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RESTRICTED WORLD TRADE WT/CTE/M/49/Add.1 28 May 2010 ORGANIZATION (10-2963) Committee on Trade and Environment SUMMARY REPORT OF THE INFORMATION SESSION ON PRODUCT CARBON FOOTPRINT AND LABELLING SCHEMES 17 FEBRUARY 2010 Note by the Secretariat1 Addendum 1. The Information Session on Product Carbon Footprint (PCF) and Labelling Schemes was held on 17 February 2010 in response to the requests by a number of developing country Members for information on the various initiatives being developed at the national and international levels in the area of product carbon footprint standards and labelling schemes.2 2. This Report provides a detailed summary of the key points of the presentations and of the issues that arose from the discussions during the information session. The full presentations made by the speakers are available on the WTO trade and environment website.3 _______________ TABLE OF CONTENTS I. OVERVIEW: RECENT STUDIES IN THE OECD ............................................................. 2 II. NATIONAL EXPERIENCE SHARING: PUBLICLY AVAILABLE SPECIFICATION (PAS 2050) – LESSONS LEARNED ...................................................... 3 III. HARMONIZATION OF CARBON FOOTPRINT RELATED STANDARDS ................. 4 A. WRI/WBCSD PRODUCT LIFE CYCLE ACCOUNTING AND REPORTING STANDARD ................. 4 B. ISO 14067 CARBON FOOTPRINT OF PRODUCTS - PART 1: QUANTIFICATION AND PART 2: COMMUNICATION ....................................................................................................... 6 1 This document has been prepared under the Secretariat's own responsibility and is without prejudice to the positions of Members and to their rights and obligations under the WTO. 2 See meeting of November 2009 of the Committee on Trade and Environment (CTE), WT/CTE/M/48. 3 http://www.wto.org/english/tratop_e/envir_e/events_feb10_e/event_17feb10_e.htm WT/CTE/M/49/Add.1 Page 2 I. OVERVIEW: RECENT STUDIES IN THE OECD 3. By way of introduction, Mr Dale Andrew, OECD Trade and Agriculture Directorate, recalled the typical features of PCF labels. They: displayed the total amount of greenhouse gas (GHG) emissions that were emitted during the entire life cycle of a product or a service; they were expressed in grams of CO2 equivalent per unit of the product; and were displayed not only directly on packaging, but also on websites or on the store shelf. 4. PCF labels could have different objectives. For producers, the key objectives were to help companies prioritize GHG reduction efforts along the supply chain and to demonstrate their commitment to climate change mitigation (as part of their corporate social responsibility efforts). PCF labels were a tool to compare the carbon footprint of similar products from different origins or with different packaging characteristics (e.g. a fruit juice bottled in a can, a glass bottle, or a plastic bottle). Knowing the carbon footprint of a product could also help offset emissions that could not be reduced, e.g. as suggested by the "Stop Climate Change" scheme in Germany, and help consumers reduce their "personal" carbon footprint. 5. The OECD recently conducted a survey on the extent to which PCF labels influenced consumer, buyer and investor behaviour. The survey showed that, in purchasing decisions, environmental concerns ranked after quality and price. He explained that although PCF schemes had first appeared in 2007, their number had quickly grown since then. Such schemes had started out with limited coverage, mostly food and drink, but had then been extended to a wide range of products. Moreover, many schemes that started as private and voluntary had now seen the involvement of governments and international organizations. As at the end of 2009, the OECD had identified PCF schemes in the following ten countries: Canada, France, Germany, Japan, Republic of Korea, Sweden, Switzerland, Thailand, the United Kingdom and the United States. 6. Some examples of PCF schemes included: (i) Japan's voluntary carbon footprint labelling scheme for products launched in 2009 on a trial basis; (ii) two French PCF schemes, initiated by supermarket chains, for application either on products themselves or on the receipt as the sum of all purchases; and (iii) a private PCF label for biofuels, developed by a Swedish association and the Brazilian ethanol industry, which covered both environmental and labour conditions. 7. The following comments could be made on the schemes surveyed by the OECD: only about half of the schemes had published methodologies; the quality of the documentation varied greatly; most schemes reflected a full life cycle analysis, but with different starting or ending points; most did not appear to create market access barriers for producers in developing country or distant countries, mainly due to the use of a life cycle analysis; some ignored short distance transport flows, such as internal domestic transport; the calculation of shipping emissions relied on various factors; there were uncertainties on how to treat the loss of soil carbon in agricultural practices; the schemes used different communication strategies, e.g. displaying the actual value of the CO2 emissions equivalent per unit or showing carbon-free claims (i.e. for companies offsetting their GHG emissions); and it was very difficult and costly to determine the exact carbon footprint of a product, particularly due to the lack of relevant data. 8. In Mr Andrew's view, conformity assessment was a major weakness of the current schemes. He reported that only four schemes relied on third party verification of the PCF and that the conformity assessment procedures generally lacked clarity and transparency. In response to a question about conformity assessment, Mr Andrew drew a parallel between carbon footprint and certification of organic products, where an entirely new industry had emerged in order to certify organic products. He acknowledged that certification was expensive, especially when producers had to seek certification for different schemes at the same time. WT/CTE/M/49/Add.1 Page 3 9. Finally, in terms of the effects of these schemes on small and medium-sized enterprises (SMEs), Mr Andrew explained that some supermarket chains had worked very closely with all suppliers upstream, including farmers, importers and retailers. He noted that one problem of some of the earlier schemes was that they relied heavily on so-called secondary data, or default values, particularly in developing countries, in calculating the carbon footprint without actually measuring the emissions in the respective countries. He noted that at present no empirical work existed on the effects of PCF labels on SMEs, but previous work done in the OECD on private labelling schemes could provide valuable insights. II. NATIONAL EXPERIENCE SHARING: PUBLICLY AVAILABLE SPECIFICATION (PAS 2050) – LESSONS LEARNED 10. Ms Maureen Nowak of the United Kingdom's Department for Environment, Food and Rural Affairs (DEFRA) presented the United Kingdom's experience in developing a standard to measure embodied GHG emissions across the life cycle of goods and services, the so-called Publicly Available Specification (PAS) 2050, published in October 2008. 11. The development of PAS 2050 started in 2007 in response to a demand from the business community to better understand the GHG emissions of their supply chains, identify hotspots where GHG emissions could be reduced most effectively and share information about its work internally, with their supply chains, and with customers. The objective was to develop a tool for measuring GHG emissions that could be applied across a wide range of products, services and supply chains, and would allow a consistent and comparable approach to supply chain measurement of GHGs across different markets. The project was overseen and managed by the British Standards Institute (BSI) and co-sponsored by DEFRA and the Carbon Trust. The development process of PAS 2050 involved consultations with over 1,000 stakeholders, both national and international. Over 3,000 comments were received and PAS 2050 had been tested as part of pilot projects across a wide range of products, services, sectors and companies, including manufacturers, retailers and traders. 12. PAS 2050 had the following key characteristics: it was built on internationally recognised life cycle assessment methods, specifically the ISO 14044; covered all GHGs specified by the Intergovernmental Panel on Climate Change (IPCC); included the whole lifecycle of a product; could be applied to any product or service, by any company and in any geographic location; allowed a full internal assessment of GHG emissions and thus the identification of emissions hotspots; facilitated evaluation of options, e.g. for purchasing and sourcing decisions; supported corporate reporting and communications with consumers; and it enabled comparability within an organisation since PAS 2050 was suitable for comparing the impact of changing materials, processes, distribution, use profiles, end of life opportunities, changes over time and the different formulations of similar products. However, Ms Nowak pointed out that PAS 2050 did not provide the level of detail necessary for product comparison. 13. PAS 2050 was already being used by many companies, including several leading retailers, across long and complex international supply chains. For example, the Carbon Trust had completed many projects worldwide, including in Europe and in South America as well as in Canada, China, South Africa and the United States. It had certified footprints of over 5,500 individual product lines, with a total carbon footprint of eight million tonnes of CO2 equivalent. 14. Ms Nowak then shared some lessons learned from a User Trials Project: the step-by-step approach in PAS 2050 provided a good structure for undertaking product or service carbon footprinting; the accompanying Guide to PAS 2050 was found to be clear and user-friendly and to provide a good overview; the primary data requirements of the PAS 2050 could be time consuming, but allowed important insights into the supply chain; difficulties were encountered in collecting secondary data. Recommendations from the user trial projects included the need for a recognized WT/CTE/M/49/Add.1 Page 4 source of full life cycle emission factors for common flows, such as energy, transportation and waste management; and wider publicly available databases needed to be more accessible. 15. A review of PAS 2050 will be conducted and take into account the related international initiatives, specifically the developing ISO 14067 standard and the WRI-WBCSD GHG Protocol Product Standard, as well as the European Commission's work on PCF. Ms Nowak explained that the review process of the PAS 2050 would also include wide consultations with stakeholders, a high level of technical expert input and extensive evidence gathering to support any proposed changes. It was expected that the overall process would take about nine months, for completion by late 2010. 16. To conclude, Ms Nowak noted that PCF had a key role to play in motivating businesses to reduce their carbon emissions and hence move towards a low carbon economy. The effectiveness of PAS 2050 needed to be assessed and if necessary improved in order to increase uptake by businesses. For instance, some practical aspects in PAS 2050 needed to be addressed, most notably the availability and accessibility of reliable and relevant data. Moreover, some products, such as agriculture and chemical products, were inherently more difficult to assess than others, as they had for instance complex and variable supply chains and multiple ingredients. She acknowledged that PAS 2050 did not work as a 'one size fits all' and that for practical purposes it needed to be supported by specific rules or guidance for each sector. III. HARMONIZATION OF CARBON FOOTPRINT RELATED STANDARDS A. WRI/WBCSD PRODUCT LIFE CYCLE ACCOUNTING AND REPORTING STANDARD 17. Ms Andrea Brown-Smatlan, representing the World Resource Institute (WRI) and the World Business Council for Sustainable Development (WBCSD), presented the GHG Protocol Initiative. 4 The GHG Protocol Initiative started in 1998 as a response to an increasing demand for harmonization coming from various stakeholders. This was a multi-stakeholder initiative, which included business, NGOs, governments, academics and others, intended to develop internationally accepted GHG accounting and reporting standards and promote their use worldwide. 18. Under the GHG Protocol Initiative, WRI/WBCSD had published a Corporate Accounting and Reporting Standard for GHG emissions in 2001 (revised in 2004). This so-called GHG Corporate Protocol had since become the most widely used international accounting standard for corporate GHG accounting. It provided the accounting framework for almost every GHG standard and was used by various programs across the world, such as ISO 14064 (Part I), the Climate Registry, the Carbon Disclosure Project, the Californian Climate Action Registry, Dow Jones Sustainability Index, the European Union Emissions Trading Scheme, World Wildlife Fund Climate Savers, etc. The initiative also led to a number of other protocols and sector-specific programs, such as the GHG Protocol for Project Accounting, which was a methodology to account for emission reduction activities, and a reporting program for the cement sector. 19. Ms Brown-Smatlan reported that a survey conducted by WRI/WBCSD in 2008 had indicated a strong need for additional information on supply chain and product GHG emissions. The increase in the number of GHG accounting initiatives and regulations at the company level, at the sector level, within organisations and national governments demonstrated the need for an internationally accepted, standardized and credible approach to measure GHG emissions. Therefore, in 2008, the WRI/WBCSD Secretariat initiated the development of two new standards. First, the Scope 3 Accounting and Reporting Standard quantify, manage and report GHG emissions in the corporate value chain. This standard was built on the GHG Protocol Corporate Standard. And second, the 4 For copies of the draft Scope 3 and http://www.ghgprotocol.org/standards/product-and-supply-chain-standard Product Standards, see: WT/CTE/M/49/Add.1 Page 5 Product Life Cycle Accounting and Reporting Standard to quantify, manage and report the life cycle GHG emissions of individual products. It was built upon the existing life cycle assessment standards, PAS 2050 and ISO 14011. The initial drafts of both standards had been released in November 2009, the second draft would be available for public comment by mid-2010 and the final standards were expected to be published by year end. 20. For WRI/WBCSD, the primary objective of a product standard was the public disclosure of GHG emissions of goods and services. Implementing the standard might also support additional business goals, namely the identification of the GHG reduction opportunities within a product supply chain, the engagement of the supply chain in order to obtain better quality data, and product differentiation. The standard was sufficiently flexible to accommodate GHG quantification and reporting for many types of goods or services. However, the standard did not fully support product comparison, as that level of comparison would require a greater degree of prescriptiveness. WRI/WBCSD intended to include guidance on how programs, product category rule developers and other organizations or governments could specify additional prescriptiveness in order to make a valid product comparison possible. In response to a question, Ms Brown-Smatlan added that WRI/WBCSD was also considering developing an SME-targeted guidance document to help them better understand the requirements to measure the PCF. 21. As for the structure of the process, Ms Brown-Smatlan explained that the WRI/WBCSD Secretariat convened and facilitated the process. A Steering Committee of 25 members included government representatives, academia, major businesses and international organisations. The process structure included several technical working groups, with about 170 experts, for the development of both standards, and a stakeholder advisory group, with about 1,200 members, who were kept informed about the standard development and who were able to provide comments throughout the process. Five stakeholder workshops were held (in Berlin, London, Guangzhou, Beijing and Washington D.C.), inviting the stakeholder advisory group to provide comments. 22. In response to a question, Ms Brown-Smatlan noted that WRI/WBCSD attached great importance to an open and inclusive process, with a representation of over 40 countries, in developing the new standards. A majority of representatives originated from Europe and North America, but WRI/WBCSD specifically sought out participation from developing countries, such as Brazil, China and India. WRI/WBCSD also organized a public comment period and thus received over 2,000 individual comments from around 65 different companies and organisations. Ms Brown-Smatlan explained that a road testing phase was underway (from January to June 2010) with the participation of 70 companies from a wide range of sizes, sectors, geographical locations and experiences in GHG accounting. Companies from Brazil, China, India and South Africa were involved in this testing of the standards. The results of the road testing would be used to revise the two standards before final publication. 23. Finally, Ms Brown-Smatlan noted that harmonization of standards could accomplish several important goals, such as: the reduction in compliance costs for business; an increased confidence in the marketplace; the facilitation of a valid comparison and thus more informed choices by consumers; and an improvement in the availability of quality data. She noted that the current versions of all three PCF standards that existed or were being developed, namely PAS 2050, ISO 14067, and GHG Product Life Cycle Standard, were generally aligned and that all three institutions would continue to work together towards further harmonization over the coming year. She was of the view that there was room in the marketplace for more than one standard with an aligned methodology. WT/CTE/M/49/Add.1 Page 6 B. ISO 14067 CARBON FOOTPRINT OF PRODUCTS - PART 1: QUANTIFICATION AND PART 2: COMMUNICATION 24. Mr Rob Steele, Secretary-General of the International Organization for Standardization (ISO), and Mr Klaus Radunsky, ISO Working Group Convener for ISO 14067, gave a joint presentation on the work of ISO to develop an international standard on carbon footprint of products, namely ISO 14067. Mr Steele provided an introductory overview of the ISO system. He emphasized that ISO aimed to ensure the effective participation by developing countries in the standard setting process. He clarified that ISO encouraged the proper implementation of standards, but was not involved in certification. 25. Mr Steele introduced an ISO study, published in February 2010, on "International standards and private standards".5 He noted that a distinction should be made between international standards, which used principles for international standards set out in the context of WTO Agreement on Technical Barriers to Trade (TBT) as well as disciplines established through acceptance of the TBT Code of Good Practice, and other standards that may be described as consortia standards. He voiced the opinion that there should be a move over time towards international standards in order to avoid the creation of non-tariff barriers to trade. He stressed the need for formal international standardisation with wide participation across countries and between industries, consumers and governments. 26. Finally, Mr Steele outlined ISO's current work relating to climate change, such as GHG emissions quantification and reporting as well as carbon footprint of products. Furthermore, ISO was working on energy efficiency and performance with the aim to assist industry to improve their energy management; on renewable energy sources, such as solar and wind energy; on the measurement of the impacts of climate change, on transportation and on sustainability perspectives. 27. In the second part of the presentation, Mr Radunsky updated the CTE on the recent work in the Working Group 2 of TC 207, Sub Committee 7, which was developing the ISO standard 14067. The development of this standard started in April 2008 and its publication was expected by the end of 2011, or at latest by the beginning of 2012. He pointed out that due to growing interest, an increasing number of experts were participating in the meetings. At every stage, the Working Group had received about 1,000 comments which substantially helped further improve the standard. He highlighted the fact that several of these technical committee meetings took place in developing countries in order to ensure their active participation. In this context, he mentioned that Sweden (SIS/Sida Project) provided a capacity building program for countries in the Middle East and North Africa region in order to facilitate their effective participation in the standard setting process. Mr Radunsky also explained that about 100 experts from 30 countries, including developing countries, such as Argentina, Brazil, China, Indonesia, Malaysia and Mexico participated regularly in the meetings of Working Group 2. 28. Mr Radunsky also provided a short overview of the standard. The objective of this standard was to provide clarity and consistency for quantifying, monitoring, reporting and verifying the PCF to the benefit of organizations, governments, project proponents and stakeholders. In response to a question on definitions, he clarified that although the standard was called carbon footprint of products (and not GHG footprint of products), it addressed all relevant GHGs. In fact, Annex A, which was mandatory to the standard, referred to all GHGs identified by the IPCC and its Fourth Assessment Report. The name PCF was chosen because it was already a common name in the marketplace. 29. Part 1 of the standard laid down the principles and requirements to quantify PCF based on the method of life cycle assessment. At the heart of the new standard would be the methodological 5 Study available at http://www.iso.org/iso/private_standards.pdf WT/CTE/M/49/Add.1 Page 7 framework with an inventory analysis of PCF. It would also address the question of allocation, which arose when processes yielded more than one product. Mr Radunsky highlighted that the standard set some detailed product category rules in order to allow consumers to compare carbon footprints across products. Part 2 aimed to specify requirements for the development of information to communicate the PCF and give guidelines on how to use such information on PCF. The requirements and procedures for communication would be different between business-to-business communication and business-to-consumer communication. On verification, he clarified that ISO was taking a flexible approach, allowing verification according to various ISO standards. 30. Mr Radunsky also emphasized that harmonization was a common goal for PAS 2050, WRI/WBCSD and ISO. In his view, it was of particular importance to have similar requirements, principles, terms and definitions, and a similar level of verification in all three standards. In order to ensure harmonization, he explained that representatives of the three initiatives participated actively in each others' meetings. He echoed the previous speaker by stating that there was an added value of having more than one approach: PAS 2050 was mainly driven by the needs of investors, WRI/WBCSD mainly by the needs of the owners of the supply chain, whereas ISO was broader, including the interests of consumers and governments. 31. As for the role of PCF, it was not meant to be a barrier to trade, but rather a tool to facilitate the participation in supply chains, which were required to provide information about the carbon footprint. PCF standards helped ascertain and manage the GHG emissions along the supply chain and respond to new regulatory, shareholders and consumers pressures. PCF standards also helped improve the understanding of risks and opportunities of the supply chain and eventually achieve a higher productivity of the supply chain. Key challenges in the development of PCF standards included the need to achieve the right balance between practicality and environmental integrity/credibility, the definition of product category rules and the question of timing. In his view, measuring and reporting the PCF of all goods and services could contribute to the transition to a zero or low carbon society. He believed that the economic crisis offered a unique opportunity to restructure the supply chains of products and to make them more efficient in terms of GHG emissions. 32. As a follow-up to the reference to the Swedish capacity building program, the representative of Sweden mentioned a conference held in Stockholm in November 2009, where several developing countries gave insightful presentations.6 A representative of the Swedish Standards Institute (SIS) also informed that pre-seminars were conducted for the Middle-East and North African region in order to prepare eleven countries to participate more actively in the development of the ISO carbon footprint standard. He mentioned that one of the issues brought up during the pre-seminars was the importance to have, especially for SMEs, a cost-benefit approach of various methodologies in order to facilitate compliance with PCF standards. __________ 6 See http://www.sis.se/