requirements for epd

ECOPLASBRICK Deliverable N°4.1 1

CIP-Eco-innovation Pilot and market replication

Grant Agreement number: ECO/10/277233

ECOPLASBRICK

Innovative recycled plastic based panels for building field

Deliverable N° D4.1

Title Requirements analysis for Eco-Label and Environmental

Product Declaration

Name of the Author

Partner

Telephone

e-mail

Tiziana Sorice

Consorzio TRE

+39 081 7256211

[email protected]

Deliverable

Responsible Consorzio TRE

Dissemination level PU

Due date 29th

June 2012

Submission date 29th

June 2012

Status Rev.0 - Draft

Disclaimer

The information in this document is provided as is and no guarantee or warranty is given that the information is

fit for any particular purpose. The user thereof uses the information at its sole risk and liability. The document

reflects only the author’s views and the Community is not liable for any use that may be made of the information

contained therein.


Table of content

1 Introduction ....................................................................................................................... 3

2 The ISO 14020 series - Environmental labels and declarations ........................................ 3

2.1 Type I ....................................................................................................................... 4

2.1.1 Eco-Label ........................................................................................................... 4

2.2 Type II ...................................................................................................................... 4

2.3 Type III ..................................................................................................................... 5

2.3.1 EPD – Environmental Product Declaration ....................................................... 5

3 Product Groups and Categories currently regulated by the marks .................................... 6

3.1 Eco-Label Product Groups ....................................................................................... 6

3.2 EPD – Product Categories ........................................................................................ 6

4 Procedure for the eco-brand application .......................................................................... 9

4.1 Eco-Label ................................................................................................................. 9

4.1.1 Eco-label - realization time and mark time validity ......................................... 11

4.2 EPD ........................................................................................................................ 11

4.2.1 EPD - realization time and mark time validity ................................................. 13

5 Labeling Type I - Ecolabel .............................................................................................. 14

5.1 Costs ....................................................................................................................... 14

5.2 New Product Groups .............................................................................................. 15

6 Labeling Type III – Environmental Product Declaration ................................................ 15

6.1 Costs ....................................................................................................................... 15

6.2 New Product Category Rules ................................................................................. 16

7 Conclusion ....................................................................................................................... 16

8 References ....................................................................................................................... 17


1 Introduction

Research activities about Task 4.1 - Requirement Analysis for Eco-label and Environmental

Product Declaration - refers to the analysis of existing product groups and product categories

and related rules as well as the verification of compatibility of the Ecoplasbrick product for

the allocation of eco-environmental labels governed by ISO 14020.

Particularly, the activity in this document is the result of the analysis of two types of brands,

Eco-Label and Environmental Product Declaration EPD, and the verification of a product

compliance with the requirements of validity of labels. This research will support the

evaluation about the applicability for the Ecolabel and/or Environmental Product Declaration

to our innovative product and for the activities regarding Task 4.2 LCA; the aim is to support

and address the definition of the goal and scope for Life Cycle Assessment Analysis.

2 The ISO 14020 series - Environmental labels and declarations

The ISO 14020 series “Environmental labels and declarations – General Principles” is an

International Standard and establishes guiding principles for the development and use of

environmental labels and declarations. It is intended that other applicable standards in the ISO

14020 series be used in conjunction with this International Standard.

This International Standard is not intended for use as a specification for certification and

registration purposes.

Other International Standards in the series are intended to be consistent with the principles set

forth in this International Standard; the other standards currently in the ISO 14020 series are:

ISO 14021 – ISO 14024 – ISO/TR 14025.

Environmental labels, governed according to the ISO 14020, are labels applied directly to a

product or a service that provide information about the overall environmental performance of

the product/service throughout its life cycle (from production to use and disposal) or about

one or more specific environmental aspects.

There are three different types of eco-labels set up by the ISO 14020 series classified into

Type I, Type II and Type III.


2.1 Type I

Type I label is a voluntary eco-label covered by the ISO 14024 and based on a multi-criteria

system that considers the entire lifecycle of the product.

It’s used to certify products and services’ reduced environmental impacts and is subjected to

external certification by an independent body.

2.1.1 Eco-Label

The Eco-Label is the official European environmental certification which aims to identify

market products and services that have a reduced environmental impact. It was established in

1992 and is currently governed by EC Regulation n° 66/2010. The Eco-Label labeling

guarantees to consumers an aware choice and a purchase of an eco product/service less

damaging to the environment. For this reason, the Eco-Label labeling is defined B2C

"Business to Consumer" and it is attributed to a product or a service directed to the end user.

The Eco-Label cannot be issued to intermediate products and is not applicable to chain

products; the term product refers to both consumer goods and services.

The Eco-Label can meet the growing demand from consumers oriented to an environmental

choice.

It’s represented by a stylized daisy.

2.2 Type II

The Type II Ecological Labeling reports environmental self-declarations by the manufacturers

and suppliers about the ecological characteristics of the product. These self-declarations are

not validated or certified by an appropriate authority. Therefore, the responsibility for its use

is of the consumer himself.

It is governed by ISO 14021 which specifies the characteristics of so-called "claims"

(environmental claims) that communicate the significant environmental aspects along the life

cycle of the product, e.g.: the recycled content, recyclability or biodegradability of the

product, the absence of harmful substances for the environment, non-toxic or natural finishing

treatment, etc. .

The ecological label of the Type II refers to a single product and is defined B2C "Business to

Consumer" but can also be B2B "Business to Business".


2.3 Type III

The Type III eco-label statements are based on established parameters and contain a

quantification of the environmental impacts associated with the lifecycle of the product

calculated through a LCA; they are governed by ISO 14025 and subjected to independent

monitoring.

2.3.1 EPD – Environmental Product Declaration

The Environmental Product Declaration (EPD) is a voluntary product certification scheme

born in Sweden but of international importance; from a regulatory standpoint the EPD is

governed internationally by the Technical Report ISO / TR 14025:2000. The other references

are ISO standards that regulate the LCA methodology, which is the basis of calculating the

environmental performance communicated with the EPD.

The EPD is a tool designed to improve communication between producers, on the one hand,

and distributors and consumers, on the other, about their production environment strategies;

for this reason it is defined B2B "Business to Business".

The EPD is represented by a document containing the quantified environmental information

about the life cycle of a product, which was created by the manufacturer and/or supplier and

that, following a process of verification of data, accompanying the marketing of the product

described; therefore with the document it is possible to communicate objective, comparable

and credible information concerning the environmental performance of products and services.

These information have purely informational character, not foreseeing evaluation mode,

preferability criteria or minimum levels that the environmental performance must respect. The

label is checked and validated by an accredited independent body who guarantees the

credibility and veracity of the information contained in the LCA study and in the EPD

declaration.

Type I - Eco-Label Type I - Recyclable Type III - EPD

Table 1: Ecological labels


3 Product Groups and Categories currently regulated by the marks

3.1 Eco-Label Product Groups

The brand EU Eco-Label is structured in 13 products groups: it covers a huge range of

product groups, from major areas of manufacturing to tourist accommodation services.

For each group of product there are the corresponding subgroups for a total of 24 subgroups.

Key experts, in consultation with main stakeholders, develop the criteria for each product

group in order to decrease the main environmental impacts over the entire life cycle of the

product. Because each product has a different life cycle, a several ecological criteria for each

of them are defined, to which the product must conform to the purposes of allocation of the

mark. These criteria are present in the Commission Decision referred to each subgroup.

Every four years on average, the criteria are revised to reflect technical innovation such as

evolution of materials, production processes or in emission reduction and changes in the

market.

Product Groups for Eco-Label 1. Beauty care 8. Gardening

2. Cleaning up 9. Household appliances

3. Clothing 10. Lubricants

4. Do it yourself 11. Other household items

5. Electronic equipment 12. Paper products

6. Coverings 13. Holiday accommodation

7. Furniture

Table 2: The product groups for Eco-Label brand (update to June 2012)

Among existing product groups it’s interesting to evaluate COVERINGS subdivided in:

1. Wooden coverings;

2. Hard coverings;

3. Textile coverings.

3.2 EPD – Product Categories

An EPD is a certified environmental declaration developed in accordance with the standard

ISO 14025; the creation of EPD refers to 12 different product categories that contain PCR

(Product Category Rules).


Product categories for EPD

1. Agriculture, forestry and fishery products 7. Rubber, plastics, glass and, chemicals

2. Ores, minerales, stone, etc 8. Metal

3. Energy and water 9. Machinery and appliances

4. Food and beverages, etc 10. Transport equipment and services

5. Textile and furniture, etc 11. Services

6. Wood and paper 12. Constructions, construction products and construction

services

Table 3: The product category for EPD brand (update to June 2012)

The PCR is a product technical “card” that represents the rules to be followed in drafting the

EPD. In PCR the criteria for membership of a product to a particular category, the scope of

the study of the Life Cycle Assessment of the product (LCA), and environmental issues

relevant to that category, are defined.

There are PCR reported both to a PCR of product group (PCR Basic Module) and both to

single PCR product (PCR); the latter may be a sub-product of the PCR Basic Module or a

single PCR.

The work developing PCR documents is the probably most vital element to coordinate in a

proper way. The international EPD® system has therefore introduced a PCR classification

scheme building on a hierarchic approach to develop "PCR modules" in order to reduce the

workload and associated costs for developing, carrying out consultations and approving

PCRs.

The main rationale of the approach taken is to simplify and harmonize PCRs work and to

avoid market confusion and trade implications.

It’s not possible to use a PCR-Basic Module as Product Category Rules (PCR) when

developing an EPD: PCR Basic Modules provides a close to ready-made PCR document, but

they are generally not PCR documents in themselves.

PCR Basic Modules includes text which is common for all full PCR documents regardless of

product group, e.g. the introduction section, but does not specify the detailed calculation rules

that are required in order for EPDs of the same product group to be comparable.

If an EPD is developed based on a PCR Basic Module instead of a PCR, only a pre-

certification with a limited validity is possible to develop.


In order to PCR development, Product Category Rules shall be prepared in an open and

participatory process either by:

- companies and organizations in co-operation with other parties, such as branch-

and interest organizations;

- institutions involving LCA experts in close cooperation with companies or branch-

and interest organizations,

- or by single companies or organizations.

Developing PCR is a procedure including a staged approach with the following elements:

1. Initiation phase

2. Preparation phase

3. Consultation phase

4. Approval and publication phase

5. Updating phase

Regarding PCR document’s content, the PCR shall define the criteria according to assigning a

product to a specific category, which parameters are set out to prepare the EPDs, the data

quality requirements and the collection and calculation rules for data to be included in the

EPD, as well as what kind of information suitable to convey to the primary audience of the

EPD.

The PCR document shall include:

- Product category definition and description (e.g. function, technical performance

and use)

- Goal and scope of the PCR ( e.g. functional unit/declared unit, system boundaries,

description of data and data quality, cut-off rules and units to be used)

- Materials and substances to be declared in a content declaration

- Inventory analysis results (e.g. data collection and calculation procedures, and

- allocation of material flows and releases)

- Pre-determined parameters for reporting LCA data (e.g. inventory data categories

and impact category indicators), as appropriate

- Impact category selection and calculation rules, if applied

- Description of the type of information to be included for the downstream

processes, i.e. the use and end-of-life stages

- Rules for provision of additional environmental information

http://www.environdec.com/en/Product-Category-Rules/PCR-Development/Initiation-Phase/

http://www.environdec.com/en/Product-Category-Rules/PCR-Development/Preparation-Phase/

http://www.environdec.com/en/Product-Category-Rules/PCR-Development/Consultation-Phase/

http://www.environdec.com/en/Product-Category-Rules/PCR-Development/Approval-and-Publication-Phase/

http://www.environdec.com/en/Product-Category-Rules/PCR-Development/Updating-Phase/


- Instructions for converting the background data for the EPD format.

4 Procedure for the eco-brand application

4.1 Eco-Label

The procedure for requesting the brand Eco-Label is divided into 5 steps:

1. Identification of group membership

It’s necessary to check if the product/service meets the criteria adopted at European level for

that product group. On website http://ec.europa.eu/environment/ecolabel/products-groups-

and-criteria.html, for each product group there is the relative Commission Decision which sets

out the environmental criteria to which the product must be complies.

The EC Regulations 1221/09 and EMAS EC 66/10 ECOLABEL provide that each Member

State sets up the national Competent Bodies which are mandated with the task of applying the

Community schemes.

The Italian Ministerial Decree 413/95 established the Ecolabel Ecoaudit Committee to

perform the functions assigned to these Competent Bodies; for this purpose it has also

determined that it should use the technical support of ISPRA (Institute for

Protection and Environmental Research).

To facilitate the preparation of documentation and facilitate the subsequent investigation, the

Competent Body/ISPRA provides to the applicant, with respect to each product group, a

manual containing a technical guidebook and verification forms. Each manual contains all

information pertaining to the criteria and test reports earnings for the release of the brand for

that product group.

2. Initiation of proceedings

It must send the application form of the mark, by registering online at:

https://webgate.ec.europa.eu/ecat_admin.

3. Preparation of documentation

The applicant shall prepare all necessary documentation consisting in: the application form

online, a receipt for payment of the inquiries cost, the registration certificate at the Commerce

Chamber, the documents required for the technical evaluation of criteria compliance. All the

documentation is collected in a separate file, in which there must be also a description of the


product use that the applicant intends to do once you get the label and sends it to the

Committee Ecolabel-Ecoaudit, Section label.

4. Request and review

The European Committee EcoLabel-Ecoaudit examines the documentation, requires

additions and shall, where appropriate, one or more inspections. To complete the

investigation, the Committee will normally have 60 days time. In this period the Committee

sends the request to ISPRA to perform administrative and technical investigation to verify

compliance with the established criteria. In the case of a positive outcome of the investigation

the Committee, within 30 days, grants the label and inform the European Commission.

5. Eco-Label award and renewal of the contract

If the application is successful the Board grants to the applicant, after signing the appropriate

agreement and registration by the European Commission, the license to use the mark with a

validity on all the European territory; then the name of the product is inserted in the

Community register of products/services Eco-Label. The assignment contract of the Eco-

Label license is renewed under the simplified procedure whenever the criteria for the relevant

group of products are subject to change. If the contract terms are violated, the Competent

Body has the power to suspend the right to use the mark.

THE APPLICANT

Verifications compliance with

the criteria and sends the file

COMMITTEE ECOLABEL

ACOAUDITISPRA

Involves technical support

Expresses its opinion

Performs administrative and

technical investigation

Notifies the decision

EUROPEAN COMMITTEE

ReleaseRelease

the the labellabel

EcoEco--LabelLabel

Has the investigation been

successful?

YES NO

The applicant can’t have the

label for him product

Figure 1: Procedure for the Eco-Label brand application


4.1.1 Eco-label - realization time and mark time validity

If the product meets the eco-label criteria, the time for obtaining the mark is from 3 to 4

months after the application to the European Commission.

The period of label validity is linked to the period of criteria validity specified in the contract

for the use of the mark. The validity of the ecological criteria for the interest product group

and their assessment and verification, extends for 4 years from the adoption date of the

current European Commission decision.

A contract awarding the Ecolabel license is renewed under the simplified procedure whenever

the criteria for the relevant product group undergo changes.

4.2 EPD

The Organization of International EPD System is structured in:

- Technical Committee

- Secretariat

- Verifiers

Creating an EPD in the international EPD system includes the following steps:

- Considering available PCRs and prepare PCR document:

The PCR is a technical product card (Product Category Rules) which

represents the rules to be followed in drafting the EPD. In PCR are defined the

criteria for membership of a product to a particular category, the scope of the

study of the life cycle of the product Life Cycle Assessment (LCA) and

environmental issues relevant to that category.

- Collecting LCA-data to be included in the EPD:

It is necessary to realize a LCA data collection that will be included in the

declaration EPD. The implementation of the LCA must meet the standards ISO

14040 and 14044, the criteria established by ISO 14025 for the drafting of EPD

and the guidelines of the relevant PCR. The LCA analysis must include all

information from cradle to grave. In the absence of information, is possible to

use generic data only if the environmental impact associated with this data does

not exceed 10% of the overall environmental impact of product system.

- Drafting EPD:


It is necessary to compile environmental information into the EPD reporting

format in addition to the LCA-based data

- Checking EPD:

Independent and External agency have to verify the data of the LCA, the

additional environmental information and the EPD elaborated;

- Registration of EPDs into the international EPD system by the secretariat:

in this event it is necessary to send the registration request in attach with: the

registration form for the EPD, a copy of the approved audit, the EPD carried

out (.doc or .pdf document), a brief description and high resolution image of

the product/service that was said and the company logo.

The applicant will receive formal confirmation of the registration with the

relevant registration number for the product/service and the EPD is

immediately published on the Internet.

- Rules for using the logotype:

It’s necessary to respect some recommendation for example for using on the

declarations, on product and packaging materials and on all types of

information materials.


THE APPLICANT

Identifies the relative PCR

Makes the check of the LCA and EPD

informations

BODY EXTERNAL VERIFIER

ReleaseRelease

the the labellabel

EPDEPD

Is the label valid?

YES NO

The applicant can’t have the

label for him product

Realizes LCA

Draws EPD by PCR

Records to International EPD

System

Figure 2: Procedure for the EPD brand application

4.2.1 EPD - realization time and mark time validity

If the product meets the criteria for membership of a pre-set PCR, the time for obtaining the

label are related to the output time of the LCA information, indicatively 3 – 4 months.

In case of lacking specific LCA data, as a special rule within the international EPD®system,

companies and organizations are allowed to use a defined proportion of generic data and

assigns data sources for selected generic data describing material flows connected to a number

of input materials. The only tie to respect is environmental impact associated to other generic

data must not exceed 10% of the overall environmental impact from the product system.

The EPD does not have a deadline because it is an information document, while the PCR has

it; it is fixed by the moderator and generally extends for a period of three years. The

moderator is the coordinator of the group of interest in the creation or update of a PCR in a

PCR Forum.

If the validity period of a PCR document has expired, the document can be updated and

reactivated on demand. In this case, the moderator announces on the PCR Forum the starting


of an upgrade process of PCR, clearly indicating the time within to provide comments during

which it is possible to provide comments. In case no comment is received on the PCR, it is

possible to extend the validity of the original document.

If there are important advices to do about the PCR in the Forum, the PCR can also be updated

at shorter deadlines intervals.

5 Labeling Type I - Ecolabel

5.1 Costs

Costs are divided in three types:

1. Start-up costs

2. Preliminary costs

3. Annual fee

Start-up costs involve testing’s cost and they must be paid directly to the laboratories. Initial

expenses are variable and include the rates incurred by the applicant to satisfy the required

criteria and prepare the documentation.

Preliminary costs mean an application fee, that is costs of processing the application and they

must be paid to the competent ANPA (National Agency for Environmental Protection) at the

presentation of the dossier.

Actually dues is 500€ per product.

Annual fee means costs “law annual” for label maintenance; they must be paid to the

competent body after the conclusion of the contract and are equal to 0.15% of the annual

volume of sales within European Community. The period covered by the annual fee

commences on the date of award of EU Eco-label to the applicant.

Actually dues is a minimum amount of 500,00 € to a maximum amount of 25.000,00 €.

It’s possible a reduction in the annual fee cost directed at micro-enterprises, SMEs, ISO

certified organizations under 14001/EMAS:

25% in case of SME suppliers or manufactures in developing countries;


15% in the event that the applicant has a certification under EMAS and or ISO 14001

certified;

25% to the first three applicants for the brand of the same items’ group.

5.2 New Product Groups

The European Commission gives to manufacturers the possibility to propose new product

groups even if the process is very long; there is a format to be filled and then European Eco-

labeling Board (EUEB) select priorities to be developed in the coming years only for

consumer products.

Beyond the timing to start the development proposal for Ecolabel criteria, the technical

documentation and the relevant scientific should be prepared and sent to the EU Commission.

Actually Ecolabel Regulation 66/2010 involves a simplified procedure to adopt criteria

developed on the basis of other systems for the allocation of eco-labels EN ISO 14024 Type I

as for example Nordic Swan or Blue Angel.

However current priorities are for “building components including insulation” and “plastic

pellet master batch”.

6 Labeling Type III – Environmental Product Declaration

6.1 Costs

Costs are divided in:

1. Start-up costs

2. Registration fee

3. Annual fee

Start-up costs means testing’s costs and must be paid directly to the laboratories. They

include expenses incurred by the applicant to carry out the Life Cycle Assessment of the

product.

Registration fee for the application depends on the requests’ number:

1 EPD amount to 1.000,00 €

2 EPD amount to 1.500,00 €


3 or 4 EPD amount to 2.000,00 €

for more than 5 EPD is needed to contact the Secretariat.

Annual fee amount to:

1.000,00 € for small and medium size organizations

2.500,00 € for large enterprises

6.2 New Product Category Rules

It is not possible to create a new category, but it’s possible to create a specific PCR according

to PCR Basic Module existing even if the product is not commercially available.

Total time for the process is 4-5 months: in detail 2 or 3 weeks are necessary to prepare the

PCR instead for the technical consultation is needed 8 weeks; finally the approval by the

Technical Committee requires 2-3 weeks.

In this case there are no registration fees but the consulting costs are variable.

Moreover the EPD can be processed but not published; it’s admitted only for the product in

production.

7 Conclusion

Conclusions about applicability Ecolabel brand to our panel are:

a) We cannot consider our Ecoplasbrick panel under existing product group: Coverings.

In spite of the sub-product groups contemplate external/internal Hard Coverings, they

consider:

- natural product (natural stone)

- processed product (hardened product and fired product)

- no mention to sandwich panel.

b) Considering the chance to create New Product Groups, we involved technical support by

ISPRA and they tell us it’s not possible certify Ecolabel award for prototype but only for

consumer product.

c) Currently our ecoplasbrik panel is a prototype

Therefore we can’t consider Ecolabel - label Type I - for our Ecoplasbrick panel


Regarding EPD labelling:

a) Among existing product category we could consider Constructions, construction

products and construction services even if it’s possible to develop only basic module;

however the only construction products contemplated are made in concrete, no

mention to sandwich panel.

b) We cannot create a new category, but we can create a Specific PCR according to PCR

BASIC MODULE existing even if the product is not commercially.

c) Considering the chance to create a Specific PCR, we involved Technical Committee, a

group of LCA/EPD expert to assist the Secretariat and they refer us EPD through a

Specific PCR can be processed but not published, moreover it’s admitted only for the

product in production.

We can’t apply Environmental Product Declaration - label Type III – to our

Ecoplasbrick panel.

The activities will focus on the production of a Type II Environmental Label according to

the standard ISO 14021 Environmental labels and Declaration – Self-declared

environmental claims.

8 References

http://www.isprambiente.gov.it/certificazioni/site/it-IT/Ecolabel_UE

EC Regulation N.66/2010 of the 25 November 2009

http://www.iso.org/iso/catalogue_detail?csnumber=34425

http://ec.europa.eu/environment/ecolabel/products-groups-and-criteria.html

The General Programme Instructions for EPD – Version 1.0 dated 2008-02-29

http://www.iso.org/iso/catalogue_detail?csnumber=34425

http://ec.europa.eu/environment/ecolabel/products-groups-and-criteria.html

requirements for epd

Documents

label product groups

epd product categories

label realization time

new product groups

labeling type

epd realization time

ecoplasbrick deliverable

mark time validity