Ever since environmental claims for products burst onto the Canadian market in the late 1980s manufacturers and brandowners have been looking to attract environmentally conscious consumers by featuring these claims on their labels and in their advertising. Today, it is difficult to find a consumer product that does not say something about its environmental performance, even if it is only a simple claim such as ‘recyclable’ or ‘recycled content’.
Even though Competition Bureau Canada, the federal regulator of misleading advertising, has published a guide on environmental claims – known as PLUS 14021 with the title “Environmental claims: A guide for industry and advertisers”, the rules proposed by the guide are frequently ignored. Critics call this “greenwashing”.
The basis of Competition Bureau Canada’s guidance is that an environmental claim should only be made if the aspect referenced actually provides a real environmental benefit. The manufacturer or brandowner needs to be able to demonstrate that the product making the claim has significantly less impact on the environment than a similar product that does not possess that environmental attribute, or than a previous version of the product that lacked the attribute.
Proving that one product has a lighter environmental footprint than another is often not a simple task. The most commonly applied tool in North America is life cycle assessment (LCA). This tool takes into account every aspect of a product’s life cycle, from raw material extraction through transportation, processing, other applied inputs, conversion into the finished product, shipping, use, and end-of-life management. Sometimes the use and end-of-life aspects are ignored because the manufacturer believes that it cannot control those steps, but omitting them can lead to significant distortions in the conclusions.
There are several problems with LCA as a tool for comparing products. First, not all of the environmental aspects of a product’s life cycle are amenable to measurement in terms that allow comparison with competing products.
For example, there are as yet no reliable science-based indicators for the impact that use and improper disposal of some plastic products have on the oceans. We know there is a problem, but the contribution of a particular product or product category to the problem is unknown and is not easily determined through research. Hence we cannot easily determine whether, for example, the use of heavier gauge reusable plastic bags actually reduces the amount of microplastic in the oceans, given that the link between Canadian use of single-use plastic bags and ocean microplastics, and the potential contribution of heavy gauge plastic bags to ocean microplastics, are both essentially unknown and certainly not measured.
A second problem is that measuring the environmental impacts of a product’s life cycle is a substantial and expensive undertaking. Researchers must measure the energy, water, other inputs, and all outputs in the form of air, water, pollutants, and waste at every step of the life cycle, not just for the product for which the environmental claims are planned, but for the product with which it is to be compared. If the manufacturer of the comparison product is unwilling to cooperate with the research, the comparative LCA may not be possible. Costs of a thorough LCA can run into tens of thousands of dollars and may exceed $100,000 in the case of a complex product.
To reduce the costs of an LCA, many studies use data from databases compiled for this purpose. The database shortcut, however, has some significant flaws.
The environmental impacts of a product’s manufacture have much to do with how the product is made, where it is made, what it is made from, and so on. LCA databases are generally compiled from information derived from one or two detailed LCA studies. Though the information may be correct for the manufacturing plant or plants where the studies were conducted, it may not be accurate for plants elsewhere in the world manufacturing a similar product. The variances between manufacturers may be huge, invalidating efforts to compare the environmental impact of the two products.
The results of LCA comparative studies often appear at first glance to be counter-intuitive. For example, one study shows that a ceramic mug needs to be reused at least two hundred times before it has a lower environmental impact than a single-use hot beverage cup, mostly because of the amount of energy and material that goes into the ceramic product.
Single-use coffee pods have a lower environmental impact than drip coffee systems because they use less coffee beans to make a cup and because they produce only the exact amount of beverage required while most drip systems make a pot of coffee of which much is poured down the drain when it spoils or at the end of the day. Many reusable shopping bags are made of polyester or other plastic textiles that shed microplastics throughout their lives and whenever they are washed or abraded.
The challenges facing LCA are not so egregious that the tool should be abandoned, but it should be remembered that it was originally designed to provide information that could be used to environmentally improve products in ways that are effective. The use of LCA as a tool to compare products has evolved because of the pressing need for such a tool, but LCA will need considerably more development before it becomes a tool that is reliable, scientifically defensible, and easy to use for this purpose.
It is recommended that manufacturers and brandowners consult with an experienced environmental lawyer before making environmental claims for a product so as to understand the risks that may arise from such claims.
“Life Cycle Assessment (LCA): A Guide to Best Practice” by Walter Klöpffer and Birgit Grahl is one of many comprehensive guides to LCA studies that comply with international standards. It is available from bookstores across Canada.
Colin Isaacs is a scientist and analyst with CIAL Group who focuses on sustainable development for business. He was selected by Environment Canada to be the principal author of the waste management chapter in the report The State of Canada’s Environment 1991. Colin can be reached at (416) 410-0432 (phone), (416) 362-5231 (fax), and firstname.lastname@example.org (e-mail).