In this issue the GreenLight Alliance breaks down the various environmental claims made by manufacturers, and the ways in which they can be applied to different needs.

How many times have we heard that a certain product is “Eco-Friendly” or that a new packaging is “Green”? Perhaps more recently we have also read a webpage or report stating that a luminaire or component is associated with a certain quantity of kg CO2 equivalent emissions, or that a production process emits X% less CO2, compared to another. All these examples represent environmental communications or claims; however, they are fundamentally different in the information they convey and in the way they are communicated. In this article we will define and explore different types of environmental claims and understand their context of validity and how they can be applied to different communication needs. 

Introduction & Context

An environmental claim is an assertion made by an organisation about a product, service, process or brand related to their effect on the environment – in the most generic sense or connected to specific aspects and environmental burdens. Claims can be made referring to a product as a whole or to parts of the product, its packaging, the way it is used or disposed of.

As a result of increasing concern towards the consequences of industrial activities on the environment, organisations are interested in declaring that their products exhibit positive environmental impacts. Environmental claims are being increasingly used as a marketing tool to attract customers; however, sometimes they are very generic (“energy efficient”, “low carbon”, “sustainable”, etc.), which poses a risk to credibility if unsubstantiated. These claims could either exaggerate some environmental aspects of the product or even be completely false – referred to as “greenwashing”.

Considering the influence that these claims potentially have on consumers, standards are in place to protect them and prevent the circulation of misleading environmental communications. A misleading claim is defined as a statement made by a business omitting or hiding information with the intent of giving the impression that their product does not have negative effects on the environment (1).

To make sure practices are aligned, international standards regulating labelling and environmental claims exist and classify claims based on what they communicate and the evidence behind them. Under the overarching ISO 14020 standard (Environmental statements and programmes for products: principles and general requirements), we can find specific standards identifying and explaining the three main types of environmental claims: Type I (or Ecolabels), Type II (or self-declarations) and Type III (or Environmental Product Declaration, EPD).

Type I, II, and III Claims

The standard ISO 14020:2023 is the core standard regulating the practice of producing environmental statements. The standard defines the basic principles that should be followed before environmental claims are created, including clearly specifying the type of statement, the criteria and the methodology used to produce it. Fundamental concepts behind any type of claims include: credibility, use of evidence-based methodologies, transparency and adoption of a life-cycle perspective. The criteria listed in ISO 14020 need to be followed in addition to those listed in other standards for specific claims.

Type I Claims, or Ecolabels

Relevant standard: ISO 14024:2018 – Environmental labels and declarations. Type I environmental labelling: principles and procedures.

Type I environmental claims are voluntary in nature and their overall goal is to communicate that a product or service meets the requirements of a specific labelling programme, related to environmentally beneficial aspects. The process starts with a preliminary feasibility study on the potential product categories that will be subject of the claim. Environmental criteria will then be evaluated, linked to specific product life-cycle stages, and the labelling programme will identify the most relevant areas to address using qualitative and quantitative approaches.

In order to certify the claim, a third-party verification is carried out, assessing whether the claim follows the criteria of the labelling programme. During this step, additional documentation may be requested to support the declaration. After the third-party verification is concluded, the licence to use the ecolabel is awarded to the organisation making the claim.

Type II Claims, or self-declarations

Relevant standard: ISO 14021:2016+A1:2021 – Environmental labels and declarations. Self-declared environmental claims (Type II environmental labelling).

Type II environmental claims are voluntary statements, symbols or graphics placed on the product, packaging or in literature related to the product. The goal of self-declared claims is to highlight aspects of products or services which cause less burdens on the environment. Due to the nature of these claims, it is fundamental that they are genuine, verifiable, scientifically sound and non-misleading. Several fixed requirements apply to Type II claims, such as a ban on vague claims (e.g. environmentally friendly, green, etc.) and on claims of sustainability – due to the high complexity of this concept and the absence of methods able to confirm the achievement of sustainability.

Strict requirements also apply to comparative claims, which can only be made based on products achieving the same function and using published and recognised methods.

For a Type II claim to be verifiable and trustworthy, the necessary information should be publicly available and accessible, including the identification of the standards and methods used, evidence and test results and proof of conformity with the requirements of ISO 14021.

Type III Claims, or Environmental Product Declarations (EPD)

Relevant standard: ISO 14025:2010 – Environmental labels and declarations. Type III environmental declarations: principles and procedures.

Type III environmental claims (or EPDs) involve quantified environmental information on the life cycle of a product. This is the only type of declaration that must be based on Life Cycle Assessment (LCA) data produced in accordance with the ISO 14040 series of standards, while Type I and II only mandate the use of a life-cycle perspective. Additionally, Type III declarations are subject to the administration of a Programme Operator (PO) and must go through a third-party verification process. Like the other types of claims, the production of Type III declarations is voluntary.

In principle, Type III declarations are intended for users to compare the environmental performance on products; however, limitations apply to this practice: the function of the products, functional unit, system boundary, type of data (including data quality, coverage and sources), inclusion/exclusion criteria, data collection methods, calculation procedures, allocation rules and several other methodological aspects must be identical or equivalent.

In addition to the requirements of ISO 14025, Type III declarations must comply with sets of rules produced by a Programme Operator; these are identified as Product Category Rules (PCR). These will contain criteria related to specific sectors, geographical regions, methodological aspects to follow for the LCA and reporting format for the declaration.

Verification procedures are also established by the Programme Operator; verification includes checking LCA data and conformance with ISO 14020, relevant PCR and other relevant ISO standards.

Examples of different claims and what they “unlock”

While the requirements of the ISO standards do not mandate the actions of a company from a legal perspective, the nature of the different environmental claim types makes them more or less suitable to be used in specific circumstances. To better understand the validity of these claims and what a company or organisation can achieve with them, let’s look at some examples.

Type I

Among the most popular Type I labels in Europe (2) we can find the Cradle-To-Cradle (3) certification. This is an international, multi-attribute programme addressing several environmental aspects of products, focusing on circularity and material health attributes. This label is being increasingly used, also by lighting manufacturers.

Type I claims are powerful marketing tools. This means, not only they highlight products for consumers looking to make informed decisions, but could also make it easier to obtain credibility and even additional certifications, nationally and internationally. A company submitting their product for an eco-label is not necessarily communicating quantitative environmental impacts regarding that product, but is rather letting consumers know that there is a (verified and certified) aspect of the product related to positive environmental performance, which makes the product stand out compared to others in the market.

Type II

There is no set format for self-declared claims. An example of this type of communication could be the declaration that a luminaire’s packaging can be recycled. However, when this is only indicated with the use of the Mobius loop symbol, without any explanatory statements, the claim risks being misleading. An example of explanatory statement accompanying this type of claim could be: “The plastic of this packaging is polyethylene, which can be recycled at any plant in [location].”

Before being able to declare this, the company making the claim must verify that the declaration is true, and be able to produce and provide documentation supporting this to any party requesting it. Another scenario where a Type II claim is used and substantiated is, for example, a company declaring that a luminaire is associated with a certain amount of Greenhouse Gas emissions (expressed in kgCO2e, for example referring to the embodied carbon), also providing background information in the form of an LCA report.

The benefits that can be unlocked through these claims, similar to Type I communications, are mostly related to marketing and differentiation purposes. This type of claims is also often linked with customer engagement, as customers willing to make more environmentally informed decisions will be inclined to value the communication and even reach out to the company for further information.

Type III

Environmental Product Declarations must be reported following specific templates and including environmental impacts connected with the product’s life cycle and with multiple impact categories. While Type I and Type II can be targeted towards specific aspects (with some limitations), Type III declarations must be comprehensive of as many impact categories as defined in the PCR and standards. EPDs can be created for single products, for a company’s average product or even for an entire industry’s average product. In the lighting industry, this topic is starting to gain momentum, with Programme Operators such as PEP Ecopassport or IBU Berlin offering PCR specific to luminaires.

EPDs contain detailed and quantified information on products and their environmental impacts and can only be published and distributed after third-party verification of the information they contain. Therefore, as opposed to the other types of environmental declarations, these two aspects make them suitable to be used for regulatory compliance requirements (related to environmental disclosure), public calls in the building sector, and compliance with building certification schemes (for example BREEAM or LEED).

However, in addition to this, a company investing in the capability of creating EPDs, will also unlock the capability to carry out Life Cycle Assessment studies. LCA will allow the company to assess the impact of their own decisions and operations, and potentially drive innovations connected with optimisation of product design, supply chain and overall cost and efficiency. This capability is enough to substantiate self-declared (Type II) claims; however, being able to demonstrate to customers that all this has been checked and verified by an independent organisation adds a layer of credibility to these efforts, which consumers value when being presented with environmental information.

Conclusions

Considering the power that environmental claims can have on consumers, it is important to be able to navigate in the ocean of environmental labels and claims that characterises the marketplace nowadays. A recent survey study by McKinsey (4) revealed that over 60% of the respondents would be willing to pay more for a product advertised to have sustainable packaging. However, a recent study (5) on consumers’ behaviour also suggested that unsuspecting consumers are not able to identify greenwashing or misleading green claims on products, but become more aware of it when prompted.

As an industry we have the responsibility to provide the consumers with honest environmental claims and allow them to make meaningful and informed decisions on their purchases. This can only be achieved with fair market practices, consumer education and a ban on misleading claims, as already highlighted by governmental action such as the European directive on Green Claims (6) or the Green Claims Code campaign in the UK (7).

The communication of Type II claims has the potential to be an important stepping stone for lighting manufacturers willing to transparently declare environmental impact information on their products: carrying out LCA on products following relevant PCR and standards and sharing the results in the form of a report is a valid strategy that allows for more environmental information at product level to be circulated. These reports cannot be categorised as EPDs, because they would not necessarily go through a third-party verification, however they still contain information that can be substantiated and justified if the criteria of ISO 14021 are followed, and the process is carried out transparently.

www.greenlight-alliance.com

 

References:

1. Competition and Markets Authority (Gov.UK). Making environmental claims on goods and services [Internet]. 2021. Available from: https://www.gov.uk/government/publications/green-claims-code-making-environmental-claims/environmental-claims-on-goods-and-services

2. GreenSpec. Type I “Ecolabels” commonly used in Europe [Internet]. Available from: https://www.greenspec.co.uk/ecolabels-used-in-europe/

3. Cradle To Cradle Institute. Cradle To Cradle [Internet]. Available from: https://c2ccertified.org/

4. McKinsey & Company. Consumers care about sustainability—and back it up with their wallets [Internet]. 2023. Available from: https://www.mckinsey.com/industries/consumer-packaged-goods/our-insights/consumers-care-about-sustainability-and-back-it-up-with-their-wallets

5. Fella S, Bausa E., Green or greenwashed? Examining consumers’ ability to identify greenwashing. J Environ Psychol, 2024 ;95(102281). Available from: https://www.sciencedirect.com/science/article/pii/S0272494424000549

6. European Commission. Green Claims [Internet]. Available from: https://environment.ec.europa.eu/topics/circular-economy/green-claims_en

7. UK Government. Green Claims Code [Internet]. Available from: https://greenclaims.campaign.gov.uk/