As some sectors develop environmental declarations, what are the prospects for full product transparency?
An exemplar of green innovation, US-based global carpet and floorings maker InterfaceFLOR has pushed sustainability boundaries for years. It has established best-practice benchmarks in everything from corporate sustainability reporting to full life-cycle analysis and closed-loop manufacturing.
Where Interface has led, others have soon followed.
Interface’s most recent step – posting the first environmental product declaration (EPD) in North America in June last year – has some observers predicting a day when consumers and businesses will be able to accurately compare products, their ingredients and the full impact of their manufacturing.
Like a food nutrition label, EPDs integrate diverse product performance information into a single, consumer-facing document. They reference the certifications achieved by that manufacturer and brand product, along with a range of product performance information, including all of the data in a third-party-certified life-cycle assessment (LCA).
Already hundreds of companies have voluntarily filed EPDs in Europe – a still-paltry number that has steadily grown since the completion in 2006 of ISO standards specifying independent, third-party EPD review and certification. In the past 18 months, standardisation committees began finalising critically important product category rules (PCRs), allowing comparisons between different products that provide the same service, for example carpeting and tiles.
Construction sector leads
PCRs are the foundation upon which EU construction products regulation is expected to follow soon. To date, it is the construction industry that has launched the earliest and most far-reaching EPD programmes.
With the exception of Japan, Europe’s decade-long project enabling EPD harmonisation is far ahead of comparable developments elsewhere, such as in the US with its lightly regulated building market. Thus, Interface’s North American EPD posting is not yet an operational reality. Rather, it is a signal to US companies: get ahead of the curve because EPDs will soon become the new sustainability standard.
But whether, in fact, this new era of full product transparency will be borne out remains open to debate.
Interface’s European sustainability director, Ramon Arratia, is the man largely responsible for driving the commitment to eliminate by 2020 any negative impact Interface has on the environment.
Arratia highlights the EPD posting of a modular carpet with post-consumer nylon, one of the company’s recent technological advancements in carpet recycling. The innovation lowers the product’s environmental impact across a range of life stages but it also precisely spotlights how the continuing use of virgin nylon accounts for 39% of the overall climate changing potential.
Impacts associated with raw materials extraction and processing, product use and end life, in many cases far outstrip the “in-house” impacts. In the case of carpets, 70% of that impact is in the raw materials phase.
Arratia believes EPDs can help Interface drive down the numbers by publishing details of every single raw material that goes into the product. The idea is that this disclosure will spur on yarn suppliers to provide more recycled content and thus move Interface towards satisfying its 2020 zero impact commitment.
“That’s the power of analysing and disclosing the impact, creating a kind of competition based on pure environmental performance rather than marketing,” Arratia says.
The problem is that companies selectively apply those portions of the LCA most favourable to their product. That has led to a proliferation in single benefit claims that do not reflect the full environmental performance.
Product category rules solve this problem by adding an additional layer of specificity to the LCA process, dictating the scope, boundaries, data quality and impacts to be considered for a given product category.
In the case of floor coverings, Interface came up with a new way of installing its modular carpet without having to use adhesives, an innovation that lessens its impact across a number of life stages.
“We did calculate for adhesives, but you don’t have to. That’s the problem,” says Arratia. “Another manufacturer can do a similar LCA and they don’t include the calculation.” This means, he argues that they are not comparable – a problem solved by product category rules. “They really tell you what to include.”
Companies with existing LCA processes may find EPD filings a fairly straightforward process – once they have the formula in place, and once they get their minds around the implications of full disclosure.
“Usually the calculation gets a bit more complicated because you have to be more transparent in your assumptions, and maybe you have to make some assumptions that are not so favourable to your product,” says Eva Schmincke of Five Winds International, a sustainability management consulting firm that verified Interface’s EPD posting.
The EPD has two parts, one that is LCA-based and the other covering performance data pertinent to human health, mechanics and safety.
A lot depends on the PCRs in place for a given product, something currently worked out by industry associations in collaboration with individual companies and verification experts.
“It is a very easy process for carpets,” says Edmund Vankann, managing director of the European carpet industry’s environmental association GUT. For Interface, working in conjunction with GUT, the process required only a slight tweaking of the existing LCA, Arratia says.
EPD development
GUT has developed a complete calculation tool that quickly creates EPD data sets. Vankann says: “We can make some case studies that meet the various what-if scenarios.” This means that if a producer thinks about changing raw materials or production processes, they can look at the overall effect the change will have on product performance.
For Fritz Egger, an Austrian-based producer of wood-based materials, the EPD process required a more involved recalculation of the LCA boundary systems in line with those defined in the PCR document. “We found it makes sense to make your own LCA and not rely only on generic data,” says Jana Sprockhoff, Egger’s product manager for construction products.
The EPD didn’t so much lead Egger to any design innovation breakthroughs, but has been used more as a tool for confirming and communicating positive environmental attributes that the company was unable previously to quantify. “Our direct competitors in brick, steel and concrete are all doing this,” Sprockhoff says.
The upbeat reaction among European companies may not play out as positively in the US. One manufacturer there portrays industry associations as no better than paid promoters existing solely to help their members increase sales.
“The industry associations don’t understand enough about sustainability to really have any sense of what product category rules should be,” says James Sheppard, chief executive of California-based Vetrazzo, a producer of recycled glass surfacing materials for which it filed an EPD in early 2010.
Vetrazzo, like Interface, looked to The Green Standard, a US not-for-profit company, with programme operator status, that ensures PCRs are developed in a transparent and fair fashion according to international standards.
Publishing template
Established under ISO 14025, programme operators create a template enabling manufacturers to publish their EPDs, says Deborah Dunning, The Green Standard’s chief executive.
“We do not verify the LCAs and therefore we are not determining whether the product category rules are valid. That’s done by verifiers,” Dunning says. These are independent third-party experts, which in the case of Vetrazzo and Interface were industry associations, verification specialists and programme operators in Germany.
Dunning says a time-efficient systems approach is required. “Most importantly, we provide education and training to anyone interested in developing and using an EPD.”
It’s a challenge exemplified by the experience of Shaw Industries, a US floor manufacturer that enrolled in The Green Standard’s early adopter EPD programme in 2008 and subsequently dropped out, choosing to produce instead a self-declared Type II eco-label.
“In order to do a truly comparative LCA across the product life-cycle, one would need to know, in great detail and accuracy, the entire supply chain, manufacturing processes, logistical and other data to perform the analysis for both products being compared,” says Richard Ramirez, Shaw’s vice-president for corporate sustainability and environmental affairs.
Ramirez asserts that few manufacturers will have intimate knowledge of each other’s product cycles that would allow them “to make the accurate case in a credible comparative manner”.
That’s an understandable, yet misinformed, observation made by a US manufacturer not privy to the lengthy deliberations conducted by the European floor covering associations and their member companies, says GUT’s Vankann. “We first made generic EPDs, which are based on average data coming from many producers that provide production data,” he says. The data was then refined using EPDs filed by individual companies. But, “the data remains in the background”, which means there is confidentiality of all proprietary trade information.
Ramirez insists that Shaw is not afraid of full product transparency. “This does not create a scary situation for companies,” he says. Rather, he argues, it is a difficult task, reaching deep into supply chains and then determining how to “appropriately fund and manage intellectual property and confidential information in the spirit of full transparency”.
However valid Shaw’s misgivings, it may soon find itself forced to come on board.
Already the US Green Building Council is piloting EPDs and is considering credit inclusion for as early as 2012, confirms Scot Horst, a senior vice-president for the environmental buildings standard Leed at the US Green Building Council. Likewise, in Europe various green building associations are now working to harmonise their systems through the Paris-based Sustainable Building Alliance.
“I see EPDs [as] central to our strategy for materials,” Horst says, while also expressing concerns owing to the US government’s benign regulatory presence. “You are using data to make comparisons that impact people’s businesses and that means everyone wants some kind of level playing field.”
Energy tool
Ultimately, EPDs are supposed to give architects and designers a tool to calculate embodied energy of an entire building based on a component breakdown of materials, encompassing everything from concrete and wallpaper, to wood products, ceiling tiles and office furniture.
But that day is not yet here. First the various green building associations have to align their approaches, Horst says. “Even in Europe, in most of the systems you are given credit for providing an EPD but you aren’t given credit as a designer based on how you use it.” Horst believes that there is still much work to do before there is enough data to actually make the declarations properly useful.
Nevertheless, Interface’s EPD filing does represent the kind of milestone portending a shift towards a system capable of beating back the tsunami greenwash marketing blitz. “We have the potential to standardise environmental information,” Arratia says, “now that we have the product category rules in place.”