Agriculture and food production have the highest potential of growth because

of their large environmental impacts.

Fines for breaching communication principles would lead to producers not

communicating.

The type of information communicated should match the objective of the

communication, the product category and should be flexible in terms of vehicle (e.g.

the online environmental information should always be an alternative option to the

printed label). (2 comments)

PEF for conveying environmental footprint information to consumers building on

conventions and rules is a good idea. Prescribing data and choices to foster innovation

is less applicable and should be facilitated better by recommending ISO 14040 (3

comments).

When disclosed to the public or used for political and regulatory discussions, all LCA

studies shall be based on ISO 14040/44 (3 comments).

PEF is not market ready for communication. In one of the tests conducted during the

pilot phase, only some impact categories were tested, and PEF communication seemed

to have moderate impact on purchasing behaviour.

If PEF is to be used, it has to be simplified for in-store decision-making, including the

language used (e.g. toxicity might be misunderstood).

It should avoid arbitrary oversimplification to a simple score to the consumer if there

are missing datasets or assumptions in sectors with an established complexity.

The focus and added value of PEF and OEF should be self-comparison of a product or

organisation in a time-line (versus a benchmark to compare “similar” products or

companies). PEF should not be used for comparing like products due to the inherent

uncertainty in its core datasets and methodologies.

An EU labelling system should build on an existing global methodology, rather than

building a separate EU one.

The Ecodesign Framework Directive 2009/125/EC and Energy labelling framework

legislation has already established an EU-wide regulation and labelling system for

energy-related products which reduces the environmental impact of these products, as

well as established international standards within the framework for Life Cycle

Assessment (LCA).

Avoid conflicting or confusing comparisons for consumers between established

schemes and new proposals.

There is no need to define a method, as there are internationally accepted existing ones

(e.g. ISO standards) for the global market (3 comments). Having an EU, proprietary

method would mean additional burden, or yet another method leading to proliferation

and resulting in confusion for stakeholders like consumers, businesses and NGOs.

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Policy-related comments – options on the table

Support for the improvement of the environmental performance of products as long as

effects on trade are excluded and there are no benchmarking criteria.

In case of mandatory application, keep it simple to enable access of small companies;

there is a risk that SMEs are discriminated, or that large companies compete unfairly (4

comments). There is also a risk that the PEF for SMEs’ products would show more

impact.

In case of mandatory application, it must be mandatory to use the PEFCRs.

A mandatory application would be a costly barrier to trade, especially for companies

with a large number of product categories or SKUs in the market.

PEF should remain voluntary, with sector-specific rules developed by industry, with

input from stakeholders, under the supervision of a third party/ the European

Commission (4 comments).

PEF should remain voluntary to allow frontrunners to contribute positively.

PEF should be voluntary, targeted at the companies wanting to lead eco-labelling or

market disclosures.

The methods should remain voluntary and follow ISO standards.

LCA should remain a voluntary tool (3 comments).

PEF cannot provide the scientific evidence to support all claims. We shouldn’t end up

having to have a PEF study to support any claim (3 comments).

Any well-defined environmental claims should be PEF-compliant. However, making

environmental claims should remain voluntary (as PEFCRs are available for a limited

number of products; although the analysis based on PEFCRs and with the free data is

cheaper, verification is costly; the impact of the communication on consumers/

customers is unclear).

Apply PEF urgently to sectors;

The harmonisation of calculation methods and labels will be key to improving public

acceptance; EU-wide methods and rules are crucial for preserving the single market (2

comments).

Ensure consistency of requirements with legislation on claims (e.g. Unfair Commercial

Practices Directive, Cosmetic Products Regulation and the Common Criteria for

Claims Regulation). (2 comments)

The Commission should consider current verification schemes based on ISO 14025 to

strengthen the verification proposal under PEF. If in the construction sector EPDs and

PEF are aligned, a single verification system would be preferable.

The PEF should rely on already existing certification schemes in order not to

disproportionately increase audit burden.

The application of the methods needs to be incremental.

Policy-related comments – new ideas

Use existing systems of taxation and fees for the use of resources or on emissions for

promoting products with a smaller environmental footprint.

Enlarge the scope by including economic, social (e.g. social LCA) and eco-efficiency

aspects. Using the sustainable triangle (environment, society, economy) has to be the

basis for labelling.

Push for a wider acceptance of the EU Ecolabel in sectors where it is under-represented

(e.g. textiles, wipes).

Source crowd-intelligence use wikis in the development of PEFCRs (3 comments).

It is important to consider transparency on material content to ensure the needed

information to assess product impacts on environment health and further recyclability

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(materials compatibility) in the circular economy. This requires being transparent on

material content beyond REACH requirements.

Foster and incentivise measurement where the improving of performance needs to

happen rather than impose the method of an authority.

Accompanying measures

Education on PEF, OEF, LCA and sustainability measurement for companies and

citizens (2 comments).

Measures are needed to improve the environmental performance of companies far

down the supply. They are not incentivised by their clients, and companies closer to the

consumer are more likely rewarded for good environmental performance.

Position papers

General:

Agree that there is an increasing demand from consumers to know more about the

environmental aspects of products.

PEFCRs enable the analysis of the whole supply chain and having a common

methodology enables fair comparison.

PEFCRs contribute to a more transparent environmental impact assessment, beneficial

for fair regulation.

There are generally good reasons for having different labels and certification schemes.

Solutions should avoid distortion of competitions, obstacles on the single market; they

should promote innovation and be feasible for SMEs.

The pilot phase

It was a very useful exercise in harmonising LCA methods, providing common ground

for product categories through the PEFCRs, and as a multi-stakeholder process.

The scope of some projects was not satisfactory and the intended use of the methods

was unclear.

On the methods:

It is important to develop environmental profiles for products to improve transparency

and understanding of trade-offs in decision-making.

Some of the impact category indicators are not sufficiently mature (mainly toxicity,

abiotic resource depletion, land use, water and biodiversity were cited). Some issues

are not covered (e.g. plastics in a marine environment, co-product allocation methods

for material flows across sectors, i.e. through industrial symbiosis, infinite recyclability

in a closed loop, food waste avoidance, microbiological pollution, littering, food chain

contamination by microplastics, direct health effects).

Expectations on the granularity of categories or sub-categories in PEFCRs need to be

clarified.

If there are changes to sub-suppliers, their location and production method, this

influences results and triggers endless iterations.

There are limitations (variability, uncertainties) that prevent the possibility to compare

(among those mentioned, some assumptions e.g. on the functional unit of food,

allocation of recycling or reuse, aggregation of environmental impacts; no approach to

quantify uncertainty).

The methods improve LCA through integrating data quality requirements, rules that

enhance consistency, and by introducing a common end of life formula (Circular

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Footprint Formula, CFF). The CFF creates greater consistency for calculating

environmental benefits of recycling.

OEF captures elements important for the circular economy, such as material efficiency.

Improve benchmarking and weighting, considering e.g. the importance of the impact

category for the given product. Others suggested to adjust based on what consumers

are most interested in.

Methods should allow adjustments to local conditions (e.g. renewable power,

availability of water). It should be possible to exclude an indicator based on local

conditions (e.g. water use is less problematic in areas with abundant water). According

to others, the methods should flexibly adapt to the circumstances of companies,

including in the choice of communication vehicles.

PEF should be improved further based on scientific considerations and the results fed

into e.g. ISO standardisation.

Consistency with the FAO LEAP initiative is welcome (relevant for agriculture-related

sectors).

Do not allow comparison across product categories.

The complexity of some products and of the methods make it difficult to realise a full

audit.

Data-related comments

Improve secondary datasets to represent latest industrial processes; improve data gaps

in primary data (i.e. regarding farming).

Remove restrictions on the use of secondary datasets (currently limited to PEF or OEF

studies based on an approved PEFCR or OEFSR). Act further on the availability of

good quality data.

Commissioning sectoral associations to deliver secondary data is an efficient way to

ensure regular updates.

Give information on actual environmental impact by providing primary data on the

company’s production processes.

The methods are not ripe for broad roll-out, especially regarding the quality of input

data.

Sector-specific insight:

Durable and energy intensive goods: little added value was found respectively to the

energy label: energy consumption is the design factor that drives the majority of the

relevant impact categories as well as total environmental impact.

Cosmetics: an EU market average would be misleading. The footprint varies according

to the ingredient and is mainly on product use.

Batteries: datasets are incomplete, especially for electronic components. The use of

proxies enhances uncertainty.

Uses of PEF and OEF

Use in support of the Unfair Commercial Practices Directive to check the accuracy of

environmental claims; and to underpin GPP criteria.

Create a level playing field by harmonising methodologies for communicating

environmental claims. Making claims should be voluntary.

Use PEF in a voluntary manner, as it is important that environmental claims come from

a strong scientific base.

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Use of the PEFCR are for internal purposes (product improvement, priority setting,

driving innovation, scientific or technical developments, supply chain management,

environmental management systems and indicators for organisations)

Voluntary use in business-to-business relations (engage with suppliers, stakeholders

and decision-makers).

Use for off-pack information.

Communication to consumers better limited to general information to consumers

(important life cycle stages, impacts and processes, measures taken by the producer),

but not the specific PEF profile of a given product.

PEF information, especially some impact categories and how to interpret them, are too

complex for consumers to understand.

Communicate information only online, and taking an explanatory approach (make

claims or stories in commercials or on products that are legitimate because they are

based on PEF studies).

Provide complete freedom in the choice of communication vehicles, including digital

solutions.

Do not prescribe a format, but prescribing minimum information content is a good idea

to guarantee comprehensive and comparable information.

Do not create a label on top of existing ones, especially not a mandatory one. There

was one strong opinion against environmental labelling for food, as it is sufficiently

covered by the organic label.

Recommend not to use PEF for external communication.

In terms of relations with financial institutions, reputation should equal factual

performance.

OEF is good for identifying impacts from direct activities and from indirect activities

and for prioritising improvement measures. Use it for tracking the company’s

performance over time, not for comparing companies’ performances.

Use them as a voluntary tool.

Avoid by all means mandatory systems based on different PEFCRs/ OEFSRs in

different Member States.

Do not use single scores, as weighting and normalisation is distorting results.

Competition between products or across sectors would hamper collaboration across

supply chains.

Revise the Ecodesign directive to use PEF in preparing background studies and setting

minimum requirements on recyclability and reusability (current method: only quantity,

not quality or differences btw environmental aspects).

Potentially, use for the EU Ecolabel and for EMAS, but do not use for GPP and for

green claims under the Unfair Commercial Practices Directive.

Use existing PEFCRs as measurement tools in existing and future policies (e.g.

greening the Common Agricultural Policy, 2050 long term strategy for a climate

neutral Europe, bio-economy strategy, Circular Economy action plan).

Additional ideas

Develop incentives to reward well-performing companies and reward investments in

efficiency and improvement programmes.

Develop a more holistic approach that also covers the social and ethical dimension

(e.g. animal welfare, healthier consumption). One stakeholder warned about the

complexity inherent to such a holistic approach, which was however judged as

necessary.

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Use material and product passports to enable the circular economy (disclosure and

communicatino of the chemical content of materials by suppliers and component

manufacturers along the supply chain, including to consumers and waste management

actors). Another stakeholder expressed clear disagreement with such an approach as it

undermines business secrets.

METHOD AND INITIATIVE OWNERS

Other comments

General

Important work was done in aligning state of the art LCIA methodology.

PEF is a big chance for improving comparability and consistency, and therefore the

reliability of LCA. High quality PEFCRs are essential for implementation.

As an initiative towards a structured approach, the PEF and OEF are “second to none”.

Conditions for it to become a true breakthrough are successful maintenance, update

and governance.

The PEF and OEF methods

There is potential to improve the comparability of products

Availability and choice of background data is a critical point. Suggest to manage a

database fed by stakeholders, providing a maximum level of transparency and a high

level of quality (e.g. specific to different production situations). Data availability needs

to constantly evolve and be checked. Ideally, the data should be updated on an annual

basis.

Avoid that analysis carried out with rough secondary data delivers better results than

studies based on primary data.

There is need to support users to collect primary data in a way to result in a robust

analysis.

Uses of the EF methods

The verification process should be based on ISO 14025 (4 comments) and managed via

Programme Operators (3 comments).

For construction products EN 15804 should be considered. Also, the building level

needs to be considered. Currently it is problematic to integrate PEF in a modular way

into building assessments, as the functional unit of a PEFCR contains more materials

and products that are not necessarily used in building assessment.

Consider the use of standards as a priority.

Communication

Consumers are ready for transparent and holistic environmental indicators enabling

them to choose the best product.

Make the EMAS environmental statement requirements (Annex IV of the Regulation)

the basis for OEF communication.

Third party verified and certified information shall be the preferred information type.

Other policies/ ideas

Use PEFCR information to priorities EU actions (e.g. trade instruments, obligations of

importers and manufacturers related to most relevant impacts, extension of the Eco-

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design Directive to technical satandards on material composition if this is relevant for

reducing the EF of a product category).

NGOs

Position papers

About the methods

The PEF undeniably harmonised and streamlined the way LCA is carried out. It

provided much-needed clarity on which data to use and how.

All relevant impact categories have to be captured (including toxicity and biodiversity).

Look beyond LCA data where needed, rely on expert views, standards or certification

schemes.

Differentiate between business and usage models.

Poor precision will prevent the possibility to establish performance classes similar to

the Energy Label.

The tool is relatively one-dimensional and may develop further at the expense of well-

established, superior approaches.

Benchmarks are useful tools to place the products in a broader context; stimulate

positive competition amongst companies; or prevent bad performing products from

entering the EU market – however, they may be misused.

As a quantitative methodology, with limited scope focusing on hotspots, there is a risk

that certain environmental, qualitative issues are overlooked. Therefore, in some cases,

additional qualitative criteria or tools are needed to complement PEF.

Continuous improvement has to be built in through regular revision of the method,

PEFCRs, benchmarks and secondary data.

Uses of PEF and OEF

Internal assessment method (optimise the environmental profile of their products and

services, mitigate trade-offs between different environmental impacts.

Use PEFCRs in support of fighting green claims under the Unfair Commercial

Practices Directive, but without creating a PEF mark or a graded PEF label to avoid

confusing consumers. Companies who make green claims should base these on the

PEF method.

Use PEF to support the development of meaningful criteria for ISO Type I ecolabels,

rather than competing with them or creating double work.

Do not use it for consumer communication.

Do not use comparison to a benchmark for communication in order to protect

excellence tools such as the EU Ecolabel.

Use for consumer communication only indicators that are robust, meaningful/ relevant,

cheap, can be measured and are easy to verify. LCA indicators are not useful.

Additional policy ideas

Combine economic input-output analysis with PEF data in order to map impacts from

global supply chains and to help identifying the most relevant product categories that

should be covered by EU product policies.

Use a mix of tools and assessment methods, including environmental assessment,

health and environmental risk assessment, technology assessment. One paper suggests

a framework for environmental indicator identification.

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Annex 2

Background document for the consultations

Consultation on the potential policy options to implement

the Environmental Footprint methods

Introduction

In its Communication on an EU Action Plan for the Circular Economy21 the European

Commission committed to explore the further use of the Environmental Footprint methods22 for

measuring and communicating environmental information after the pilot phase.

The challenge of the proliferation of methods and initiatives for measuring environmental impact

and providing the basis for green claims, and the related obstacles to the growth of green markets

in the EU still stands true after the pilot phase23.

The appetite for environmental information is still high – consumers are interested more than

ever, investors increasingly act upon the fact that on average companies with sound sustainability

strategies have proved to be more profitable and industry increasingly wants to take advantage of

this competitiveness factor.

The pilot phase resulted in improvements in the Environmental Footprint methods, proved the

possibility to set a benchmark and compare the performance of similar products and confirmed

the potential for significant cost reductions for users, compared to conventional Life Cycle

Assessment (LCA). The tests of communication vehicles are pointing to how to effectively

communicate Environmental Footprint information. The tests on verification provided

information on how to establish a reliable verification system.

The scenarios under analysis for possible uses of the EF methods after the pilot phase include the

continued support for the development of the EF methods, the integration of EF methods into the

Eco-Management and Audit Scheme, into the EU Ecolabel and Green Public Procurement; or its

use as a tool under the Unfair Commercial Practices Directive. Furthermore, the creation of a

new instrument on green claims, addressing producers, importers or traders that voluntarily

decide to make an environmental claim could be considered.

THE ENVIRONMENTAL FOOTPRINT PILOT PHASE

In November 2013, the Commission, started a 4-year pilot phase through an open call for

volunteering stakeholders from within and outside of the EU. The pilot phase had the following

main objectives:

(1) To test the implementation of the PEF/OEF methods adopted in 2013 into Product Category

Rules and Organisation Sectoral Rules (respectively called PEFCRs, and OEFSRs). Having

a single set of rules for a product category or a sector could stop of the current proliferation

of "similar-but-different" rules in the EU.

21 COM(2015) 614

22 For more details about the methods, see Annex 1

23 For more details related to the problems, see Annex 2

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52015DC0614

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(2) To develop a "benchmark" for each product category, where the benchmark is the quantified

environmental performance of the average product sold in EU. The benchmark is available

per impact category (the methods address 16 different impact categories) and as total

environmental impact (single score).

(3) To test alternative verification approaches, knowing that the reliability and traceability of

the information provided is a key element to increase the lacking trust from stakeholders

when it comes to green claims and labels.

(4) To test alternative communication vehicles (websites, leaflets, Environmental Product

Declarations, labels, bar codes, QR codes, etc).

120 proposals for pilots received in 2013. 27 pilots selected, 11 related to food drink sector

(meat, fish, olive oil, coffee, pasta, packed water, wine, beer, dairy, pet food, feed) and 16 related

to other sectors (Batteries, decorative paints, footwear, pipes, detergents, intermediate paper

products, IT equipment (storage), leather, metal sheets, photovoltaic panels, stationery products,

thermal insulation, t-shirts, Uninterruptible Power Supply, copper extraction, retail).

4 pilots decided to stop during the process due to technical reasons (fish pilot), disagreements

amongst competitors (coffee), due to the complexity of project management (stationery products)

or disagreement among stakeholders over the allocation of impacts (red meat).

20 pilots are currently active on PEF:

food, drinks and related: beer, dairy, feed for food producing animals, pasta, packed water,

pet food (cats & dogs), olive oil, wine;

other sectors: batteries and accumulators, decorative paints, hot and cold water supply pipes,

household detergents, intermediate paper product, IT equipment (storage), leather, metal

sheets, thermal insulation, t-shirts, uninterruptible power supply (UPS).

2 pilots are active on OEF: retail and copper production.24

Most of the pilots finalised their work by the in April 2018. Some pilots continue work with the

aim of finalising their documents by autumn 2018.

About 300 companies and business associations (from the EU and beyond ) are directly involved

in the technical work. More than 2000 stakeholders follow the work done during the pilot phase.

Several public administrations are closely monitoring the work and some of them (e.g. France,

Germany, Italy, Switzerland) are also contributing to the technical work.

The great majority of the pilots cover at least 51% of the European market (in terms of turnover

of product sold in EU) with a total average for all pilots around 67%.

As a proof of concept, tools to calculate the Environmental Footprint profile based on four

PEFCRs are developed. The tools can be used without having previous expertise. The aim is to

help small- and medium-sized enterprises to access the PEF easily. The tools are developed based

on the final version of the PEFCRs, and are expected to be available by the end of 2018.

Guidance documents (one related to PEF and one to OEF) provided instructions on how to

develop PEFCRs and OEFSRs during the pilot phase.

These documents were regularly updated during the pilot phase to reflect agreements on

methodological approaches (e.g. approach on how to identify most relevant environmental

impacts, life cycle stages and processes, how to apply the principle of relevance to data

gathering) and the need of additional steps (e.g. review of the screening studies, which were

24 Final deliverables of the pilot phase are available on the website of the initiative:

http://ec.europa.eu/environment/eussd/smgp/PEFCR_OEFSR_en.htm

http://ec.europa.eu/environment/eussd/smgp/PEFCR_OEFSR_en.htm

98

carried out based on available data to provide input on the most relevant environmental impacts,

life cycle stages and processes related to a given product or sector).

The essential technical developments during the pilot phase include the following features:

application of the materiality principle

approach for identifying most relevant environmental impacts, life cycle stages and

processes;

primary data gathering is focussed on a limited number of specific processes;

data quality requirements vary based on environmental relevance and access to data;

how to define a benchmark (which corresponds to the Environmental Footprint profile of

the average product/ organisation on the market, also called representative product/

organisation);

agreements on modelling climate change, electricity, transport, infrastructure & equipment,

packaging, end of life and agriculture;

progress on normalisation and weighting25;

guidelines on how to include biodiversity as additional environmental information (non-

LCA information).

Issues where work will be finalised in 2018/19 include improvements on the toxicity-related

methods (human toxicity – cancer effects; human toxicity – non-cancer effects; eco-toxicity,

expected to be available in 2018) and resource use (available in 2019).

The pilot phase identified needs for further improvement of the approach on certain issues such

as:

scope definition: identifying rules for identifying the right coverage/ granularity for PEFCRs

and OEFSRs;

development an approach for defining classes of performance;

improvement of modelling on agriculture and animals (allocation of impacts);

improvement of the International Life Cycle Data Network format for datasets.

The assessment of the results of the pilot phase is based on the following:

An independent review of the Environmental Footprint pilot phase by experts from

international organisations (UNEP), the private sector and NGOs (performed by an

environmental NGO expert). This report was finalised in August 201726 and concluded that:

25 Through normalisation the environmental footprint impact assessment results are multiplied by

normalisation factors in order to calculate and compare the magnitude of their contributions to the

environmental footprint impact categories relative to a reference unit (typically the pressure related to

that category caused by the emissions over one year of a whole country or an average citizen, e.g. kg

of CO2 emitted over one year by a EU citizen). As a result, dimensionless, normalised environmental

footprint results are obtained. These reflect the burdens due to a product relative to the reference unit

(e.g. with how many kg of CO2 does the product contribute to the CO2 per capita in a region in a

given year).

Weighting is a step where environmental footprint results, for example normalised results, are

multiplied by a set of weighting factors which reflect the perceived relative importance of the

environmental footprint impact categories considered. Weighted results for impact categories can then

be compared to assess their relative importance (e.g. climate change more relevant than toxicity for a

specific product). Results can also be aggregated across environmental footprint impact categories to

obtain several aggregated values or a single overall impact indicator.

26 Final report of the Environmental Footprint pilot peer reviewers

http://ec.europa.eu/environment/eussd/smgp/pdf/2017_peer_rev_finrep.pdf

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PEF and OEF are a good basis for harmonisation at EU and international level, more

action is needed internationally;

PEF and OEF are good tools for simplifying the assessment and information gathering

for industry and for companies in supply chains;

Stakeholders expect that the Commission will discuss as quickly as possible with

stakeholders what the Environmental Footprint methods should be used for.

Rules on verification are needed.

A multi-stakeholder approach that considers existing initiatives should be continued;

Integration into existing policies such as Ecolabel, Green Public Procurement and

EMAS is a logical next step.

The pilot phase created consolidated approaches to some long-debated methodological

issues (e.g. end of life of products).

There are a number of opinions on how to communicate EF information.

There are a number of opinions on the Environmental Footprint methods, ranging from

trust in its robustness to doubts on specific elements in the methods (e.g. toxicity

impact categories); from appreciation of simplifications through the PEFCRs/ OEFSRs

to worries about over-simplification.

A verification of embedded impacts and traceability as part of the Environmental Footprint

methods implementation, including recommendations on the verification of Environmental

Footprint information. This report was finalised in April 201727 and:

Stated that the good balance between cost and reliability of verification might be to

verify models and data owned by the company (typically covering about 80% of the

data) through on-site audits. This would require about 2 days of verification.

Identifies different scenarios of verification activities needed and related costs based on

wider types of policy.

Identifies issues where clarity is needed (these issues will be addressed in the modified

method and Guidance on developing product-specific and sector rules).

A report on the technical evaluation of the pilot phase, by the Technical Helpdesk for the

Testing of Environmental Footprint Rules. This report was finalised in April 201728 and:

Identifies points of improvement needed for fair product comparisons (e.g. clearer

rules on scope, improving the impact assessment of toxicity, etc.). These will be

addressed during the revision of the PEF and OEF methods.

Concludes that a significant reduction of cost of calculations will result from the

PEFCRs/OEFSRs compared to conventional Life Cycle Assessment. Main drivers of

this are the rules, the materiality principle (focus on what drives environmental

impacts), freely available background data and models and having a single method as a

basis.

An assessment of different communication vehicles for providing Environmental Footprint

information, including recommendations based on tests of pilots and complementary tests

decided by DG Environment, with the involvement of other interested services. Some key

conclusions from the report29:

27 Final report on the verification stage, Ernst & Young 2017

28 Technical evaluation of the EU Environmental Footprint pilot phase

29 Final report on the assessment of different communication vehicles for providing Environmental

Footprint information (2018)

http://ec.europa.eu/environment/eussd/smgp/pdf/2017_EY_finalrep_verification_public.pdf

http://ec.europa.eu/environment/eussd/smgp/pdf/HD_pilot_eval_final.pdf

http://ec.europa.eu/environment/eussd/smgp/pdf/2018_pilotphase_commreport.pdf


100

A total of 51 communication tests were carried out – 27 focussing on business-to-

business communication, and 24 focussing on business-to-consumer communication.

Approaches included labels, environmental product declarations, reports, websites,

videos, banners, infographics, ads and newsletters. To understand the impact of these

approaches, surveys, interviews, workshops and focus groups were carried out.

Both citizens and businesses find Environmental Footprint information of interest.

Citizens are concerned about environmental sustainability even if environmental

performance is not the main driver of their purchasing decisions; for many businesses,

Life Cycle Assessment is already embedded in their thinking and they anticipate

benefits for both business-to-business and business-to-consumer activities through the

use of the Environmental Footprint.

Both for citizens and businesses the clarity and simplicity of the information is key.

Citizens find numerical information and scientific terms too complex and prefer

graphics, bars and colour scales. QR codes, barcodes and links can lead to more

detailed information for the interested citizen. Translating the complexity of EF

information into simple, easily understandable messages is a challenge.

Consumers want certification of information from named and independent sources.

POTENTIAL OPTIONS FOR POSSIBLE USES OF THE METHODS

The Commission will further reflect on possible options taking into account input from

stakeholders. At this stage the following options are put up for the consideration and views of

stakeholders.

Cross-cutting elements in the policy options

The results from the pilot phase would be used, in particular:

the revised PEF and OEF methods and guidance on the development of PEFCRs and

OEFSRs;

free secondary data for implementing PEFCRs and OEFSRs;

a verification system with accredited and licensed verifiers.

Alternative routes for the development of PEFCRs and OEFSRs would be considered:

Development under the leadership of the European Commission for priority product groups

and sectors.

Development under the leadership of industry, following the European Commission

guidance document for the development of PEFCRs and OEFSRs. After internal scrutiny of

the European Commission, these rules may be adopted.

Development based on mandates to European Standardisation Organisations, following the

EC guidance document for the development of PEFCRs and OEFSRs.

For the provision of free secondary data30 for implementing PEFCRs and OEFSRs, the following

routes would be considered:

Licenses for the use of secondary data are acquired by the European Commission;

Licenses for the use of secondary data are acquired by the developers of the PEFCRs/

OEFSRs;

30 Until 2020, the European Commission ensures free data by acquiring a license for secondary data

under the PEFCRs and OEFSRs developed during the pilot phase, free for use to those applying these

PEFCRs and OEFSRs.

101

Licenses for the use of secondary data are acquired in co-funding by the European

Commission and the developers of PEFCRs/OEFSRs.

In all three cases, the European Commission would be responsible to ensure the coherence and

consistency of data tendered.

The following key features of verification would be proposed:

mandatory independent 3rd party verification according to rules detailed in the European

Commission revised PEF/OEF methods;

verification carried out by accredited or licensed verifiers;

verification of the model, data and calculations;

verification is partly done at desk (off-site), and partly on-site;

minimum requirements for verifiers in terms of verification practice, LCA knowledge and

industry/ sector knowledge are defined in the EC guidance;

verification implements the materiality principle, meaning that most attention is paid to the

data/ processes driving most relevant impacts.

Option 1: Business as usual

The European Commission Recommendation 2013/179/EU stays in place. Its Annexes are

updated to a version of the Environmental Footprint methods that resulted from the pilot phase.

The European Commission would take no further steps in applying the methods in other policies

and to further develop product- and sector-specific rules (Product Environmental Footprint

Category Rules – PEFCRs; and Organisation Environmental Footprint Sector Rules – OEFSRs,

respectively). The methods would remain at the disposal of interested sectors and industries for

the autonomous development of PEFCRs and OEFSRs.

Option 2: Continued support to the implementation of the EF methods

The European Commission continues to follow the development and update of PEFCRs and

OEFSRs based on the EC Guidance and to maintain and periodically update the Environmental

Footprint methods.

Option 3: Licensing of the right to use PEF and OEF

The European Commission would protect the PEF and OEF as trademarks and then license its

use to interested bodies.

Option 4: Integration of the methods in existing policies

The PEF and OEF methods could strengthen several existing EU policy instruments. The range

of instruments could be further expanded to consider arising policy needs.

EU Ecolabel: potential to help set criteria based on an Environmental Footprint analysis;

and/or potential to integrate PEF results into conditions for award and communication;

Green Public Procurement (GPP): potential to help set criteria based on an Environmental

Footprint analysis; and/or potential to use PEF thresholds as technical specifications in

Green Public procurement.

Eco-Management and Audit Scheme (EMAS): potential to bring clarity in how to calculate

and communicate indirect impacts of an organisation and use of OEF to help define EMAS

Sectoral Reference Documents.

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Unfair Commercial Practices Directive: potential to provide a tool/ guidance for competent

enforcement authorities based on the Environmental Footprint methods to help check the

accuracy of environmental claims.

Option 5: New instrument on specific green claims

The instrument, conceived to be complementary to the EU Ecolabel and GPP, would require the

use of PEF to substantiate clearly defined types of green claims. It would only apply to those

companies that wish to advance such green claims related to their product.

These could include claims on overall environmental performance (e.g. “green product”) or

claims related to a single environmental aspect covered by the EF methods (e.g. “low carbon”).

Comparative environmental claims would also be a relevant area to cover.

The scope of environmental claims not covered by the instrument would also need to be defined.

Potential candidates are issues not covered by the methods (e.g. Genetically Modified Organisms,

reparability, etc.), implicit claims (e.g. imagery and colours suggesting environmental

friendliness) and labels regulated at EU level (e.g. Energy Label, organic label, CO2 labelling of

cars).

The role of Environmental Footprint profiles would be to substantiate the claims. PEF can inform

whether the claim is relevant (is it an environmental issue that is significant for the given

product) and whether there are any misleading omissions (important environmental impacts that

are omitted from the claim).

The instrument would apply to products sold on the EU market and would also contain rules on

how to communicate EF information. These rules would be based on the principles established in

the Single Market for Green Products Communication31: transparency, availability and

accessibility, reliability, completeness, comparability and clarity. They would cover the content,

but not the format of the communication.

Regarding OEF, an EU registry for companies could be proposed.

Annex 1 – The EF methods

The Product Environmental Footprint (PEF) and Organisation Environmental Footprint (OEF)

methods are annexed to the European Commission Recommendation on the use of common

methods for measuring and communicating the life cycle environmental performance of products

and organisations32.

PEF and OEF are Life Cycle Assessment methods. Environmental performance is calculated

taking into consideration the environmental impacts throughout the value chain, from the

extraction/ growing of resources to the end of life of the product or the product portfolio of an

organisation, respectively.

They are able to calculate performance on 16 impact categories: climate change, ozone depletion,

human toxicity – cancer effects, human toxicity – non-cancer effects, particulate matter, ionizing

radiation, photochemical ozone formation, acidification, eutrophication – terrestrial,

eutrophication – freshwater, eutrophication – marine, ecotoxicity – freshwater, land use, resource

depletion – water, resource depletion – mineral, fossil.

31 Building the Single Market for Green Products Facilitating better information on the environmental

performance of products and organisations, COM(2013) 196 final

32 2013/179/EU


http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32013H0179

103

Before considering developing a new method, the Commission carried out an in-depth analysis of

the most widely applied methodologies33, 34. The objective of this analysis was to assess if the

existing methodologies are "good enough" to achieve a number of policy objectives, such as:

improvement of resource efficiency along the value chain; definition of environmental

performance benchmarking; improvement of design for environment; reproducibility of results;

and comparison of environmental performances. The analysis35 indicated that none of the existing

methodologies could be used as such, and a need to "fill some methodological gaps".

The methods were developed by the European Commission’s Joint Research Centre, using

existing methods and standards as a basis36. One important new feature of both methodologies

developed by the Commission is that they enable the possibility of comparing the environmental

performance of products and organisations. This feature required the development of product

category specific rules, called Product Environmental Footprint Category Rules (PEFCRs) and of

sector-specific rules, called Organisation Environmental Footprint Sector Rules (OEFSRs). The

testing of this approach was subject to the Environmental Footprint pilot phase, alongside other

developments needed to reach the full potential of the methods. These include the improved

availability of good quality life cycle data; setting-up a verification system which is cost-

effective; and normalisation and weighting system.

Annex 2

The problem of proliferation of methods and initiatives

There are more than 465 environmental labels worldwide, up from 430 in 2013. In the EU, more

than 100 environmental labels are active37. 29% of food and drink sales and 53% of non-

food/drink sales carried environmental labels in France, Germany, Italy, Poland and Sweden in

201738. There are more than 80 leading initiatives on greenhouse gas reporting only39.

These labels and initiatives are based on different methods, with a varied level of reliability and

environmental issues covered. Also labels and initiatives based on Life Cycle Assessment (LCA)

are based on similar-but-different approaches: looking at the same product or organisation, these

33 For products the methodologies assessed were: ISO 14044 (Environmental management -- Life cycle

assessment -- Requirements and guidelines), ISO 14067 (carbon footprint of product), ILCD

(International Reference Life Cycle Data System), Ecological footprint, Product and Supply Chain

Standards Greenhouse Gas Protocol (WRI/ WBCSD), French Environmental Footprint (BPX 30-323),

UK’s Product Carbon footprint (PAS 2050), ISO 14025 (Environmental Product Declarations).

34 For organisations the methodologies assessed were: ISO 14064 (Greenhouse gases -- Part 1, 2 and 3),

ISO/WD TR 14069 (GHG - Quantification and reporting of GHG emissions for organisations), ILCD

(International Reference Life Cycle Data System), Corporate Accounting and Reporting Standards

Greenhouse Gas Protocol from WRI/ WBCSD, Bilan Carbon, DEFRA - Carbon Disclosure Project

(CDP), CDP water, Global Reporting Initiative (GRI).

35 The full report is available at: http://ec.europa.eu/environment/eussd/pdf/Deliverable.pdf

36 Analysis of Existing Environmental Footprint Methodologies for Products and Organisations:

Recommendations, Rationale, and Alignment, JRC, 2011.

37 Ecolabel Index, extracted August 2017. http://www.ecolabelindex.com/

38 Opportunities in Europe for Environmental labels, Euromonitor for DG Environment, 2017. Product

groups covered: wine, apples, coffee, olive oil, cheese, dried pasta, processed meat, bottled water, dog

food, laundry care, footwear, jackets & coats, shirts & blouses, decorative paint, televisions.

39 Company GHG Emissions Reporting – a Study on Methods and Initiatives. ERM for DG Environment,

2010

http://ec.europa.eu/environment/eussd/pdf/Deliverable.pdf



http://www.ecolabelindex.com/

http://ec.europa.eu/environment/eussd/smgp/pdf/2017_Euromonitor_EU_opp_envlabels.pdf

http://ec.europa.eu/environment/pubs/pdf/ERM_GHG_Reporting_final.pdf

104

methods would deliver different results due to different calculation rules and methodological

assumptions. Companies wishing to prove their environmental credentials have difficulties in

choosing an approach that would be accepted in the whole of the internal market, and users of the

information (other companies along the value chain, consumers, investors, procurers, policy

makers and other stakeholders), have difficulties in interpreting the results and understanding

how they relate to results of other companies.

Especially where results might be interpreted as comparable by the user (e.g. absolute numbers

presented on CO2 emissions), these differences in methodology become a cause of misleading the

users of information. As the Guidance on the implementation of Directive 2005/29/EC on unfair

commercial practices points out “comparisons should refer to products within the same product

category” and it is important “that the method used to produce the information is the same, that it

is applied in a consistent manner (i.e. the same methodological choices and rules are applied,

results are reproducible), and that the method applied allows comparisons, otherwise any

comparison becomes less meaningful”.40

When preparing the European Commission Recommendation on the use of common methods to

calculate and communicate the life cycle environmental performance of products and

organisations41 and the Communication on Building the Single Market for Green Products42, the

European Commission was responding to calls for harmonisation from industry and stakeholders.

Respondents to the public consultation of 2012 considered the lack of consistency as one of the

most important barriers to the display and benchmarking environmental performance (72.5%

agreement), alongside lack of time or expertise (76.4%), and insufficient market reward for good

environmental performance (70%). When asked about the drivers of the barriers, multiple

initiatives in the EU (70.8%) and multiple ways of reporting (76.3%) received high agreement

from stakeholders43.

The proliferation is driven by the success of green products and the appetite for environmental

information.

The majority of EU consumers consider themselves “occasional” environmentally friendly

products’ consumers (54%) and more than a quarter of the respondents often buy

environmentally-friendly products (26%)44. In France, the share of consumers buying products

bearing an environmental label grew from 40% in 2009 to 50% in 2017. Consumers are also

willing to pay up to 44% more for environment-friendly products45.

Price and quality remain the most important decision factor when buying products. However,

proof is building up that more and more consumers follow their environmental values in their

purchasing behaviour. In 2014, products bearing information on sustainability grew by 7% in

comparison with 1% growth for those that didn't have a commitment in this area47

40 SWD(2016) 163 final

41 Recommendation 2013/179/EU

42 COM(2013) 196 final

43 See the impact assessment SWD(2013) 111 final and its annexes

44 Attitudes of Europeans Towards Building the Single Market for Green Products, European

Commission, 2013

45 Results vary based on income levels and age group. Qui est prêt à payer davantage pour un produit

vert?, French Ministry for the Environment, Energy and Sea, 2017 and The Sustainability Imperative –

New insights on consumer expectations. Nielsen, 2015.

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52016SC0163





http://ec.europa.eu/commfrontoffice/publicopinion/flash/fl_367_en.pdf

https://www.ecologique-solidaire.gouv.fr/sites/default/files/Th%C3%A9ma%20-%20Qui%20est%20pr%C3%AAt%20%C3%A0%20payer%20davantage%20pour%20un%20produit%20vert.pdf

https://www.ecologique-solidaire.gouv.fr/sites/default/files/Th%C3%A9ma%20-%20Qui%20est%20pr%C3%AAt%20%C3%A0%20payer%20davantage%20pour%20un%20produit%20vert.pdf

http://www.nielsen.com/eu/en/insights/reports/2015/the-sustainability-imperative.html


105

Businesses reported that they struggle to keep up with consumer demand for sustainable

products46. The sale of goods demonstrating commitment to sustainability has been growing even

during the economic crisis47. To differentiate themselves, companies are increasingly making

environmental claims regarding their products. As part of their strategies, companies are looking

at their supply chains and step up their requests for sustainability information.

Investors are increasingly requiring information as they are aware that a company with a sound

sustainability strategy has better stock performance48. So-called "dark green" funds, which boast

clearer environmental features, have seen their volume almost double over the past three years49.

Although assets under green funds in Europe are growing significantly (47% over the last three

years totalling €22bn49), they remain a fraction of total assets, estimated at €24,567bn50.

The issue of misleading claims

Given the proliferation of methods and initiatives, market participants are facing diverse

environmental claims and have difficulties in identifying reliable ones.

The number of misleading green claims remains significant. Three in ten citizens have come

across exaggerated or misleading statements on the effects of products on the environment44.

An analysis of 50 products in the EU also revealed that often environmental claims are too

general and vague and do not specify the concrete environmental benefit of the product.

Moreover, it was hard to access the scientific evidence on which the claims were based.

Furthermore, certain environmental claims did not relate to the environmental characteristic they

should relate to51. This undermines the trust of consumers and other market players in green

claims, and their readiness to purchase greener products52.

The high demand and readiness to pay more prove potential for further growth for green markets;

the increasing phenomenon of misleading green claims and the related mistrust and unfair

competition on the market is hampering this potential to unfold fully. This phenomenon does not

only concern consumers, but also other actors: investments and public procurement are also

struggling to reach their potential.

46 Long-Term Growth, Short-Term Differentiation and Profits from Sustainable Products and Services –

a global survey of business executives, Accenture, 2012

47 The Sustainability Imperative – New insights on consumer expectations. Nielsen, 2015

48 From the stockholder to the stakeholder – How sustainability can drive financial outperformance.

Smith School of Enterprise and the Environment of the University of Oxford, Arabesque Asset

Management Ltd, 2015.

49 The European Green Funds Market, Novethic, 2017

50 The 21 biggest banks in Europe by total assets. Business Insider, 2017.

51 Consumer Market Study on Environmental Claims for Non-Food Products, European Commission

2014.

52 The Effect of Misleading Environmental Claims on Consumer Perceptions of Advertisements, Stephen

J. Newell, Ronald E. Goldsmith and Edgar J. Banzhaf Journal of Marketing Theory and Practice, Vol.

6, No. 2 (Spring, 1998), pp. 48-60

http://www.ddline.fr/wp-content/uploads/2012/12/Accenture-Long-Term-Growth-Short-Term-Differentiation-and-Profits-from-Sustainable-Products-and-Services1.pdf

http://www.ddline.fr/wp-content/uploads/2012/12/Accenture-Long-Term-Growth-Short-Term-Differentiation-and-Profits-from-Sustainable-Products-and-Services1.pdf


https://arabesque.com/research/From_the_stockholder_to_the_stakeholder_web.pdf

ttps://www.businessinsider.nl/sp-global-biggest-banks-in-europe-2017-4/

http://ec.europa.eu/consumers/consumer_evidence/market_studies/docs/green-claims-report.pdf

106

Consequences

The proliferation of methods of initiatives has further consequences on different market

participants.

Companies trading across borders are facing additional costs as they have to prove their

environmental credentials in different ways on different markets. The EU Ecolabel is a solution

for products that are best performers in a product category covered by the scheme; however, it

does not resolve the issue for products that do not fall in the best performer category.

Furthermore, as information is not available in a consistent manner along the supply chain, there

are missed opportunities for optimising performance, which would typically go hand in hand with

efficiency gains and cost savings53, beyond decreasing environmental impact. Acting on the

results of the analysis often results in product innovation and improvements in design, boosting

the circular economy agenda54.

Consumers are interested in products with better environmental performance but do not trust the

environmental claims they encounter (see above.). Due to the many green claims they encounter,

they are confused, they are overloaded with information and as a consequence might disregards

claims altogether.

There is a growing interest from investors to consider environmental performance, but there are

not sufficient common metrics to do this in a systematic manner55.

53 Examples: Unilever reports over €700m of cumulative cost avoidance since 2008 through measures

focussing on water, energy, waste and materials. A media company reached over €30m cost avoidance

through a comparative life cycle assessment of packaging focussing on greenhouse gas emissions only.

54 Philips is using life cycle assessment to identify environmental focal areas for their green products

development programme. Life Cycle Assessment triggered processes of reducing water use , standards

for recycle and reuse and initiatives in their supply chain at Levi Strauss.

55 Financing a Sustainable European Economy - Interim Report, High Level Group on Sustainable

Finance, 2017.

https://www.unilever.com/sustainable-living/reducing-environmental-impact/eco-efficiency-in-manufacturing/

https://www2.deloitte.com/content/dam/Deloitte/us/Documents/process-and-operations/us-consulting-enhancingthevalueoflifecycleassessment-112514.pdf

https://www.philips.com/a-w/about/sustainability/sustainable-planet/green-products-and-green-innovation.html

http://www.levistrauss.com/sustainability/planet/#lifecycle-assessment

https://ec.europa.eu/info/sites/info/files/170713-sustainable-finance-report_en.pdf

107

Annex 3

Questionnaire – consultation targeted to

business and business associations

Introduction

In 2013, the European Commission adopted the Product and Organisation Environmental

Footprint (PEF and OEF) methods, suggesting public and private organisations to use them for

measuring and communicating the life cycle environmental performance of products and

organisations56.

In adopting this Recommendation, the objective of the European Commission was to overcome

the fragmentation of the internal market as regards different available methods for measuring

environmental performance.

Based on the methods, the European Commission started a pilot phase in order to test:

the development of product group and sector-specific calculation rules (Product

Environmental Footprint Category Rules and Organisation Environmental Footprint

Sector Rules) through a process open to any stakeholder;

the development of benchmarks: this corresponds to the environmental performance of

the average product/ organisation on the market and is the starting point for comparing

between similar products and organisations;

approaches to verify Environmental Footprint information;

approaches to communicate Environmental Footprint information to consumers and to

other company stakeholders (e.g. business partners, investors, NGOs, etc.).

The aim of the rules is to provide a clear set of instructions for calculating the Environmental

Footprint profile that guarantees reproducibility and comparability between similar products (the

benchmarking of organisations is more complicated and requires very specific situations in order

to be meaningful). They are based on the principle of relevance: the rules pre-define the

environmental issues that are most relevant for the given product group or sector and ensure that

the quality of the analysis on these issues is best.

The pilot phase involved 24 product groups57 and two sectors58, with more than 260 leading

companies and other stakeholders. Most of the pilots represented more than 2/3 of the EU market

for the given product or sector. More than 2000 stakeholders followed the process and several of

them took the opportunity to comment on milestone documents of the pilots.

A technical evaluation of the pilots has confirmed the importance of having clear product group

and sector-specific rules. A comparison of environmental performance proved to be feasible for

56 European Commission Recommendation 2013/179/EU, http://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=CELEX:32013H0179

57 Batteries and accumulators, decorative paints, hot and cold water supply pipes, household detergents,

intermediate paper product, IT equipment – storage, leather, metal sheets, footwear, photovoltaic

electricity generation, thermal insulation, t-shirts, uninterruptible power supply, beer, dairy, feed for

food-producing animals, olive oil, packed water, pasta, pet food and wine.

58 Copper production and retail.



108

final products: it is possible to determine whether the performance of a product is better or worse

than the average product on the market (benchmark)59.

This became possible due to the agreements on technical issues reached during the pilot phase

(e.g. modelling of cattle, packaging, end of life/ recycling/ recovery, etc.) and to the use of a

single set of high quality secondary data. As a further action to enhance access to the methods,

these data are going to be made available for free to any user of the product group and sector-

specific rules until 2020.

The testing of verification approaches suggested a combination between on-site and remote

audits and a focus on data that have most impact on the final results, which are mostly data

owned by the companies60.

A wide range of tests were also carried out by the pilot participants and the European

Commission on how to communicate Environmental Footprint information. Many of the tests re-

confirmed a high interest in environmental information in general, and Environmental Footprint

information specifically. The issues to tackle include the difficult balance between complete and

accurate information on the one hand and a need for simplicity and clarity on the other61.


the PEF and OEF in existing or new policies. This public consultation aims to gather views on

possible options for the further use of these methods and to collect evidence and opinions on

underlying issues related to environmental information and green markets.

Potential policy options could include the integration of the Environmental Footprint methods

into existing voluntary policies such as the EU Ecolabel and Green Public Procurement; or the

development of a new, stand-alone instrument implementing the methods. The tool also has the

potential to support the implementation of the Action Plan on Sustainable Finance. Among the

potential applications, it is possible to envisage a role for the PEF and the OEF to help define a

taxonomy for sustainable finance (i.e. a classification of sustainable economic activities)62 and as

a basis for developing low carbon benchmarks and positive carbon impact benchmarks63.

A. INFORMATION ON THE RESPONDENT

(1) I am giving my contribution as

Academic/research institution

Business association

59 See a detailed analysis in the document “Technical evaluation of the EU Environmental Footprint pilot

phase, http://ec.europa.eu/environment/eussd/smgp/pdf/HD_pilot_eval_final.pdf (document available

only in English)

60 Final report on the testing of verification approaches during the Environmental Footprint pilot phase,

http://ec.europa.eu/environment/eussd/smgp/pdf/2017_EY_finalrep_verification_public.pdf (document

available only in English)

61 F Final report on the assessment of different communication vehicles ofr providing Environmental

Footprint information,


62 See the proposal for a Regulation on the establishment of a framework to facilitate sustainable

investment, COM(2018) 353 final

63 See the proposal for a Regulation amending Regulation (EU) 2016/1011 on low carbon benchmarks

and positive carbon impact benchmarks, COM(2018) 355 final




https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018PC0353


109

Company/ business organisation

EU citizen

Environmental organisation

Non-EU citizen

Non-governmental organisation (NGO)

Public authority

Trade union

Other

(2) Please provide your full name

(3) Please provide your e-mail address

(4) If responding on behalf of an organization, association, authority, company,

or body, please provide the name

(5) Where are you based?

Publication privacy settings

The Commission will publish the responses to this targeted consultation. You can

choose whether you would like your details to be made public or remain

anonymous.

Anonymous

Only your type, country of origin and contribution will be published. All personal

details (name, organisation name and size, transparency register number) will not be

published.

Public

Your personal details (name, organisation name and size, transparency register

number, country of origin) will be published with your contribution.

Respondents should not include personal data in documents submitted in the context

of the consultation if they opt for anonymous publication.

Please note that, whatever option chosen, your answers may be subject to a request

for public access to documents under Regulation (EC) No 1049/2001. Please also

read the specific privacy statement referred to on the consultation webpage.

(6) Is your organisation or institution registered in the EU Transparency

Register? (relevant for companies, industry organisations, NGOs, consumer

groups, research organisations and other).

Yes

No

110

Do not know

(7) Please provide your register ID number. Click below to view the EU

Transparency Register:

https://ec.europa.eu/transparencyregister/public/homePage.do

(8) Organisation size

Micro (1 to 9 employees)


Medium (50 to 249 employees)


(9) Please specify the type of product your organisation produces or represents

Intermediate product (e.g. ingredient for a final product)

Final product (used as is)

Both intermediate and final products

Other (e.g. services)

Not applicable

(10) Please specify the sector(s).

Agriculture

Apparel & footwear

Chemicals



Food and beverages


Retail & wholesale

Banking

Insurance

Tourism

Other

If other, please specify


111

(11) Where are you active?

Local market

Regional market

National market

EU market

Worldwide market

(12) Does your company have at least one person with explicit responsibility for

environmental concerns?

Yes

No

(13) Are you a member of a sectoral association?

Yes

No

Not applicable

(14) How would you describe your commitment to environmental issues (you can

choose several options, if applicable)?

Environmental considerations are the main driver of the business (e.g. specialised in

environmentally friendly products)

Environmental performance and remuneration policy are linked

The company knows the environmental performance of its products/ of the

organisation, and strives to improve it

The company knows environmental issues in the supply chain and strives to

improve them

The company gathers information on environmental performance

The company has an environmental policy

The company has an environmental management system

Environmental issues are not important for my company

(15) Environmental efforts in your company focus on…

Products

112

The company (e.g. production processes, catering, employee travel and commuting)

Both the products and the company

Not applicable

B. QUESTIONNAIRE ON THE FUTURE USE OF ENVIRONMENTAL

FOOTPRINT

B.1 Input on the importance of environmental information

(1) To what extent do you agree with the following statements in terms of

environmental information on products and organisations?

Strongly

agree

Agree Undecided Disagree Strongly

disagree

There are too many methods

on the environmental

performance of products

There are too many labels




on measuring companies’

environmental performance

There are too many

reporting initiatives on the


of companies

Companies should apply

environmental criteria when

choosing their suppliers

Companies should measure

their environmental

performance

Not enough information is

available on the


of products / organisations

I prefer to work with

financial institutions (e.g.

113

banks) that have a good

environmental reputation

Investors and banks should

apply environmental criteria

when deciding where to

invest

I think consumers care more

and more for environmental

performance

(2) What importance do you give to the following types of environmental

information on products?

Very

important

Quite

important

Less

important

Not

important

No

opinion

Information directly linked

to the product (e.g.

environmental impacts of

ingredients, packaging,

energy use etc.)

Production type (e.g.

organic, covered by

environmental management

system)

Information considering all


the product during its whole

life cycle (resources,

manufacturing, transport,

use, waste or recycling, etc.)

Information on a single

relevant environmental issue

(e.g. climate change)

The most relevant

environmental impacts for

the product (those

cumulatively contributing to

80% of the total impact

Information on the


of the product in comparison

114

to the performance of the

average product on the EU

market (e.g. better, average,

worse)

Information pointing to

environmentally excellent

products, so as to choose the

best products (e.g. through

ecolabels such as the EU

Ecolabel)

B.2 Input on experience with environmental information

Misleading green claims

(3) Did you ever encounter a label or environmental information that you would

qualify as misleading?

Yes

No

If yes, please specify or give an example

(4) If yes, did you file a complaint?

Yes

No

(5) In my experience…

… most of the environmental claims are false

… many environmental claims are false

… some environmental claims are false

… environmental claims are correct

I don't have an opinion

Comments (if you have an idea of what % of environmental claims are false, please

add it here)

(6) Do you think that the availability of reliable, comparable environmental

information would trigger more growth on green markets?

Yes

No

I don’t know

115

(7) In your experience, do companies with a sound environmental strategy

perform better economically?

Yes

No

I don’t know

(8) Do you think your clients would be ready to pay more for a green product if

green claims were more reliable?

Yes

No

I don’t know

(9) In your opinion, which sectors have the highest potential of growth for

products with better environmental performance?

Agriculture

Apparel & footwear

Banking

Chemicals



Forestry

Food and beverages

Insurance


Retail & wholesale

Tourism

Other


116

(10) Do you experience growing demand from your customers for greener

products?

Yes

No

Don’t know

If yes, please give examples of demands from your customers

(11) Are you able to satisfy the demand for greener products?

You are able to satisfy the demand

You have products that match this demand, but cannot provide them in sufficient

quantities

You do not have products that match this demand, but plan to introduce them

You do not have products that match this demand, and do not plan to introduce them

You do not see demand for greener products

(12) Which labels or certifications are you using?

EU Ecolabel

Other ecolabels (e.g. Nordic Swan, Blue Angel, etc.)

EU Energy label

Sustainable forestry (e.g. FSC)

Sustainable fisheries (e.g. MSC)

EU organic label

Fair trade

Company-specific claim

Other (please specify)

Not applicable

(13) Which environmental performance measurement methods do you apply?

(Examples of environmental performance measurement methods include

Life Cycle Assessment based on ISO 14044, Greenhouse Gas Protocol,

water footprint, Global Reporting Initiative indicators, Eco-Management and

Audit Scheme indicators, etc.)

117

(14) In which environmental initiatives do you participate? (Examples of

environmental initiatives include Carbon Disclosure Project, Global

Reporting Initiative, The Sustainability Consortium, Sustainable Apparel

Coalition, etc.)

(15) Could you state the costs for your business of applying these methods and

using these initiatives?

(16) What is the reason to apply the methods and/or using initiatives?

My clients are interested

It helps me improve the environmental performance of the product or organisation

To better manage my suppliers

To reduce costs

To show my commitment towards stakeholders

I expect that the market of greener products in my sector will grow

Other

Not applicable

If other, please specify.

(17) Do your clients ask questions about the labelled products? (e.g. what aspects

the labels cover)

Yes

No

I don’t know

Doesn’t apply to my case

(18) Do you require environmental information from your suppliers?

Yes, I require specific certification/ label/ method

Yes, I require environmental information, but I don’t specify what should be the

content

No

Not applicable

If requiring specific certification/label/method, please specify:

118

(19) Which of the statements apply to you as SME? (multiple answers possible)

Clients ask environmental data from me

We produce products with environmental features (e.g. eco-labelled, “A” energy

class products, organic label, recyclable, reused, cradle-to-cradle)

We plan to produce products with environmental features

Not applicable

(20) Do you think your clients are satisfied with the environmental information

you provide?

Yes

Partially

No

I don’t provide information

If you replied “partially” or “no”, please explain what would clients like to see in

your opinion

B.3 Use of the Product and Organisation Environmental Footprint

methods (PEF and OEF)

(21) Please select the statement(s) that applies to you

I (or my organisation) was member of one of the Technical Secretariats developing

Product Environmental Footprint Category Rules or Organisation Environmental

Footprint Sector Rules during the EU Environmental Footprint Pilot phase

I (or my organisation) followed the EU Environmental Footprint pilot phase as a

stakeholder

I am aware of the EU Environmental Footprint pilot phase but was not involved

I know about Life Cycle Assessment

I am not aware of this work

(22) Did you apply the PEF or OEF method?

Yes, PEF

Yes, OEF

119

We are considering to apply it

No

(23) If the answer is yes, what were your main motivations for applying (or

considering to apply) the PEF or OEF methods?

Strongly

agree


disagree

Demonstrating market

leadership

We expect EU policies

related to the methods

We support having a

common method for

measuring environmental

performance

We wanted to understand

differences with other

approaches we use

We expect that it will

improve the company’s

reputation

We expect environmental

improvements based on the

exercise

We expect cost reductions

based on the exercise

Other


(24) If the answer is no, why not?

Waiting for the revised methods after the Environmental Footprint pilot phase

There are no Product Environmental Footprint Category Rules or Organisation

Environmental Footprint for my product/ sector

120

Waiting for policies applying the methods

Will apply only if required by legislation

Already apply other method

It is not of interest for my company (please give reasons):

(25) The Product Environmental Footprint method has new features respectively

to traditional Life Cycle Assessment. Please tell us to what extent you

consider these useful or not:

Very

useful

Quite

useful

Neutral Less

useful

Not

useful at

all

Product Environmental

Footprint Category Rules

pre-identify most relevant

environmental impacts,

processes and life cycle

stages for the product group

Primary data gathering is

focussed on a limited

number of specific processes

Data quality requirements

vary based on environmental

relevance and access to data


Footprint Category Rules list

secondary data to be used

Secondary data are available

for free to users of Product

Environmental Footprint

Category Rules

The environmental

performance of the average

product on the market

(representative product/

benchmark) is stated in the



It is possible to compare the


profile of the product with

121

the benchmark

B.4 Input on the potential use of the Product and Organisation Environmental

Footprint (PEF and OEF) methods for providing environmental information

(26) Who should have an important role in ensuring the availability of reliable


Very

important

Quite

important

Less

important

Not

important

No

opinion

European Union

Member States (countries)

NGOs

Private sector

Other


(27) How important do you rate the following elements for providing reliable,

comparable and comprehensive environmental information?

Very

important

Quite

important

Less

important

Not

important

No

opinion

Product group and sector-

specific calculation rules

(e.g. how to calculate the


of clothing)

Availability of a benchmark

(performance of the average

product) per product group

Availability of a metric that

allows to compare

companies’ environmental

performance within a sector

Clear rules on how to

develop product group and

sector-specific calculation

122

rules

Requiring the gathering of

primary data for specifically

defined processes that are

most relevant from an

environmental point of view

and where primary data can

be accessed

Availability of common,

free average (secondary)

data

Calculation tools enabling

non-experts to carry out the

analysis

Use of a solid verification

system

(28) Who should develop EU-wide product group and sector-specific rules?

Best Good Less

appropriate

Worse No

opinion

The private sector, with

input from stakeholders

The private sector,

supervised by the European

Commission and with input

from stakeholders

Standardisation

organisations (e.g. European

Committee for

Standardisation), based on

EU rules

The European Commission,

with input from the private

sector and other

stakeholders

Other

123


(29) Who should bear the cost of providing free average (secondary) data to use

in Environmental Footprint measurement?

Best Good Less

appropriate

Worse No

opinion

The European Commission

The private sector

Co-funded by the European

Commission and the private

sector

It is not important to

provide free secondary data

(30) What actions related to the Product Environmental Footprint method (PEF)

would be effective to trigger the uses of environmental information you

consider important?

Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion


encourages the use of the


methods for measuring and

communicating


on a voluntary basis

Delegate the management of

a voluntary Environmental

Footprint scheme to a 3rd

party

Prescribe the use of the PEF

in case communicating


(it is not mandatory to

communicate environmental

information, but if

communicated, the

information has to rely on

124

the PEF method)


for measuring and

communicating life cycle


Use the PEF in the

development of EU Ecolabel

criteria

Use PEF benchmarks


product) as thresholds to

access the EU Ecolabel

scheme

Use PEF information to

demonstrate compliance

with the EU Taxonomy of

Sustainable Investments.

Use PEF for defining Green

Public Procurement criteria

Use PEF benchmarks as

thresholds for accessing

Green Public Procurement


check the accuracy of

environmental claims when

applying the Unfair

Commercial Practices

Directive

Provide requirements on

how to communicate on the

Environmental Footprint (it

is not mandatory to


information, but if

communicated, these have to

comply with specific

requirements)

Create an EU repository of

PEF results for products

(participation voluntary or

mandatory depending on the

125

policy)

Other

If other, please specify:

(31) What actions related to the Organisation Environmental Footprint method

(OEF) would be effective to trigger the uses of environmental information

you consider important?

Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion





communicating






party

Use OEF indicators in the

EU Eco-Management and

Audit scheme (EMAS)

reporting

Promote more harmonised

reporting based on (but not

limited to) the OEF for the

environmental pillar of non-

financial reporting

Provide an EU registry of

OEF results for companies



policy)

Create an EU rating scheme

for environmental

performance of companies,

based on (but not limited to)

126

the OEF

Other


(32) Do you think there should be specific provisions for SMEs?

Micro companies should be exempted from legislative requirements

Calculation tools for non-experts should be available

No specific provisions are necessary


(33) If you chose “calculation tools should be available”, please specify who

should develop these?

Best Good Less

appropriate

Worse No

opinion


Public administrations,

coordinated by the

European Commission

Sectoral/trade associations

Individual businesses (free

market of tools)

Other


(34) Do you think that the European Commission should work on specific

strategic sectors?

Yes, based on potential environmental impact

Yes, based on importance for the EU economy

127

Yes, based on importance for capital markets (e.g. market capitalisation of a sector)

and/or financial stability

Yes, based on a combination of factors (environmental impact and importance for

the EU economy)

The decision should be left to industry

I don’t know/ no opinion

(35) Do you think that the scope of the EU Ecolabel should be extended to food,

feed and drinks?

Yes

No

I am not sure

Please explain your choice:

(36) What communication requirements related to environmental information

would be most effective in your opinion for products?

Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion


compliance with


Fines for breaching


Prescribe minimum


prescribing the format

Prescribe a format for

communicating to

consumers (to use e.g. on a

label, on-shelf information,

online etc.)


communicating to business

128

partners



chain (e.g. through

barcodes)


(communicating information

is voluntary, verification is

mandatory)

Other


(37) Which of the following approaches to verification should be used with

reference to information produced based on PEF/OEF methods?

Strongly

disagree

Moderately

disagree

Moderately

agree

Strongly

agree

Don’t

know/No

opinion

No need for verification, self-

declarations are sufficient

Member States should be responsible

for monitoring that the information

communicated complies with the

requirements

An independent third party (whose

costs are covered by who is producing

the information) should verify the

information meets requirements

before it is communicated

(38) Where should Product Environmental Footprint information on products be

available?

Only directly on the product (e.g. on a label)

Near the product (e.g. on shelf, leaflet provided with the product)

Only online (e.g. linked to the product with a QR code or barcode)

129

On or near the product and online

Other

No opinion

If you chose other, please specify

(39) What communication requirements would be most effective in your opinion

for organisations (e.g. companies)?

Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion

Prescribe minimum



Prescribe a reporting format

Other


(40) Please provide any further comments, explanations or suggestions (for

example other measures to improve the availability and comparability of

environmental information).

Click here to upload a position paper.

130

Annex 4


investors and financial institutions

Introduction


Footprint (PEF and OEF) methods, recommending public and private organisations to use them

for measuring and communicating the life cycle environmental performance of products and

organisations64.














The aim of the rules is provide a clear set of instructions for calculating the Environmental




environmental issues that are most relevant for the given product group or sector and ensure a

high-quality analysis of these issues.
















131





single set of high quality secondary (average 3rd party) data. As a further action to enhance access

to the methods, these data are going to be made available for free to any user of the product group

and sector-specific rules until 2020.


audits and a focus on data that have the most impact on the final results, which are mostly data












into existing policies such as the EU Ecolabel and Green Public Procurement; or the development

of a new, stand-alone instrument implementing the methods.

The tool also has the potential to support the implementation of the Action Plan on Sustainable

Finance. Among the potential applications, it is possible to envisage a role for the PEF and the

OEF to help define a taxonomy for sustainable finance (i.e. a classification of sustainable

economic activities)70 and as a basis for developing low carbon benchmarks and positive carbon

impact benchmarks71. OEF results may also be used as a basis for determining the environmental

performance of financial instruments.





only in English)




69 Final report on the assessment of different communication vehicles ofr providing Environmental












132




EU citizen


Non-EU citizen


Public authority

Trade union

Other









anonymous.

Anonymous



published.

Public











133

Yes

No

Do not know









(9) Which category best describes you or the organisation you represent?

Institutional investor

Asset manager

Auditing

Banking

Credit rating agency

Insurance

Pension fund

Financial advice

Index provider

Association related to investment

Association related to finance

Other (please specify):

(10) Scope

Local

Regional

National


134

EU-wide

International

No answer

(11) Total assets in management (if applicable, in EUR, as of 15 March 2018)

(12) Indicate whether the answer to the question above should be kept

confidential.

Yes, keep answer confidential

No






stakeholder

I am aware of the EU Environmental Footprint methods


None of the above


FOOTPRINT

B.1 Input on the importance of environmental information

(14) To what extent do you agree with the following statements?

Strongly

agree


disagree


for measuring


of organisations

Quantified information on

the environmental

performance of

organisations is insufficient

135

We prefer to invest in

companies with a good

environmental reputation

(please answer if you are an

investor)

Environmental performance

in the supply chain is

important

The environmental

performance of its products

is important to judge a

company’s environmental

reputation

I expect that companies

with a sound environmental

strategy would perform

better economically

All companies should

measure their environmental

performance




invest

Market opportunities for

companies producing green

products or providing green

services are growing

(15) What importance do you assign to the following types of environmental

information on organisations (e.g. companies)?

Very

important

Quite

important

Less

important

Not

important

No

opinion


to the organisation (e.g.

operations that are owned)

Information considering

environmental impacts

generated when producing

136

the company’s product

portfolio (activities owned

and operated, but linked to

the products of the

company)

Environmental impacts in

the supply chain of the

organisation



(e.g. climate change or water

use)

Information only related to

the most relevant

environmental impacts

(those cumulatively

contributing to 80% of the

total impact)

Comparative information

based on a common metric

(16) What importance do you give to the following features of/ approaches to

environmental information?

Very

important

Quite

important

Less

important

Not

important

No

opinion

A single method for


performance, applied in the

EU

A common reporting format

on environmental impacts

Compare the environmental


with the same main function

(e.g. two pairs of trousers)

Compare the environmental

performance of organisations

with a similar product

portfolio

137

Environmental information

should be reproducible

(repeated calculations on the

same organisation should

give the same result)


should be available on all

products


should be available for all

companies


should be verified by an

independent 3rd party

B.2 Input on experience with environmental information



Yes

No

I don’t know



Agriculture

Apparel & footwear

Banking

Chemicals



Food and beverages

Insurance


138

Retail & wholesale

Tourism

Other


(19) Do you require environmental information from companies?

Yes

No

(20) If yes, what kind of environmental information do you require?

Qualitative information on the environmental strategy of the company/ organisation

Existence of an environmental management system (e.g. EU Eco-Audit and

Management Scheme or ISO 14001)

Information on environmental credentials of the company’s products

Environmental or sustainability report

Reply to a questionnaire (e.g. through the CDP – formely Carbon Disclosure Project

– or questionnaires developed by the investor) (please specify which):

Global Reporting Initiative indicators

GHG emissions (please specify method required):

Life Cycle Assessment indicators (please specify method and impact categories

required)

Performance within a sustainability index (please specify which)


(21) How do you use environmental information?

We keep record of it

We assess environmental risks related to the company

We only invest in companies above a certain threshold of environmental

performance

We use them in sustainability indices

139

We assess the environmental performance of our own portfolio


(22) In your opinion, which developments are needed so that environmental

considerations are systematically built into decision-making in the financial

sector?

Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion

Information on the most

relevant environmental

impacts and processes in a

given sector

Comparable performance

results on environmental

impacts relevant for a sector

Monetisation of impacts

Other


B.3 Input on the potential use of the Product and Organisation

Environmental Footprint (PEF and OEF) methods for providing


(23) You are interested to reply to

(a) Options related to environmental information on organisations

(b) Options related to environmental information on products

(c) Both



Very

important

Quite

important

Less

important

Not

important

No

opinion

140

European Union


NGOs

Private sector

Other




Very

important

Quite

important

Less

important

Not

important

No

opinion





of clothing)





allows to compare


performance in a sector




rules






and if primary data can be

accessed

141



data



analysis


system


Best Good Less

appropriate

Worse No

opinion



The private sector,



from stakeholders

Standardisation


Committee for


EU rules



sector and other

stakeholders

Other




Best Good Less

appropriate

Worse No

opinion


142

The private sector



sector



(28) What actions related to the Product Environmental Footprint methods (PEF)


consider important?

Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion





communicating






party




on products (it is not

mandatory to communicate

environmental information,

but if communicated, the


the PEF method)


for measuring and



of products

Use the PEF in the


143

criteria






thresholds to access the EU

Ecolabel scheme









applying the Unfair


Directive




is not mandatory to


information, but if



requirements)





policy)

If other, please specify (please also include ideas on how to facilitate the access of

SMEs, if any)

(29) What actions related to the Organisation Environmental Footprint methods



144

Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion



Audit scheme (EMAS)

reporting (voluntary)





financial reporting





policy)


for environmental



the OEF

Other

If other, please specify (please also include ideas on how to facilitate the access of

SMEs, if any)


strategic sectors?




and/or financial stability.


EU economy)


I don’t know/ No opinion

145



Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion


compliance with


Fines for breaching


Prescribe minimum




communicating to



online etc.)



partners



chain (e.g. through

barcodes)




mandatory)

Other



reference to information produced based on PEF/OEF methods

Strongly Moderately Moderately Strongly Don’t

know/No

146

disagree disagree agree agree opinion

No need for verification, self-declarations

are sufficient




requirements






(33) Where should Environmental Footprint information on products be

available?





Other

No opinion




Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion

Focusing on a common

method per sector (applied

either voluntarily or on a

mandatory basis)

Prescribe minimum


147



Other






148

Annex 5


public administrations and international institutions

Introduction




organisations72.



































149

































only in English)
















150




EU citizen


Non-EU citizen


Public authority

Trade union

Other









anonymous.

Anonymous



published.

Public











151

Yes

No

Do not know










International organisation

Public administration at national level

Public administration at regional level

Public administration at local level

(10) Please specify the type of activities your organisation is performing

Policy-making at supra-national level

Policy-making at national level

Policy-making at regional or local level

Policy implementation at international level

Policy implementation at national level

Policy implementation at regional or local level


(11) Please specify the main area you are concerned with

Agriculture

Consumer policy

Climate policy

Energy policy


152

Environmental policy

Financial policy

Industrial/ economic policy

Research/ innovation policy

Trade policy

Other


EU Ecolabel

Other ecolabels (e.g. Nordic Swan, Blue Angel, etc)

EU Organic label

National organic label



Carbon reporting

Environmental, Social and Governance (ESG) reporting

Life Cycle Assessment in policy-making or implementation (please give an

example)


FOOTPRINT

B.1. Input on the importance of environmental information



Strongly

agree


disagree








153



There are too many



of companies





their environmental

performance


available on the






invest



performance



Very

important

Quite

important

Less

important

Not

important

No

opinion





energy use etc.)


organic, covered by


system)

154










The most relevant


the product (those



Information on the






worse)






Ecolabel)

B.2. Input on experience with environmental information




Yes

No




155






add it here)



Yes

No

I don’t know



Yes

No

I don’t know



Agriculture

Apparel & footwear

Banking

Chemicals



Food and beverages

Insurance


Retail & wholesale

Tourism

Other


156

(19) Do you require environmental information from your suppliers?

Yes, I require specific certification/ label/ method

Yes, I require environmental information, but I don’t specify what should be the

content

No

If requiring specific certification/label/method, please specify:

B.3. Use of the Product and Organisation Environmental Footprint methods

(PEF and OEF)






stakeholder




(21) Did you apply the PEF or OEF method?

Yes, PEF

Yes, OEF

We are considering to apply it

No

(22) If the answer is yes, what were your main motivations for applying (or

considering to apply) the PEF or OEF methods?

Strongly

agree


disagree

Demonstrating market

leadership

157

We expect EU policies

related to the methods

We support having a

common method for


performance

We wanted to understand

differences with other

approaches we use

We expect that it will

improve the organisation’s

reputation

We expect environmental

improvements based on the

exercise

We expect cost reductions

based on the exercise

Other


(23) If the answer is no, why not?

Waiting for the revised methods after the Environmental Footprint pilot phase

There are no Product Environmental Footprint Category Rules or Organisation

Environmental Footprint for my product/ sector

Waiting for policies applying the methods

Will apply only if required by legislation

Already apply other method

Not a priority for us




Very Quite Neutral Less Not

useful at

158

useful useful useful all



















Category Rules

The environmental










the benchmark

B.4. Input on the potential use of the Product and Organisation





Very

important

Quite

important

Less

important

Not

important

No

opinion

159

European Union


NGOs

Private sector

Other




Very

important

Quite

important

Less

important

Not

important

No

opinion





of clothing)





allows to compare






rules






and if primary data can be

accessed



160

data



analysis


system


Best Good Less

appropriate

Worse No

opinion



The private sector,



from stakeholders

Standardisation


Committee for


EU rules



sector and other

stakeholders

Other




Best Good Less

appropriate

Worse No

opinion


The private sector

161



sector





consider important?

Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion





communicating






party






information, but if

communicated, the


the PEF method)


for measuring and



Use the PEF in the


criteria

Use PEF benchmarks


162



scheme




Sustainable Investments









applying the Unfair


Directive




is not mandatory to


information, but if



requirements)





policy)

Other





163

Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion





communicating






party



Audit scheme (EMAS)

reporting





financial reporting





policy)


for environmental



the OEF

Other




164






Best Good Less

appropriate

Worse No

opinion



coordinated by the

European Commission



market of tools)

Other



strategic sectors?






the EU economy)



165


feed and drinks?

Yes

No

I am not sure




Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion


compliance with


Fines for breaching


Prescribe minimum




communicating to



online etc.)



partners



chain (e.g. through

barcodes)




mandatory)

166

Other




Strongly

disagree

Moderately

disagree

Moderately

agree

Strongly

agree

Don’t

know/No

opinion

No need for verification, self-

declarations are sufficient




requirements







available?





Other

No opinion


167



Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion

Prescribe minimum




Other






168

Annex 6


method and initiative owners

Introduction




organisations80.



































169

































only in English)
















170




EU citizen


Non-EU citizen


Public authority

Trade union

Other









anonymous.

Anonymous



published.

Public











171

Yes

No

Do not know










Standardisation body

Other business-led method/ initiative owner

Investor-led method/ initiative owner

Other public administration led method/ initiative owner

Multi-stakeholder led method/initiative owner


(10) You are active on

Local level

Regional level

National level

EU-wide level

International level

(11) Please specify if you are active in specific sectors (several answers possible)

Potentially all sectors/ products

Agriculture

Apparel & footwear

Chemicals


172



Food and beverages

Forestry


Retail & wholesale

Banking

Insurance

Tourism

Other


(12)

(13) Please specify the type of the method/initiative (several answers possible)

Life Cycle Assessment based

Non-LCA (please specify)

Multi-criteria

Single indicator

Organisation-level reporting

Product-related information

Label

Focussed on best in class products/ organisations

Environmental product declaration

Company rating scheme

Certification


173

B. QUESTIONNAIRE ON THE FUTURE USE OF ENVIORNMENTAL

FOOTPRINT




Strongly

agree


disagree










There are too many



of companies





their environmental

performance


available on the






invest



174

performance



Very

important

Quite

important

Less

important

Not

important

No

opinion





energy use etc.)


organic, covered by


system)










The most relevant


the product (those



Information on the






worse)






175

Ecolabel)





Yes

No



Yes

No








add it here)



Yes

No

I don’t know



Yes

No

I don’t know

176



Agriculture

Apparel & footwear

Banking

Chemicals



Food and beverages

Insurance


Retail & wholesale

Tourism

Other


(22) Do you experience growing demand to apply the method/ initiative?

Yes

No

Don’t know

(23) How many companies or products are using your method/ initiative?

(24) Please give a range of cost of applying the method, stating basic conditions

(e.g. simple product, large organisations, etc.)

(25) Indicate whether the answer to the question above should be kept

confidential

Yes, keep answer confidential.

177

No

(26) For what purposes is your method/ initiative used in practice?

Internal performance tracking

Communication purposes (on environmental credentials of products or

organisations)

Enhancing good reputation

Get access to investors

Participate in rankings

Other

Don’t know


(PEF and OEF)






stakeholder




(28) Did you consider to apply PEF or OEF as a basis of your method/initiative?

Yes

No

Don’t know




178

Very

useful

Quite

useful

Neutral Less

useful

Not

useful at

all



















Category Rules

The environmental










the benchmark






179

Very

important

Quite

important

Less

important

Not

important

No

opinion

European Union


NGOs

Private sector

Other




Very

important

Quite

important

Less

important

Not

important

No

opinion





of clothing)





allows to compare






rules







180

be accessed



data



analysis


system


Best Good Less

appropriate

Worse No

opinion



The private sector,



from stakeholders

Standardisation


Committee for


EU rules



sector and other

stakeholders

Other




Best Good Less

appropriate

Worse No

opinion

181


The private sector



sector





consider important?

Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion





communicating






party






information, but if

communicated, the


the PEF method)


for measuring and



Use the PEF in the

182


criteria

Use PEF benchmarks




scheme




Sustainable Investments









applying the Unfair


Directive




is not mandatory to


information, but if



requirements)





policy)

Other


183




Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion





communicating






party



Audit scheme (EMAS)

reporting





financial reporting





policy)


for environmental



the OEF

Other


184








Best Good Less

appropriate

Worse No

opinion



coordinated by the

European Commission



market of tools)

Other



strategic sectors?






the EU economy)


185



feed and drinks?

Yes

No

I am not sure




Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion


compliance with


Fines for breaching


Prescribe minimum




communicating to



online etc.)



partners



chain (e.g. through

barcodes)



186


mandatory)

Other




Strongly

disagree

Moderately

disagree

Moderately

agree

Strongly

agree

Don’t

know/No

opinion


are sufficient




requirements







available?





Other

No opinion


187



Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion

Prescribe minimum




Other






188

Annex 7


NGOs

Introduction




organisations88.



































189

































only in English)
















190




EU citizen


Non-EU citizen


Public authority

Trade union

Other









anonymous.

Anonymous



published.

Public











191

Yes

No

Do not know









(9) Please specify the focus of the activity of the NGO you represent

Consumers

Environment


(10) Where are you active?

Local

Regional

National

EU

Worldwide


FOOTPRINT




Strongly

agree


disagree


192








measuring companies’


There are too many



of companies





their environmental

performance


available on the






invest



performance



Very

important

Quite

important

Less

important

Not

important

No

opinion

193





energy use etc.)


organic, covered by


system)










The most relevant


the product (those



Information on the






worse)






Ecolabel)





194

Yes

No



Yes

No








add it here)



Yes

No

I don’t know



Yes

No

I don’t know



Agriculture

Apparel & footwear

Banking

195

Chemicals



Food and beverages

Insurance


Retail & wholesale

Tourism

Other


(19) In your experience, are citizens increasingly interested in greener

consumption?

Yes

No

Don’t know


(PEF and OEF)






stakeholder

I am aware of the EU Environmental Footprint pilot phase, but was not involved



196




Very

useful

Quite

useful

Neutral Less

useful

Not

useful at

all



















Category Rules

The environmental










the benchmark




197



Very

important

Quite

important

Less

important

Not

important

No

opinion

European Union


NGOs

Private sector

Other




Very

important

Quite

important

Less

important

Not

important

No

opinion





of clothing)





allows to compare






rules





198



be accessed



data



analysis


system


Best Good Less

appropriate

Worse No

opinion



The private sector,



from stakeholders

Standardisation


Committee for


EU rules



sector and other

stakeholders

Other




199

Best Good Less

appropriate

Worse No

opinion


The private sector



sector





consider important?

Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion





communicating






party






information, but if

communicated, the


the PEF method)


for measuring and


200


Use the PEF in the


criteria

Use PEF benchmarks




scheme













applying the Unfair


Directive




is not mandatory to


information, but if



requirements)





policy)

Other

201





Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion





communicating






party



Audit scheme (EMAS)

reporting





financial reporting





policy)


for environmental



the OEF

Other

202









Best Good Less

appropriate

Worse No

opinion



coordinated by the

European Commission



market of tools)

Other



strategic sectors?






the EU economy)

203




feed and drinks?

Yes

No

I am not sure




Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion


compliance with


Fines for breaching


Prescribe minimum




communicating to



online etc.)



partners



chain (e.g. through

barcodes)

204




mandatory)

Other




Strongly

disagree

Moderately

disagree

Moderately

agree

Strongly

agree

Don’t

know/No

opinion


are sufficient




requirements







available?





Other

No opinion

205




Very

effective

Effective Slightly

effective

Not

effective

at all

No

opinion

Prescribe minimum




Other




