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Recommendations to avoid greenwashing
It is illegal for a business in the EU to advertise false, inaccurate, or exaggerated claims about its environmental achievements or commitments (https://europa.eu/youreurope/citizens/consumers/unfair-treatment/unfair-commercial-practices/index_en.htm ).
There are 4 common manipulations in LCA that lead to greenwasching: (1) false claims of sustainable electricity (2) allocation of eco-burden to low value by-products like waste (3) underestimation of use of energy and water for natural products from agri-waste and wood-waste (4) biased midpoint selection
- For electricity, the country mix of production is to be applied. Sustainable electricity can be claimed when it is own production. Guarantees of Origin (GOs) and Renewable Energy Certificates (RECs) are not allowed to claim sustainable electricity, unless they are “bundled” with electricity of the same provider (so called Power Purchasing Agreements), to be verified and documented in a letter by an independent accounting firm. See ‘GOs and RECs in LCA‘.
Note: Carbon Offsets (i.e. tradable “rights” or certificates linked to activities that lower the amount of greenhouse gasses in the atmosphere) are not allowed in LCA, since there is no physical relationship with the production system.
- In the case of co-products and by-products of a production facility, economic allocation must be applied on the basis of the relative financial turnover of each product, To be verified and documented in a letter by an independent accounting firm. See ‘Idemat calculation rules‘.
Note that allocation on the basis of mass normally shifts eco-burden to byproducts (like waste with a small value/mass ratio). Allocation of recycled or biobased inputs to only a few co-products on the basis of the so called Mass Balance Approach is not allowed (see also MBA for EPDs).
- The eco-costs and carbon footprint of products that are made from agricultural waste or wood waste, must be derived from the amount energy and water that is required for production. To be verified and documented in a letter by an independent accounting firm. The minimum resulting score that can be accepted is the score of molded paper.
- A type of implicit greenwashing by companies is the selection of a specific set of midpoints that favors the green claim of a product, i.e. the midpoints that are unfavorable for the product are left out (NGOs do often the opposite). This is the reason that endpoint systems or single indicator systems should be preferred. See also the explanation on the choice of midpoints, endpoints and single score indicators at the eco-costs page.
Note. These recommendations of SSIM are more specific than the requirements of the draft Green Claims Directive of the EU (see Section 3.2 and 6.2), but must be taken into account when using SSIM data.