CIP-Eco-innovation Pilot and market replication

Grant Agreement number: ECO/10/277233

ECOPLASBRICK

Innovative recycled plastic based panels for building field

Deliverable N

D4.1

Title

Requirements analysis for Eco-Label and Environmental

Product Declaration

Name of the Author

Tiziana Sorice

Partner

Consorzio TRE

Telephone

+39 081 7256211

e-mail

tiziana.sorice@consorziotre.it

Deliverable
Responsible

Consorzio TRE

Dissemination level

PU

Due date

29th June 2012

Submission date

29th June 2012

Status

Rev.0 - Draft

Disclaimer
The information in this document is provided as is and no guarantee or warranty is given that the information is
fit for any particular purpose. The user thereof uses the information at its sole risk and liability. The document
reflects only the authors views and the Community is not liable for any use that may be made of the information
contained therein.

ECOPLASBRICK Deliverable N4.1

Table of content
1 Introduction ....................................................................................................................... 3
2 The ISO 14020 series - Environmental labels and declarations........................................ 3
2.1

Type I ....................................................................................................................... 4

2.1.1

Eco-Label ........................................................................................................... 4

2.2

Type II ...................................................................................................................... 4

2.3

Type III ..................................................................................................................... 5

2.3.1

EPD Environmental Product Declaration ....................................................... 5

3 Product Groups and Categories currently regulated by the marks .................................... 6

3.1

Eco-Label Product Groups ....................................................................................... 6

3.2

EPD Product Categories ........................................................................................ 6

4 Procedure for the eco-brand application .......................................................................... 9

4.1

Eco-Label ................................................................................................................. 9

4.1.1
4.2

Eco-label - realization time and mark time validity ......................................... 11

EPD ........................................................................................................................ 11

4.2.1

EPD - realization time and mark time validity ................................................. 13

5 Labeling Type I - Ecolabel .............................................................................................. 14

5.1

Costs ....................................................................................................................... 14

5.2

New Product Groups .............................................................................................. 15

6 Labeling Type III Environmental Product Declaration................................................ 15

6.1

Costs ....................................................................................................................... 15

6.2

New Product Category Rules ................................................................................. 16

7 Conclusion ....................................................................................................................... 16
8 References ....................................................................................................................... 17

ECOPLASBRICK Deliverable N4.1

1 Introduction
Research activities about Task 4.1 - Requirement Analysis for Eco-label and Environmental
Product Declaration - refers to the analysis of existing product groups and product categories
and related rules as well as the verification of compatibility of the Ecoplasbrick product for
the allocation of eco-environmental labels governed by ISO 14020.
Particularly, the activity in this document is the result of the analysis of two types of brands,
Eco-Label and Environmental Product Declaration EPD, and the verification of a product
compliance with the requirements of validity of labels. This research will support the
evaluation about the applicability for the Ecolabel and/or Environmental Product Declaration
to our innovative product and for the activities regarding Task 4.2 LCA; the aim is to support
and address the definition of the goal and scope for Life Cycle Assessment Analysis.

2 The ISO 14020 series - Environmental labels and declarations

The ISO 14020 series Environmental labels and declarations General Principles is an
International Standard and establishes guiding principles for the development and use of
environmental labels and declarations. It is intended that other applicable standards in the ISO
14020 series be used in conjunction with this International Standard.
This International Standard is not intended for use as a specification for certification and
registration purposes.
Other International Standards in the series are intended to be consistent with the principles set
forth in this International Standard; the other standards currently in the ISO 14020 series are:
ISO 14021 ISO 14024 ISO/TR 14025.
Environmental labels, governed according to the ISO 14020, are labels applied directly to a
product or a service that provide information about the overall environmental performance of
the product/service throughout its life cycle (from production to use and disposal) or about
one or more specific environmental aspects.
There are three different types of eco-labels set up by the ISO 14020 series classified into
Type I, Type II and Type III.

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2.1

Type I

Type I label is a voluntary eco-label covered by the ISO 14024 and based on a multi-criteria
system that considers the entire lifecycle of the product.
Its used to certify products and services reduced environmental impacts and is subjected to
external certification by an independent body.

2.1.1

Eco-Label

The Eco-Label is the official European environmental certification which aims to identify
market products and services that have a reduced environmental impact. It was established in
1992 and is currently governed by EC Regulation n 66/2010. The Eco-Label labeling
guarantees to consumers an aware choice and a purchase of an eco product/service less
damaging to the environment. For this reason, the Eco-Label labeling is defined B2C
"Business to Consumer" and it is attributed to a product or a service directed to the end user.
The Eco-Label cannot be issued to intermediate products and is not applicable to chain
products; the term product refers to both consumer goods and services.
The Eco-Label can meet the growing demand from consumers oriented to an environmental
choice.
Its represented by a stylized daisy.

2.2

Type II

The Type II Ecological Labeling reports environmental self-declarations by the manufacturers

and suppliers about the ecological characteristics of the product. These self-declarations are
not validated or certified by an appropriate authority. Therefore, the responsibility for its use
is of the consumer himself.
It is governed by ISO 14021 which specifies the characteristics of so-called "claims"
(environmental claims) that communicate the significant environmental aspects along the life
cycle of the product, e.g.: the recycled content, recyclability or biodegradability of the
product, the absence of harmful substances for the environment, non-toxic or natural finishing
treatment, etc. .
The ecological label of the Type II refers to a single product and is defined B2C "Business to
Consumer" but can also be B2B "Business to Business".

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2.3

Type III

The Type III eco-label statements are based on established parameters and contain a
quantification of the environmental impacts associated with the lifecycle of the product
calculated through a LCA; they are governed by ISO 14025 and subjected to independent
monitoring.

2.3.1

EPD Environmental Product Declaration

The Environmental Product Declaration (EPD) is a voluntary product certification scheme

born in Sweden but of international importance; from a regulatory standpoint the EPD is
governed internationally by the Technical Report ISO / TR 14025:2000. The other references
are ISO standards that regulate the LCA methodology, which is the basis of calculating the
environmental performance communicated with the EPD.
The EPD is a tool designed to improve communication between producers, on the one hand,
and distributors and consumers, on the other, about their production environment strategies;
for this reason it is defined B2B "Business to Business".
The EPD is represented by a document containing the quantified environmental information
about the life cycle of a product, which was created by the manufacturer and/or supplier and
that, following a process of verification of data, accompanying the marketing of the product
described; therefore with the document it is possible to communicate objective, comparable
and credible information concerning the environmental performance of products and services.
These information have purely informational character, not foreseeing evaluation mode,
preferability criteria or minimum levels that the environmental performance must respect. The
label is checked and validated by an accredited independent body who guarantees the
credibility and veracity of the information contained in the LCA study and in the EPD
declaration.
Type I - Eco-Label

Type I - Recyclable

Type III - EPD

Table 1: Ecological labels

ECOPLASBRICK Deliverable N4.1

3 Product Groups and Categories currently regulated by the marks

3.1

Eco-Label Product Groups

The brand EU Eco-Label is structured in 13 products groups: it covers a huge range of

product groups, from major areas of manufacturing to tourist accommodation services.
For each group of product there are the corresponding subgroups for a total of 24 subgroups.
Key experts, in consultation with main stakeholders, develop the criteria for each product
group in order to decrease the main environmental impacts over the entire life cycle of the
product. Because each product has a different life cycle, a several ecological criteria for each
of them are defined, to which the product must conform to the purposes of allocation of the
mark. These criteria are present in the Commission Decision referred to each subgroup.
Every four years on average, the criteria are revised to reflect technical innovation such as
evolution of materials, production processes or in emission reduction and changes in the
market.
Product Groups for Eco-Label
1. Beauty care
2. Cleaning up
3. Clothing
4. Do it yourself
5. Electronic equipment
6. Coverings
7. Furniture

8. Gardening
9. Household appliances
10. Lubricants
11. Other household items
12. Paper products
13. Holiday accommodation

Table 2: The product groups for Eco-Label brand (update to June 2012)

Among existing product groups its interesting to evaluate COVERINGS subdivided in:
1. Wooden coverings;
2. Hard coverings;
3. Textile coverings.

3.2

EPD Product Categories

An EPD is a certified environmental declaration developed in accordance with the standard

ISO 14025; the creation of EPD refers to 12 different product categories that contain PCR
(Product Category Rules).

ECOPLASBRICK Deliverable N4.1

Product categories for EPD

1. Agriculture, forestry and fishery products
2. Ores, minerales, stone, etc
3. Energy and water
4. Food and beverages, etc
5. Textile and furniture, etc
6. Wood and paper

7. Rubber, plastics, glass and, chemicals

8. Metal
9. Machinery and appliances
10. Transport equipment and services
11. Services
12. Constructions, construction products and construction
services

Table 3: The product category for EPD brand (update to June 2012)

The PCR is a product technical card that represents the rules to be followed in drafting the
EPD. In PCR the criteria for membership of a product to a particular category, the scope of
the study of the Life Cycle Assessment of the product (LCA), and environmental issues
relevant to that category, are defined.
There are PCR reported both to a PCR of product group (PCR Basic Module) and both to
single PCR product (PCR); the latter may be a sub-product of the PCR Basic Module or a
single PCR.
The work developing PCR documents is the probably most vital element to coordinate in a
proper way. The international EPD system has therefore introduced a PCR classification
scheme building on a hierarchic approach to develop "PCR modules" in order to reduce the
workload and associated costs for developing, carrying out consultations and approving
PCRs.
The main rationale of the approach taken is to simplify and harmonize PCRs work and to
avoid market confusion and trade implications.
Its not possible to use a PCR-Basic Module as Product Category Rules (PCR) when
developing an EPD: PCR Basic Modules provides a close to ready-made PCR document, but
they are generally not PCR documents in themselves.
PCR Basic Modules includes text which is common for all full PCR documents regardless of
product group, e.g. the introduction section, but does not specify the detailed calculation rules
that are required in order for EPDs of the same product group to be comparable.
If an EPD is developed based on a PCR Basic Module instead of a PCR, only a precertification with a limited validity is possible to develop.

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In order to PCR development, Product Category Rules shall be prepared in an open and
participatory process either by:
-

companies and organizations in co-operation with other parties, such as branchand interest organizations;

institutions involving LCA experts in close cooperation with companies or branchand interest organizations,

or by single companies or organizations.

Developing PCR is a procedure including a staged approach with the following elements:
1. Initiation phase
2. Preparation phase
3. Consultation phase
4. Approval and publication phase
5. Updating phase
Regarding PCR documents content, the PCR shall define the criteria according to assigning a
product to a specific category, which parameters are set out to prepare the EPDs, the data
quality requirements and the collection and calculation rules for data to be included in the
EPD, as well as what kind of information suitable to convey to the primary audience of the
EPD.
The PCR document shall include:
-

Product category definition and description (e.g. function, technical performance

and use)

Goal and scope of the PCR ( e.g. functional unit/declared unit, system boundaries,
description of data and data quality, cut-off rules and units to be used)

Materials and substances to be declared in a content declaration

Inventory analysis results (e.g. data collection and calculation procedures, and

allocation of material flows and releases)

Pre-determined parameters for reporting LCA data (e.g. inventory data categories
and impact category indicators), as appropriate

Impact category selection and calculation rules, if applied

Description of the type of information to be included for the downstream

processes, i.e. the use and end-of-life stages

Rules for provision of additional environmental information

ECOPLASBRICK Deliverable N4.1

Instructions for converting the background data for the EPD format.

4 Procedure for the eco-brand application

4.1

Eco-Label

The procedure for requesting the brand Eco-Label is divided into 5 steps:
1. Identification of group membership
Its necessary to check if the product/service meets the criteria adopted at European level for
that product group. On website http://ec.europa.eu/environment/ecolabel/products-groupsand-criteria.html, for each product group there is the relative Commission Decision which sets
out the environmental criteria to which the product must be complies.
The EC Regulations 1221/09 and EMAS EC 66/10 ECOLABEL provide that each Member
State sets up the national Competent Bodies which are mandated with the task of applying the
Community schemes.
The Italian Ministerial Decree 413/95 established the Ecolabel Ecoaudit Committee to
perform the functions assigned to these Competent Bodies; for this purpose it has also
determined that it

should

use the technical

support

of

ISPRA

(Institute for

Protection and Environmental Research).

To facilitate the preparation of documentation and facilitate the subsequent investigation, the
Competent Body/ISPRA provides to the applicant, with respect to each product group, a
manual containing a technical guidebook and verification forms. Each manual contains all
information pertaining to the criteria and test reports earnings for the release of the brand for
that product group.
2. Initiation of proceedings
It

must

send

the

application

form

of

the

mark,

by

registering

online

at:

https://webgate.ec.europa.eu/ecat_admin.
3. Preparation of documentation
The applicant shall prepare all necessary documentation consisting in: the application form
online, a receipt for payment of the inquiries cost, the registration certificate at the Commerce
Chamber, the documents required for the technical evaluation of criteria compliance. All the
documentation is collected in a separate file, in which there must be also a description of the

ECOPLASBRICK Deliverable N4.1

product use that the applicant intends to do once you get the label and sends it to the
Committee Ecolabel-Ecoaudit, Section label.
4. Request and review
The European Committee EcoLabel-Ecoaudit examines the documentation, requires
additions and shall, where appropriate, one or more inspections. To complete the
investigation, the Committee will normally have 60 days time. In this period the Committee
sends the request to ISPRA to perform administrative and technical investigation to verify
compliance with the established criteria. In the case of a positive outcome of the investigation
the Committee, within 30 days, grants the label and inform the European Commission.
5. Eco-Label award and renewal of the contract
If the application is successful the Board grants to the applicant, after signing the appropriate
agreement and registration by the European Commission, the license to use the mark with a
validity on all the European territory; then the name of the product is inserted in the
Community register of products/services Eco-Label. The assignment contract of the EcoLabel license is renewed under the simplified procedure whenever the criteria for the relevant
group of products are subject to change. If the contract terms are violated, the Competent
Body has the power to suspend the right to use the mark.
THE APPLICANT
Verifications compliance with
the criteria and sends the file

Involves technical support

COMMITTEE ECOLABEL
ACOAUDIT

ISPRA
Expresses its opinion
Performs administrative and
technical investigation

Has the investigation been

successful?

YES

EUROPEAN COMMITTEE
Notifies the decision

NO

The applicant cant have the

label for him product

Release
the label
EcoEco-Label

Figure 1: Procedure for the Eco-Label brand application

ECOPLASBRICK Deliverable N4.1

10

4.1.1

Eco-label - realization time and mark time validity

If the product meets the eco-label criteria, the time for obtaining the mark is from 3 to 4
months after the application to the European Commission.
The period of label validity is linked to the period of criteria validity specified in the contract
for the use of the mark. The validity of the ecological criteria for the interest product group
and their assessment and verification, extends for 4 years from the adoption date of the
current European Commission decision.
A contract awarding the Ecolabel license is renewed under the simplified procedure whenever
the criteria for the relevant product group undergo changes.

4.2

EPD

The Organization of International EPD System is structured in:

-

Technical Committee

Secretariat

Verifiers

Creating an EPD in the international EPD system includes the following steps:
-

Considering available PCRs and prepare PCR document:

The PCR is a technical product card (Product Category Rules) which
represents the rules to be followed in drafting the EPD. In PCR are defined the
criteria for membership of a product to a particular category, the scope of the
study of the life cycle of the product Life Cycle Assessment (LCA) and
environmental issues relevant to that category.

Collecting LCA-data to be included in the EPD:

It is necessary to realize a LCA data collection that will be included in the
declaration EPD. The implementation of the LCA must meet the standards ISO
14040 and 14044, the criteria established by ISO 14025 for the drafting of EPD
and the guidelines of the relevant PCR. The LCA analysis must include all
information from cradle to grave. In the absence of information, is possible to
use generic data only if the environmental impact associated with this data does
not exceed 10% of the overall environmental impact of product system.

Drafting EPD:

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11

It is necessary to compile environmental information into the EPD reporting

format in addition to the LCA-based data
-

Checking EPD:
Independent and External agency have to verify the data of the LCA, the
additional environmental information and the EPD elaborated;

Registration of EPDs into the international EPD system by the secretariat:

in this event it is necessary to send the registration request in attach with: the
registration form for the EPD, a copy of the approved audit, the EPD carried
out (.doc or .pdf document), a brief description and high resolution image of
the product/service that was said and the company logo.
The applicant will receive formal confirmation of the registration with the
relevant registration number for the product/service and the EPD is
immediately published on the Internet.

Rules for using the logotype:

Its necessary to respect some recommendation for example for using on the
declarations, on product and packaging materials and on all types of
information materials.

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12

THE APPLICANT
Identifies the relative PCR
Realizes LCA

Draws EPD by PCR

Records to International EPD

System

BODY EXTERNAL VERIFIER

Makes the check of the LCA and EPD
informations

Is the label valid?

YES

Release
the label
EPD

NO

The applicant cant have the

label for him product

Figure 2: Procedure for the EPD brand application

4.2.1

EPD - realization time and mark time validity

If the product meets the criteria for membership of a pre-set PCR, the time for obtaining the
label are related to the output time of the LCA information, indicatively 3 4 months.
In case of lacking specific LCA data, as a special rule within the international EPDsystem,
companies and organizations are allowed to use a defined proportion of generic data and
assigns data sources for selected generic data describing material flows connected to a number
of input materials. The only tie to respect is environmental impact associated to other generic
data must not exceed 10% of the overall environmental impact from the product system.
The EPD does not have a deadline because it is an information document, while the PCR has
it; it is fixed by the moderator and generally extends for a period of three years. The
moderator is the coordinator of the group of interest in the creation or update of a PCR in a
PCR Forum.
If the validity period of a PCR document has expired, the document can be updated and
reactivated on demand. In this case, the moderator announces on the PCR Forum the starting

ECOPLASBRICK Deliverable N4.1

13

of an upgrade process of PCR, clearly indicating the time within to provide comments during
which it is possible to provide comments. In case no comment is received on the PCR, it is
possible to extend the validity of the original document.
If there are important advices to do about the PCR in the Forum, the PCR can also be updated
at shorter deadlines intervals.

5 Labeling Type I - Ecolabel

5.1

Costs

Costs are divided in three types:

1. Start-up costs
2. Preliminary costs
3. Annual fee
Start-up costs involve testings cost and they must be paid directly to the laboratories. Initial
expenses are variable and include the rates incurred by the applicant to satisfy the required
criteria and prepare the documentation.

Preliminary costs mean an application fee, that is costs of processing the application and they
must be paid to the competent ANPA (National Agency for Environmental Protection) at the
presentation of the dossier.
Actually dues is 500 per product.
Annual fee means costs law annual for label maintenance; they must be paid to the
competent body after the conclusion of the contract and are equal to 0.15% of the annual
volume of sales within European Community. The period covered by the annual fee
commences on the date of award of EU Eco-label to the applicant.
Actually dues is a minimum amount of 500,00 to a maximum amount of 25.000,00 .
Its possible a reduction in the annual fee cost directed at micro-enterprises, SMEs, ISO
certified organizations under 14001/EMAS:
25% in case of SME suppliers or manufactures in developing countries;
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14

15% in the event that the applicant has a certification under EMAS and or ISO 14001
certified;
25% to the first three applicants for the brand of the same items group.

5.2 New Product Groups

The European Commission gives to manufacturers the possibility to propose new product
groups even if the process is very long; there is a format to be filled and then European Ecolabeling Board (EUEB) select priorities to be developed in the coming years only for
consumer products.
Beyond the timing to start the development proposal for Ecolabel criteria, the technical
documentation and the relevant scientific should be prepared and sent to the EU Commission.
Actually Ecolabel Regulation 66/2010 involves a simplified procedure to adopt criteria
developed on the basis of other systems for the allocation of eco-labels EN ISO 14024 Type I
as for example Nordic Swan or Blue Angel.
However current priorities are for building components including insulation and plastic
pellet master batch.

6 Labeling Type III Environmental Product Declaration

6.1 Costs
Costs are divided in:
1. Start-up costs
2. Registration fee
3. Annual fee
Start-up costs means testings costs and must be paid directly to the laboratories. They
include expenses incurred by the applicant to carry out the Life Cycle Assessment of the
product.
Registration fee for the application depends on the requests number:
1 EPD amount to 1.000,00
2 EPD amount to 1.500,00

ECOPLASBRICK Deliverable N4.1

15

3 or 4 EPD amount to 2.000,00

for more than 5 EPD is needed to contact the Secretariat.

Annual fee amount to:

1.000,00 for small and medium size organizations
2.500,00 for large enterprises

6.2 New Product Category Rules

It is not possible to create a new category, but its possible to create a specific PCR according
to PCR Basic Module existing even if the product is not commercially available.
Total time for the process is 4-5 months: in detail 2 or 3 weeks are necessary to prepare the
PCR instead for the technical consultation is needed 8 weeks; finally the approval by the
Technical Committee requires 2-3 weeks.
In this case there are no registration fees but the consulting costs are variable.
Moreover the EPD can be processed but not published; its admitted only for the product in
production.

7 Conclusion
Conclusions about applicability Ecolabel brand to our panel are:
a) We cannot consider our Ecoplasbrick panel under existing product group: Coverings.
In spite of the sub-product groups contemplate external/internal Hard Coverings, they
consider:
-

natural product (natural stone)

processed product (hardened product and fired product)

no mention to sandwich panel.

b) Considering the chance to create New Product Groups, we involved technical support by
ISPRA and they tell us its not possible certify Ecolabel award for prototype but only for
consumer product.
c) Currently our ecoplasbrik panel is a prototype
Therefore we cant consider Ecolabel - label Type I - for our Ecoplasbrick panel

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Regarding EPD labelling:

a) Among existing product category we could consider Constructions, construction
products and construction services even if its possible to develop only basic module;
however the only construction products contemplated are made in concrete, no
mention to sandwich panel.
b) We cannot create a new category, but we can create a Specific PCR according to PCR
BASIC MODULE existing even if the product is not commercially.
c) Considering the chance to create a Specific PCR, we involved Technical Committee, a
group of LCA/EPD expert to assist the Secretariat and they refer us EPD through a
Specific PCR can be processed but not published, moreover its admitted only for the
product in production.
We cant apply Environmental Product Declaration -

label Type III to our

Ecoplasbrick panel.
The activities will focus on the production of a Type II Environmental Label according to
the standard ISO 14021 Environmental labels and Declaration Self-declared
environmental claims.

8 References
http://www.isprambiente.gov.it/certificazioni/site/it-IT/Ecolabel_UE
EC Regulation N.66/2010 of the 25 November 2009
http://www.iso.org/iso/catalogue_detail?csnumber=34425
http://ec.europa.eu/environment/ecolabel/products-groups-and-criteria.html
The General Programme Instructions for EPD Version 1.0 dated 2008-02-29

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