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BACKGROUND AND OBJECTIVES
Currently there are over 400 ecolabels for food and consumer products in the
global marketplace. These labels are marketing efforts informing the purchaser
of a variety of claims of sustainability measures enacted by companies. The
marketplace is flooded with several similar claims on whether a product is less
hazardous, sustainable, organic, non-GMO, fair-trade, recyclable, recycled,
carbon neutral, or biodegradable. Generally there are four types of labels in
order of volume, 1) voluntary environmental certification programs, 2) self- or 3)
cause-related claims and 4) governmentally regulated. The federal, some state,
and International governments have limited direct roles in ecolabeling beyond
mandatory hazard warning (e.g., pesticide or Prop. 65) or informational
disclosures (EPA fuel economy, certified organic, WaterSense, or Energy Star).
There are several third-party certification and quasi-governmental programs
that lend credibility to an ecolabel; however, standardization or centralization of
these programs are lacking.
RESULTS AND DISCUSSION
• 6% of the consumer goods were declaration based, no associated standard
ecolabels also called Type III per The International Organization for Standardization
(ISO).
• 26% were self-declared environmental claims (Type II ISO standards).
• 65% of the consumer goods ecolabels were reviewed by an independent 3rd party
reviewers (Type I ISO standard).
• The ISO Type I ecolabel association, Global Ecolabelling Network, harmonizes 25
ecolabel organizations worldwide. However, the ISO standards are not freely
accessible. 19% of the consumer good ecolabels have fee-based standards.
• 77% of the ecolabels had publically available standard.
• 56% of the ecolabels had recertification reviews within 1-2 years of initial award.
• 56% of the ecolabels reviewed had some form of enforcement against companies or
products that failed to conform to criteria or standard once awarded.
• Deceptive claims are primarily discovered by concerned citizens or watchdog
non-governmental organization.
• Review of the 25 published hazard standards indicated that hazard data and hazard
identification from Authoritative peer-reviewed open-sources were preferred.
• Globally Harmonized System of Classification and Labelling of Chemicals (GHS
CLP), EU’s Registration, Evaluation, Authorisation and Restriction of Chemicals
(REACH), California EPA’s Proposition 65, U.S. EPA and Europe’s pesticide data,
U.S. EPA’s Integrated Risk Information System (IRIS), and Agency for Toxic
Substances and Disease Registry (ATSDR), NTP (National Toxicology Program),
and International Agency for Research on Cancer (IARC).
FUTURE RESEARCH
Compare Hazard Based Criteria or Standards
• Do all products need to conform to performance standard?
• What are the ingredient and impurity thresholds across the standards?
• What are the ecological endpoint standards? Are there study standards?
• Ready biodegradability; aquatic toxicity (acute and chronic);
bioaccumulative
• What are the human health endpoints? Are there study standards?
• Cancer, developmental/reproductive, genotoxic, mutagen, acute
toxicity, repeat dose toxicity, skin irritation, eye irritation, skin or
respiratory sensitizer and possibly endocrine disrupting or neurotoxic
• Is route of exposure considered?
• In the case of a data gap for a standard what is acceptable?
• Private-study data (GLP, standards, QA/QC)?
• Quantitative structure–activity relationship modelling?
• Read-across?
• Weight of evidence?
Transparency of Review for Ecolabel
• Are the reviews for ecolabel published and/or freely accessible?
• Is there a way to protest a ruling from review?
• Is there a me-too fast-track review?
Standardization of ecolabels have been driven by VOLUNTARY programs or
mandates for sustainability such as governmental green procurement. How
have the influenced criteria/standards for ecolabels?
• United States Executive Order (EO) 13693
• European Commission – Green Public Procurement
• Australia – Sustainable Procurement Guide
• South Africa – Sustainable Public Procurement
• China – Green Public Procurement
REFERENCES
Australia. 2013. Sustainable Procurement Guide. National Waste Policy: Less
waste, more resources.
Big Room Inc. 2015. http://www.ecolabelindex.com/ Accessed: October 26,
2015
China. 2006. Green Public Procurement.
European Commission. 2013. Green Public Procurement. Decision No
1386/2013/EU of the European Parliament and of the Council of 20
November 2013 on a General Union Environment Action Programme to 2020
‘Living well, within the limits of our planet’
South Africa. 2008. Sustainable Public Procurement in South Africa.
United States President. 2015. Executive Order (EO) 13693. Planning for
Federal Sustainability in the Next Decades
Consumer Goods
(Cleaning Products,
Cosmetics, and
Textiles)
21%
Construction,
Building Practices,
and Forest Products
16%
Foods (Includes
Coffee)
16%
Electronics and
Appliances
12%
Waste Management
7%
Business Practices
6%
Travel and/or
Tourism
5%
Energy
5%
Machinery and
Equipment
4%
Transportation
4%
Water Resources
2%
Carbon
Offsets
2%
Other
0.5%
Consumer
Goods (144)
Cleaning
Products (73)
Cosmetics
(66)
Textiles
(108)
Non-Profit 80 35 37 61
Profit 37 18 18 25
Governmental 16 13 6 13
Industry Association 9 4 2 6
Declaration based (1st party) 9 2 3 7
Self-certify (2nd party) 38 18 20 30
Criteria fulfillment reviewed
by independent entity (3rd
party)
94 51 41 69
Published and publically
available standards
111 61 46 74
Published fee-based
standards
28 2 10 23
Audit 115 53 47 87
Recertification 81 50 30 39
Enforcement 81 50 30 39
Hazard review 32 29 14 22
Hazard review – published
criteria
25 23 13 18
CONSUMER GOODS ECOLABEL REVIEW
PROPOSED APPROACH FOR REVIEWING HAZARD BASED ECOLABELS
Initial screening of 463 ecolabels from the open source non-subscription version
of the Ecolabel Index (Big Room Inc., 2015) identified hazard based ecolabels.
• What are the products, services, or issues defining the ecolabel?
• Conformity of criteria or standards performed by independent 3rd party, self-
certify (2nd party), or declaration based non-standard 1st party?
• Are the criteria or standards published, freely accessible, or fee-based?
• Does a product or company get audited for conformity to criteria or standards?
• Are their enforcement methods for non-compliance?
• Is there recertification or re-review after a period of time?
ECOLABEL PRODUCT CATEGORIES CHART
Ecolabels with ecological and human health hazard criteria were associated with
“consumer goods”, namely, cleaning products (73), cosmetics (66), and textiles
(108). There were 144 unique consumer good labels as some ecolabels
overlapped between the cleaning product, cosmetic, and textile subcategories.
GREEN-WASHING: WHAT IS A MEANINGFUL ECOLABEL
Nikki Maples-Reynolds and Duane B. Huggett
Waterborne Environmental Leesburg, VA, USA

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Waterborne_Ecolabel_draft NMR_2015

  • 1. BACKGROUND AND OBJECTIVES Currently there are over 400 ecolabels for food and consumer products in the global marketplace. These labels are marketing efforts informing the purchaser of a variety of claims of sustainability measures enacted by companies. The marketplace is flooded with several similar claims on whether a product is less hazardous, sustainable, organic, non-GMO, fair-trade, recyclable, recycled, carbon neutral, or biodegradable. Generally there are four types of labels in order of volume, 1) voluntary environmental certification programs, 2) self- or 3) cause-related claims and 4) governmentally regulated. The federal, some state, and International governments have limited direct roles in ecolabeling beyond mandatory hazard warning (e.g., pesticide or Prop. 65) or informational disclosures (EPA fuel economy, certified organic, WaterSense, or Energy Star). There are several third-party certification and quasi-governmental programs that lend credibility to an ecolabel; however, standardization or centralization of these programs are lacking. RESULTS AND DISCUSSION • 6% of the consumer goods were declaration based, no associated standard ecolabels also called Type III per The International Organization for Standardization (ISO). • 26% were self-declared environmental claims (Type II ISO standards). • 65% of the consumer goods ecolabels were reviewed by an independent 3rd party reviewers (Type I ISO standard). • The ISO Type I ecolabel association, Global Ecolabelling Network, harmonizes 25 ecolabel organizations worldwide. However, the ISO standards are not freely accessible. 19% of the consumer good ecolabels have fee-based standards. • 77% of the ecolabels had publically available standard. • 56% of the ecolabels had recertification reviews within 1-2 years of initial award. • 56% of the ecolabels reviewed had some form of enforcement against companies or products that failed to conform to criteria or standard once awarded. • Deceptive claims are primarily discovered by concerned citizens or watchdog non-governmental organization. • Review of the 25 published hazard standards indicated that hazard data and hazard identification from Authoritative peer-reviewed open-sources were preferred. • Globally Harmonized System of Classification and Labelling of Chemicals (GHS CLP), EU’s Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), California EPA’s Proposition 65, U.S. EPA and Europe’s pesticide data, U.S. EPA’s Integrated Risk Information System (IRIS), and Agency for Toxic Substances and Disease Registry (ATSDR), NTP (National Toxicology Program), and International Agency for Research on Cancer (IARC). FUTURE RESEARCH Compare Hazard Based Criteria or Standards • Do all products need to conform to performance standard? • What are the ingredient and impurity thresholds across the standards? • What are the ecological endpoint standards? Are there study standards? • Ready biodegradability; aquatic toxicity (acute and chronic); bioaccumulative • What are the human health endpoints? Are there study standards? • Cancer, developmental/reproductive, genotoxic, mutagen, acute toxicity, repeat dose toxicity, skin irritation, eye irritation, skin or respiratory sensitizer and possibly endocrine disrupting or neurotoxic • Is route of exposure considered? • In the case of a data gap for a standard what is acceptable? • Private-study data (GLP, standards, QA/QC)? • Quantitative structure–activity relationship modelling? • Read-across? • Weight of evidence? Transparency of Review for Ecolabel • Are the reviews for ecolabel published and/or freely accessible? • Is there a way to protest a ruling from review? • Is there a me-too fast-track review? Standardization of ecolabels have been driven by VOLUNTARY programs or mandates for sustainability such as governmental green procurement. How have the influenced criteria/standards for ecolabels? • United States Executive Order (EO) 13693 • European Commission – Green Public Procurement • Australia – Sustainable Procurement Guide • South Africa – Sustainable Public Procurement • China – Green Public Procurement REFERENCES Australia. 2013. Sustainable Procurement Guide. National Waste Policy: Less waste, more resources. Big Room Inc. 2015. http://www.ecolabelindex.com/ Accessed: October 26, 2015 China. 2006. Green Public Procurement. European Commission. 2013. Green Public Procurement. Decision No 1386/2013/EU of the European Parliament and of the Council of 20 November 2013 on a General Union Environment Action Programme to 2020 ‘Living well, within the limits of our planet’ South Africa. 2008. Sustainable Public Procurement in South Africa. United States President. 2015. Executive Order (EO) 13693. Planning for Federal Sustainability in the Next Decades Consumer Goods (Cleaning Products, Cosmetics, and Textiles) 21% Construction, Building Practices, and Forest Products 16% Foods (Includes Coffee) 16% Electronics and Appliances 12% Waste Management 7% Business Practices 6% Travel and/or Tourism 5% Energy 5% Machinery and Equipment 4% Transportation 4% Water Resources 2% Carbon Offsets 2% Other 0.5% Consumer Goods (144) Cleaning Products (73) Cosmetics (66) Textiles (108) Non-Profit 80 35 37 61 Profit 37 18 18 25 Governmental 16 13 6 13 Industry Association 9 4 2 6 Declaration based (1st party) 9 2 3 7 Self-certify (2nd party) 38 18 20 30 Criteria fulfillment reviewed by independent entity (3rd party) 94 51 41 69 Published and publically available standards 111 61 46 74 Published fee-based standards 28 2 10 23 Audit 115 53 47 87 Recertification 81 50 30 39 Enforcement 81 50 30 39 Hazard review 32 29 14 22 Hazard review – published criteria 25 23 13 18 CONSUMER GOODS ECOLABEL REVIEW PROPOSED APPROACH FOR REVIEWING HAZARD BASED ECOLABELS Initial screening of 463 ecolabels from the open source non-subscription version of the Ecolabel Index (Big Room Inc., 2015) identified hazard based ecolabels. • What are the products, services, or issues defining the ecolabel? • Conformity of criteria or standards performed by independent 3rd party, self- certify (2nd party), or declaration based non-standard 1st party? • Are the criteria or standards published, freely accessible, or fee-based? • Does a product or company get audited for conformity to criteria or standards? • Are their enforcement methods for non-compliance? • Is there recertification or re-review after a period of time? ECOLABEL PRODUCT CATEGORIES CHART Ecolabels with ecological and human health hazard criteria were associated with “consumer goods”, namely, cleaning products (73), cosmetics (66), and textiles (108). There were 144 unique consumer good labels as some ecolabels overlapped between the cleaning product, cosmetic, and textile subcategories. GREEN-WASHING: WHAT IS A MEANINGFUL ECOLABEL Nikki Maples-Reynolds and Duane B. Huggett Waterborne Environmental Leesburg, VA, USA