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European Commission Consultation on Delivering more Sustainable Consumption and Production: Our Response

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This is Interface Europe’s response to the European Commission consultation on the possible introduction of EU-wide measures related to sustainable consumption and production (entitled: Consultation on Delivering more Sustainable Consumption and Production).

The consultation looks at green public procurement, the environmental footprint of products (PEFs) and the environmental footprint of organisations (OEF).

At Interface Europe we are particularly interested in PEFs.

The European Commission is beginning to understand the power of full product transparency, as is evident in this latest consultation document.

At Interface we very much welcome this development, as we believe that environmental policies across Europe lack co-ordination.

Our view is that the coordination of all environmental policy instruments is best served by starting from the central point of Environmental Product Declarations (EPDs), which the EC is calling Product Environmental Footprints (PEFs).

An EPD reveals the ingredients of a product, its methods of production, and the full environmental impact of each stage of its life cycle, measured in several impact categories including impact on climate change (grammes of CO2), water use (litres), and other air emissions (grammes of SO2).

We believe the way forward for corporate sustainability is to use the information gleaned from EPDs to substantially reduce the overall environmental impacts of the products we make, rather than just focusing on cutting the impacts of our own operations.

By concentrating on EPDs, we will automatically cut the impacts of our operations anyway as these are represented in the manufacturing stage of the product life cycle.

Below you will find a few excerpts from our consultation document.  

You can find the full PDF here .

If you have any suggestions, questions or  queries  about this document,  please don’t hesitate to leave a comment.  

If you would like to share this document with individuals that would be interested, we would could very much welcome this.

At Interface we are producing EPDs for all our carpet tiles. We believe the way forward for corporate sustainability is to use the information gleaned from EPDs to substantially reduce the overall environmental impacts of the products we make, rather than just focusing on cutting the impacts of our own operations. By concentrating on EPDs, we will automatically cut the impacts of our operations anyway as these are represented in the manufacturing stage of the product life cycle.

Here are some of the ways in which we believe EPDs can be used to reward those who begin to reduce the environmental impacts of their products:

EPDs as a guarantee against greenwash

Despite the prevalence of greenwash, there is no European-wide agreement on the making of environmental claims. Companies are very fond of making extravagant claims, such as that their factories use ‘100% green electricity’ or that they are ‘carbon neutral’. But the main impacts of products are usually outside company boundaries. EPDs are the only things that show these impacts exactly as they are, across the life cycle.

We therefore advocate a European-wide regulation which stipulates that companies can only make environmental marketing claims that are based on third party certified EPDs. That way greenwash is effectively banished – and companies also have an incentive to carry out EPDs. The French government is exploring this avenue already. Governments should stop wasting money on anti-greenwash guides and awareness-raising, and make sure that companies are only allowed to make claims that can be prove through an EPD.

EPDs as an alternative to dubious green labels

There are too many ‘green labels’ in Europe, and a good deal of them are inadequate or highly dubious. Some companies have labels on their products that are issued by private firms that offer consulting and certification services simultaneously. Many labels are far too easy to obtain, or just focus on a narrow range of issues. Others lack independent certification methods or may even be administered by the manufacturers themselves. Many labels duplicate each other, confusing clients and obliging manufacturers to certify the same product several times. Unfortunately, some of the labels that are best marketed are the least robust.

EPDs are a much better alternative. The concept of full product transparency (producing an EPD where you state your ingredients, production methods and environmental impacts) will give greater re-assurance to buyers and will eventually lead to the demise of bad labels. If every product had an EPD, then there would be no need for any other ‘green’ labelling.

EPDs as a basis for Ecolabels

The consultation paper suggests increasing the marketing budget for the EU’s voluntary Ecolabel. This might be a good idea, but we should fix the Ecolabel criteria first. At the moment there is no credibility in the criteria required to achieve the Ecolabel. Powerful industry lobbies – and countries protecting their industries – manage to impose criteria that are favourable to themselves. In many cases, the criteria for Ecolabels do not take into account the full environmental impacts of a product because they do not include the rigour of a life cycle analysis.

Again, EPDs can provide the solution. There should be an overarching European rule which says that Ecolabels are only awarded to products that have 50% less impact than the typical generic product in their category. For example, a typical carpet tile has 10kgCO2/m2, so Ecolabels should only be awarded for carpets with less than 5kgCO2/m2.

In order to drive radical innovation there should be a ‘golden’ Ecolabel (at a higher level than the normal Ecolabel) which is only awarded to products with 80% less impact than the generic product. That way you create an incentive for companies to go the extra mile.

Once these rules have been introduced to add credibility to the Ecolabel, then we can consider increasing the marketing budget.

EPDs as the foundation for green public procurement

If you had EPDs for all products, it would be easy to know which products have more or less impacts. That would be good news for public procurers, who are struggling to establish which of the products they need to buy is better for the environment. Today everybody is talking about the power of green public procurement, but what’s the point if nobody knows how to buy green?

The EU’s guidelines on green public procurement provide advice based either on complicated criteria and ideas or on generalities such as ‘take into account energy consumption and emissions’. What public procurers really want is clear guidelines and targets. For instance, that they should buy cars with less than 120gCO2/km or rent buildings with heating/cooling requirements of 50kWh/m². With EPDs, we could provide very simple guidance to public procurers on many things. We could provide real data per product, instead of vague advice that is of very little help in making sustainable purchasing decisions.

EPDs as a way to decide on tax incentives

If EPDs were universally adopted, we would have a clear and simple basis for assigning tax benefits to products that have a lower environmental impact. For example, products awarded the Golden Ecolabel on the grounds that they have 80% less environmental impact could also qualify for lower product taxes (eg VAT) over a period of time.

If we don’t provide such tax incentives, who will re-design products with 80% less embodied carbon, apart from a handful of companies with a higher purpose? Business needs clear signals that environmental innovation will be rewarded.

This suggests a way ahead for other products:

  1. Develop a common ‘magic metric’, to be measured by an EPD, based on the full product life cycle impact or at least on the main area of impact.
  2. Set a target for the product, based on that metric, at EU level. Reinforce this with penalties if the target is not met.
  3.  Make it mandatory to have the magic EPD metric visible on all promotional materials and at point of sale. This could be through an easy to understand colour-coded A-G label based on absolute figures.
  4. Create tax regimes and incentives that reinforce the signals given at EU level.
  5. Encourage civil society intermediaries to raise awareness of the issue based on the magic metric.
  6. Release the power of public procurement by providing easy guidance based on the magic metric.


If the EC wants to deliver more sustainable consumption and production, then it must harness the power of full product transparency.

EPDs provide a full picture of a product’s impact throughout its life, rather than a snapshot as that product passes through one business. Companies that focus on EPDs very quickly discover what they need to do to reduce their footprint – whereas those that don’t can spend many years pursuing policies that make little difference, mainly because they don’t have the true picture of where their main impacts are.

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