Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica A Report from the University of Florida 2009 Costa Rica Conservation Clinic

Authors: Wesley W. Ingwersen, Silvia Alvarez Clare, Diego Acuña, Milagros Jean Charles, Carli Koshal and Ana Quiros Clinic Director: Tom Ankersen, J.D. Project Advisors: Franklin Paniagua and Jon Dain Project website: http://www.epdcostarica.info November, 2009 Gainesville, FL English Version

Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

PREFACE Conservation in the context of development demands new tools that provide measureable conservation gains of the activities that sustain local economies and global consumers. This report examines the application of a relatively new instrument, environmental product declarations (EPDs), to the production of Costa Rican goods, consumed nationally and abroad. These are voluntary instruments, based on a standardized environmental evaluation, which reveal in the form of published declarations how products relate to the local and global environment throughout their life cycles, from the early stages of production to end consumption and disposal. Their success depends in part on the extensiveness of their adoption and use as an environmental measuring stick by producers; in part on the development and administration of these declarations which will determine their scientific credibility, impartiality, and the effectiveness of their communication; and heavily on the part of buyers and end-consumers, who have the ability to choose the products with the most favorable environmental performance, and thus through market forces, drive the success of more environmentally responsible production practices. While programs for environmental product declarations do exist in Europe, North America and Asia, environmental product declarations have yet to be applied in Costa Rica. Yet there are numerous signals that suggest Costa Rica may be an excellent place for its adoption: it has been early among its peers in adopting conservation instruments and goals, such as payments for environmental services and a national carbon neutral plan; it has a history of respect and extensive adoption of international certification programs, and many of its products are consumed in regions, such as Europe, where there is an increasing public demand for the information that these labels provide. Finally, there has been rising antagonism between producer of pineapples and groups concerned about the impacts this is having on local environments. Acknowledging this situation we consider the particular example of an environmental product declaration in this sector, as one potential conservation tool, not exclusive of existing regulations and other certifications, to mediate this conflict and address the needs and concerns of both sides. In a workshop composed of various stakeholders in the industry as well as certification experts, on July 23, 2009 we introduced the concepts of EPDs, specifically talked about how the process of creating an EPD for pineapple, but also discussed the steps toward establishing a general EPD program in Costa Rica. The results of this workshop are summarized and integrated into our final recommendations. With conflicts such as these at a head, and the unique climate in Costa Rica for novel environmental instruments, the authors intend this report to introduce policy makers to another conservation tool, discuss it in terms of programs in other countries and the Costa Rica context, and make our recommendation on whether and how environmental product declarations should be used in Costa Rica. -The Authors

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

GUIDE TO KEY ABBREVIATIONS EPD – Environmental Product Declarations. Also known as Type III labels, these are producer declarations of the environmental performance of a product made according to independently established guideless and subject to independent review. Environmental performance in EPDs is measured with LCA. EPDs are described in ISO 14020 and 14025. ISO – International Standards Organization. LCA – Life Cycle Assessment. A framework for assessing the environmental impacts of goods over their entire life cycles. LCA is described by ISO 14041 and 14044. LCI – Life Cycle Inventory. A collection of data on inputs and outputs of processes on which a LCA is based. PCR – Product Category Rules. These are the common guidelines for the publication of an EPD for a product in a given category.

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

TABLE OF CONTENTS Introducing Environmental Product Declarations .......................................................................... 1 Models of Other EPD Programs ..................................................................................................... 9 Costa Rican Institutional Context ................................................................................................. 15 Fresh Pineapple: An Investigation into a First Product Category................................................. 18 Synthesis: Recommendations on EPDs in Costa Rica.................................................................. 21 Conclusions ................................................................................................................................... 24 Acknowledgements ....................................................................................................................... 25 Appendix ....................................................................................................................................... 25

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

INTRODUCING ENVIRONMENTAL PRODUCT DECLARATIONS Labeling of goods to provide buyers and final consumers with information regarding the production of goods has a long history. Perhaps in its simplest form, a label may name only the country of origin of a product. Food products often contain much more information than origin, referring to the production but also to the contents of products themselves, such as nutrition information, ingredients, weight or volume of contents, and health and safety information, depending on both voluntary and mandatory requirements, such as those specified by the international Codex Ailmentarius1 and the USDA. Such labels are used both to educate and assure buyers and consumers, but they are also used to influence purchasing decisions. Labels generally present information of two forms – that which is descriptive and that which represents a seal of approval. In the last few decades, labels have emerged which specifically address environmental aspects of products. One index of environmental labels reports over two-hundred and seventy different sponsors of environmental label programs across the globe, but this is certainly an under-estimate of the actual number.2 These labels span a variety of nations and products and indicate the growing trend and consumer demand for environmental production process information. Environmental labels as a way of distinguishing environmentally sustainable practices One of the first environmental labels was Blue Angel label in Germany, introduced in 1978. The Blue Angel, and many of the environmental labels found on goods today, represent a seal of approval type label, which signifies that an independent body reviewed the environmental management of the product production, and found that it met certain criteria that represent environmental sound management for that product category. Other types of labels present descriptive environmental claims, made by the manufacturer themselves and subject to no independent review or criteria. These claims are often in the form of simple qualitative terms, such as “green”, “environmentally friendly”, or “sustainable”. The different forms of environmental labels have been codified by the International Standards Organization (ISO). Seal of approval type labels generally fall under a category of labels defined as Type I environmental labels by the International Standards Organization. The second type of label mentioned, self-declarations, are Type II labels. A third, and the most recently standardized form of labels, and the focus of this investigation, are environmental product declarations, or Type III labels. 3

1

See www.codexalimentarius.net and http://www.fsis.usda.gov/Fact_Sheets/Food_Labeling_Fact_Sheets/ This estimate primarily includes Type I like eco-labels. http://ecolabelling.org/search/apachesolr_search/*?filters=type:ecolabel&solrsort=stitle%20asc 3 The Blue Angel program can be found here http://www.blauer-engel.de/en/index.php 2

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

Table 1. Environmental label types for products ISO 14020 Environmental Label Definition (specific ISO standard) Type I (ISO 14024) claims are award-type labels, based Eco-label (Type I) on predetermined requirements set by a third party (not by manufacturer or retailer) and are multi-issue, depending on the product’s life cycle impacts. The label identifies environmentally preferred products within a product category. (14024) Product claims are based on self-declarations by Self-declaration (Type II) manufacturers or retailers. (14021) Provides quantified environmental product information Environmental Product for the entire life cycle of a product, issued by a Declaration (Type III) supplier. It is based on independently verified, systematic data and is presented as parameters in a set of categories describing the environmental performance of the product or the service. It is relevant to all products and presents the information in a format that facilitates comparison between products (14025) Environmental claims that address a single Single-issue claim environmental issue, to which the general principle of environmental labels (14020) apply, but for which no specific standard exists. Single issue labels can be in the style of any of the three types, but only address one environmental aspect of a product. These four type of labels are defined in Table 1. Environmental Product Declarations An environmental product declaration, or henceforth EPD, presents quantified environmental data for a product related to aspects of resource use and wastes created, that together describe the environmental performance of the product or the service. It is based on independently verified data collection and analysis and also referred to as a Type III environmental declaration based on ISO 14020 standard. An example of an EPD for a steel product is presented in Figure 1. The common objective of environmental labels and declarations is to promote demand and supply of products that cause less of an impact on the environment, by providing information to consumers. A Type III declaration provides this information through quantitative assessment that should assist buyers in making decisions when comparing products, encourage continuous market-driven environmental performance, and help in assessing environmental impacts.4 A 4

GEDnet. 2006. International Guide to Environmental Product Declarations. http://www.gednet.org/

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

requirement and unique component of EPDs is that the quantitative information has to result from a Life Cycle Assessment (LCA) of a product. Life Cycle Assessment A Life Cycle Assessment (LCA) analyzes and assesses products and services through their life cycle stages from the extraction of resources to manufacturing/assembly, distribution, use, and discarding/recycling according to a method that anticipates environmental aspects and potential environmental impacts.5 LCA generally consists of 4 steps: (1) goal and scope definition; (2) inventory analysis; (3) life cycle impact assessment, and (4) interpretation. Quantitative methods are used in an LCA to measure impacts associated with product life cycles such as global warming, acidification, smog-creation, resource depletion, energy and water use, and toxicity impacts. ISO provides guidelines for LCA as for eco-labels, under the 14041 and 14044 standards. LCAs for EPDs The ISO 14040 series standards are only general guidelines that do not define the stages of the life cycle that have to be considered, the level of detail to be used in the collecting the data, legitimate sources of data, the impacts to be measured, or how to report the results. Product category rules (PCRs) have to be specified so that results presented in EPDs are comparable. PCRs must state: • The definition of the product category • The goal and scope of the LCA • Rules for creating the inventory • Impact types and calculation tools to be used for measuring the impacts • Additional environmental information, materials or substances to be reported • Formatting instructions • Period of validity of the EPD

5

Baumann, H. and A.-M. Tillman. 2004. The hitchhiker's guide to LCA: an orientation in life cycle assessment methodology and application. Studentlitteratur AB. Lund, Sweden.

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

Figure 1. Excerpts from an EPD of a steel product from the International EPD program. The cover page and one of two pages on environmental performance are depicted. The full EPD can be downloaded from http://www. environdec.com. EPD Programs Before an EPD can be published, and EPD program needs to be established. Three parties are essential to any EPD program: Program Operator – Responsible for administration of program. Define general program instructions which include rules for publication and independent verification of EPDs. Producers/Manufacturers – Entities creating the EPDs for their products Verifiers – Independent agents that verify EPDs. In addition to these groups, other groups involved may be those that initiate or guide the institution of the EPD program, and other parties assisting in the creation of the PCRs for the various product categories in the program. Although they may vary slightly between EPD programs, the steps for publishing an EPD are described in Figure 2.

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

Program Operator

1. Establishment of product rules

6. Publication of final EPD

2. Inventory

5. Independent verification

3. Impact Evaluation (LCA)

Verifier

4. Preparation of EPD

Producer/Manufacturer Program Operator

Figure 2. Steps for creating an EPD. The process of developing the rules for an EPD is coordinated by the program operator, but should attempt to involve to all interested parties (ISO 14025, 2006). These may binclude companies or producer associations, life cycle assessment and EPD experts, and buyer and consumer groups. Once created, PCR documents are published by the program operator and available for producers interested in publishing an EPD for that category. LCAs for EPDs may be conducted by the producer themselves or by experts contracted by producers. Once the EPD is prepared it has to be verified by independent groups deemed eligible for verification by the program operator. Once verified, the EPD may be published by the program operator and distributed by the producer. EPDs compared with other environmental labels used in Costa Rica The advantages and disadvantages of EPDs are best explained in the context of other types of environmental labels. Company labels Environmental labels appearing on or with products may actually apply to products or may apply to the company that produces the product. A common labels that apply to companies are the ISO 14000 certification. ISO 14000 certifies that a company has an environmental management system in place that complies with the international ISO 14000 series guidelines. The Costa Rican Ministry of Energy and the Environment (MINAE) maintains a similar 5

Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

company level certification called the Bandera Ecologica, which requires having an environmental management system in place according a standard set by a national commission, as well as being fully compliant with environmental law (Commission Nacional Bandera Ecologica, 2007) Neither the ISO 14000 nor the Bandera Ecological directly convey information regarding the environmental management of a product over it life cycle. Therefore they are not considered here in direct comparison with EPDs and other ecolabels. Product Labels (Types I-III and single-issues labels) Numerous examples of Type I-like, Type II, and single-issue labels are currently in use in Costa Rica, particularly in the agricultural sector. Type I-like labels, so called because they are similar to the Type I labels defined by ISO but do not necessarily claim to be based on the ISO 14024 standards, include certifications like the Globalgap and Rainforest Alliance certifications. These labels are similar to ISO Type I labels in that they are seal of approval labels, where an independent body creates environmental management standards that have to be met by the producer. Self-declaration (Type II) labels in Costa Rica are common on many types of consumer products. One example are the various labels used on products made by Bioland S.A..6 Single-issue environmental labels may be quite variable in their implementation, reflecting characteristics of Type I and III labels. The USDA Organic label is a single-criteria label, in that it only concerns that a product is produced without the use of synthetic chemicals, but is similar to Type I labels, in that an independent body determines the criteria and awards the label.7 However others, such as the EnergyGuide,8 applied to energy-consuming appliances, is more like a Type III label in that it is quantitative and does not represent the approval of the body. A difference between the EnergyGuide and Type III labels, aside from not covering all relevant environmental aspects of a product, is that it is required for appliances sold in the United States, whereas the ISO-based labels are voluntary. A comparison of EPDs with these types of product labels is presented in Table 2. An EPD is by nature a neutral document – publishing an EPD does not in itself designate a product as “better” than others in its category according to criteria, as any producer can publish an EPD of a product. Furthermore some Type I-like standards require certain practices or prohibit the use of inputs to acquire the certification. For instance the Globalgap certification requires storage of agrochemicals in a structure constructed according to a set criteria, and prohibits the use of certain chemicals agents (GlobalGap 2009).9 EPDs, in contrast, may not levy specific requirements on producers. A key trait of EPDs are that they report the quantified environmental performance of a product over its entire life cycle, according to determined LCA rules. This is a notable difference 6

See http://www.bio-land.org/index-english.html USDA Agricultural Marketing Service. 2009. "National Organic Program." from http://www.ams.usda.gov/AMSv1.0/nop. 8 USDOE. 2009. "How to Read the Energy Guide Label." from http://www1.eere.energy.gov/consumer/tips/energyguide.html. 9 Globalgap. 2009. Control Points and Compliance Criteria Integrated Farm Assurance - Crops Base. Cologne. 7

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

between EPDs and other environmental labels. Evaluating a product’s performance with common criteria also enables products with EPDs in the same category to be directly compared and differentiated. Type I and II labels do not allow products within a category that have the certification to be compared. Table 2. Comparison of label types Type I-like (seal of approval) Neutral

No

Type II-like (selfdeclaration) No

Valid for any product in a category Requires specific practices

No

No

Yes

Yes

No

No

Prohibits use of certain inputs

Yes

Yes

No

Considers the entire life cycle

Only recommended Yes

No

Yes

No

Yes

Yes No

Depends on producer No

Depends on presentation Yes

Little

Not required

Very

Requires independent verfication Ease of understanding Permits differentiation from other products with the same label Quantitative

Type III (EPD)

Yes

Effect of EPDs in the market As the international standard for EPDs was not released until 2006, this is an recent evolution in product certification and there is little evidence yet as to whether or not EPDs have had an effect on product sales. Because of their novelty, hard financial data in terms of change in market share or percent change in sales for products with EPDs has not yet been published. As EPDs were initially designed for business-to-business transactions, changes in purchasing decisions by wholesale and retail buyers would be more likely to take place than changes in end-consumer purchasing. A study on the implementation of EPDs from a program toward the development of EPDs called Stepwise EPDs did not find them useful as a marketing

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

tool for end-consumers, however this is in part because these products lacked the program logo.10 On the other hand, EPDs and the LCAs that underlie them were seen as effective tools for communication of environmental information between producers and buyers, and as tools for improving the environmental management of production. EPDs, in comparison with Type I labels, are not as easily interpreted and for this reason, are not likely to have as strong of an influence over final purchasing decisions. However, authors of EPDs can at least in part overcome this challenge with improved methods for presenting the LCA information in the EPDs.11 Comparing the performance of a product directly with other projects in its category or with all consumer goods, especially in graphical format, would be more comprehensible for consumers. A recent example of a Type III-like label designed to communicate directly to consumers is the Walmart Sustainable Product Index. Announced by Walmart in July 2009, this index will provide a consumer-friendly simple index of environmental performance for a product based on life cycle assessment of its global supply chain.12 The intent of the project is both to allow Walmart to select more sustainable suppliers and for consumers to be able to compare environmental performance of products. Type III labels were found in a study of Australian consumers to be a potential solution to the problem of non-transparency and lack of credibility associated with Type I and II label types, respectively.13 However in the same study there were concerns among manufacturers that the costs of acquiring these labels would demand that their use be accompanied with premium pricing.

10

Zackrisson, E., C. Rocha, K. Christiansen and A. Jarnehammar. 2008. Stepwise environmental product declarations: ten SME case studies. Journal of Cleaner Production 16:1872-1886. 11 Christiansen, K., M. Wesnæs and B. P. Weidema. 2006. Consumer demands on Type III environmental declarations. Copenhagen, 2.0 LCA Consultants. 12 Walmart Stores Inc. 2009. "Walmart Announces Sustainable Product Index." from http://walmartstores.com/FactsNews/NewsRoom/9277.aspx 13 Clare, D. S., T. Mehdi, L. Peter and P. Roman. 2007. Green decisions: demographics and consumer understanding of environmental labels. International Journal of Consumer Studies. 31: 371-376.

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

MODELS OF OTHER EPD PROGRAMS An overview the governance structure, development process, and products covered by established EPDs programs is given in the following section. An examination of existing programs will provide potential models for the creation of a Type III EPD system in Costa Rica. It is important to clarify that there is no universal administrator for EPDs. EPDs are published according to the rules established by an EPD program administrator. ISO 14025 states that administrators should aim to make PCRs consistent between different EPD programs to make EPDs of similar products from different programs comparable. In order to close the gaps between PCRs in different programs, GEDnet, a network of global Type III environmental product declarations programs, was formed in 1999.14 Currently there are nine programs based on the process described in ISO 14025 (see Table 1) that are members of GEDnet. The list of member program is not all-inclusive; there are a number of Type III EPD systems that are not yet members of the international GEDnet organization. But the most established and best developed of those programs that are members of GEDnet are reviewed here. Most of these systems are non-governmental, but many were created by acts of government, and have their headquarters in these nations. Only one of the programs currently has EPDs from manufacturers outside of the country in which the EPD program is based. International EPD System (Sweden)15 Established: 1997 EPDs published: 76 (certified); 14 (pre-certified) PCRs published: 80 (published) International EPD System (Sweden) The International EPD® System one of the more extensive programs and arguably the most recognized. The program was created and given its mandates by the Swedish Environmental Ministry and is operated by the Swedish Environmental Management Council. 16 The program was started in 1997 and introduced to the public in 1999. The International EPD System operates with support from the government- and this governmental support is one of the factors that lend credibility to the system. An organization called the International EPD Consortium (IEC) acts as the program operator. It is responsible for system administration via a steering committee (SC), a technical committee (TC), and a secretariat. The TC serves as a PCR review panel while the secretariat handles general administrative work. The IEC is comprised of permanent members and associate members. Permanent members are organizations or associations that are interested in the development of the EPD. Associate 14

See http://www.gednet.org/?page_id=2 See http://www.environdec.com 16 The International EPD Cooperation. 2008. General Programme Instructions for Environmental Product Declarations. Version 1.0. Stockholm. 15

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

members, on the other hand, are other interested parties knowledge of PCR or LCA processes. The SC assists the Secretariat in the overall management of the system. The TC acts as the PCR review panel, suggests measures for further development, and considers applications and appoints LCA/PCR experts to act as external verifiers. Typically the TC is a small group of 3-5 experts. The secretariat is in charge of the overall management of the system. Outside of the IEC, the other primary participants in the EPD process in this system are the producers, who initiate and create a preliminary EPD, the PCR moderator and stakeholder consultation group, and certification agencies who review the EPD to ensure that it meets the requirements of the PCR. Also participating in this system are the national accreditation board, who accredit the certification agencies, and the Swedish institute of standards, who may assist in developing the final standard. Ministry of the Environment • Established EPD program

PCR Moderator and SCG

SWEDAC • Accredits and controls certification agencies

Program mandate

Accredidation

• Create PCRs

IEC Preliminary PCRs

Certification agencies

• Administers program • Organizes development and distribution of PCRs • Registers and publishes EPDs

Revised PCRs

•Verfies EPDs

Verified EPD

Solicits technical support for PCR

PCR

SMS

Preliminary EPD

Verification

Producer • LCA • Prepares initial EPD

• Supports the development of PCRs

Figure 3. The organizational structure of the International EPD System. IEC = International EPD Consortium; SCG = Product Category Stakeholder Consultation Group; SMS = Swedish Materials Standards Board; SWEDAC = Swedish Accreditation Board. Regarding measures beyond what is specified in ISO 14025, the International EPD program offers “pre-certification” for EPDs created for which a PCR does not yet exist. This enables producers to present environmental information before the PCR has been completed. Pre-certified EPDs are subject to special rules for provision of additional variation and are only valid until a PCR is developed.

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

There are a variety of products covered and EPDs registered within the International EPD system. These products include: food products and beverages, wood and wood products, chemicals and chemical products, non-metallic mineral products, basic metals, fabricated metal products, machinery and equipment, radio, television and communications, furniture, recycling, electricity, gas and water supply, land transport, refuse disposal, and sanitation. Products registered in the system as of August 2009 are from Sweden, Italy, Japan, the Czech Republic, Holland, and Poland. Ecoleaf (Japan)17 Established: 1998 EPDs published: 206 PCRs published: 53 Ecoleaf (Japan) Like the International EPD system, the Ecoleaf program in Japan is also widely regarded as a comprehensive EPD system. The Ecoleaf program is governed by the Japan Environmental Management Association for Industry (JEMAI). JEMAI is a public corporation organized by the membership of about 1,100 companies.18 The company operates with support from the Japanese Ministry of Economy, Trade and Industry.19 JEMAI was established in September 1962, when industrial pollution was becoming a serious concern in Japan. JEMAI began the process of developing Type III EPD assessments in September of 1998. The organization began trial programs for the Ecoleaf program in May 1999 and June 2000, and completed the trial phase in June 2001. During this process JEMAI established procedures for obtaining and verifying the Type III EPD information. The aim of Ecoleaf, as with all Type III declarations is to present information about the environmental impact of a product or service without making any judgment about whether the product or service meets any environmental quality standard. Similar to the Swedish system, the program has administrative and technical committees working under the program operator: a steering committee, a PCR committee, and a review committee. The steering committee is composed of experts from academia, industry, consumers, and public authorities. The committee makes administrative decisions regarding program operation and oversees the activities of the PCR and review committees. The PCR committee reviews proposed PCRs and authorizes their publication. Members of this committee include experts from academia and industry, and knowledgeable consumers. The review committee evaluates the EPDs submitted by producers. The review committee members are LCA experts familiar with ISO environmental labels. Beyond the technical committee, PCR working groups are created in response to calls for development of PCR standards and are responsible for drafting the PCR and submitting it to the

17

See http://www.jemai.or.jp/english/ecoleaf/index.cfm See http://www.jemai.or.jp/english/about/greeting.cfm 19 See http://www.jemai.or.jp/english/ecoleaf/pdf/EcoleafGuideline_ver.1.pdf 18

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

PCR committee. The groups is comprised of company representatives who have applied to participate in response to an announcement by the Ecoleaf program office. Ecoleaf has a unique process for internal verification of data collection and processing for producers that create EPDs, allowing the producers to self-publish EPDs that meet the Ecoleaf requirements and are approved by JEMAI operation; b) the objectivity of quantitative data is ensured by qualified verifiers appointed by JEMAI. To self-publish an EPD, a company must have an internal verifier who can verify the data collection and EPD preparation who is qualified according to the same standards set for external verifiers by JEMAI. The Ecoleaf program provides an LCI database to participants which basic data such as conversion factors that allow producers to convert inventory data into environmental impacts. The information provided allows for greater consistency among EPDs. In addition to a label appearing on a product with the program logo, the publication of EPDs in the Japanese systems consists of three documents published separately, each of which require provide information targeting to different audiences. A Product Environmental Aspects Declaration summarizes for the consumer and general public the environmental performance in a page with a standardized and simplified presentation style. For business to business communication, more comprehensive presentation of the LCA results and the inventory data is presented in the Product Environmental Information Data Sheets and Product Data Sheets, respectively. Environmental Declaration of Products (Korea)20 Established: 1994 EPDs published: 22 PCRs published: 28 Environmental Declaration of Products (Korea) The Korean Ministry of the Environment (MOE) created an EPD program and acts as its overall coordinator. The agency created the Korean Eco-Products Institute (KORECO) to administer the process of creating PCRs and approving EPDs. When producers submit PCRs to KORECO, independent verifiers, trained and registered by Korea Environmental Preservation Association, are appointed to audit the EPD. Approved EPDs are published by the KORECO. Published EPDs from this program differ other programs in that quantitative environmental information, not just the program logo, appears on the product itself.21 These include resource depletion, global warming potential, ozone depletion potential, acidification potential, eutrophication potential, and ozone creation potential.

20

See http://www.edp.or.kr/eng_index.asp Bolon, K. and K. Fujihira. 2006. Guidelines for the Creation of a Program for Type III Environmental Declarations in the United States. Natural Resources and Environment. Ann Arbor, University of Michigan. M.S.: 180. 21

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

As the in the International EPD and Ecoleaf programs, the program is open to the development of PCRs for all products. Like the Ecoleaf program, the Korean program operator works to make PCRs international confirms to assure that they cannot be construed as non-tariff barriers to trade. Other developing programs Other general EPD programs exist in Norway and China, and a program is being established in Denmark.22 In China, the government run Environmental Certification Center of China administers the Type III labeling systems By 2003, 41 enterprises in China had registered through this system.23 Germany and Canada currently have EPD programs geared toward specific industries. Summary of the EPD Programs Most of the existing EPD programs have been developing over the past ten years. All programs offer industry-initiated PCR development and producer-based publication of EPDs. The Japanese system, with its method of internal verification, is the only that gives producers the power to publish EPD themselves if they are pre-certified. The International EPD program is the program with the most international participation, and the one with the most open process of PCR development. Their current initiative to develop tiered common product category (CPC) based PCRs further could be a powerful step in the harmonization of PCRs among similar products for broader comparison. All reviewed programs were originated through legislation or directly through a government agency. The degree of private control now varies, but all programs involve, at some level of administration, collaboration between the operator, industry, certification and outside experts. The private involvement in these systems ensures that private expertise is involved not just in the LCA, but also in the development of the PCRs. The public sponsorship or involvement lends credibility to the systems and provides support for LCA development in terms of providing common LCA inventory data that can be used by participating producers. The Ecoleaf program in Japan is the only program that has created a common database that can be used to make EPDs comparable. The units and conversion factors are based on Japanese conditions. The provision of a common database was one element recommended in a study of a potential US EPD program.24 All programs cite the goal of harmonization of EPDs to enable EPDs from one program to be recognized by another. Some of the programs have mutual recognition agreements that allow EPDs and PCRs from one program to be accepted by another. This international 22

See http://www.environdec.com/pageId.asp?id=123 Qing, Xia. China’s Environmental Labeling Program. June 2003. 24 Bolon, K. and K. Fujihira. 2006. Guidelines for the Creation of a Program for Type III Environmental Declarations in the United States. Natural Resources and Environment. Ann Arbor, University of Michigan. M.S.: 180. 23

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

harmonization is important so that efforts to develop PCRs and publish EPDs are not duplicated. While EPDs are the most recently internationally standardized label, and because of this one would expect the number of EPDs to be less than other programs, still the growth rate of EPDs does not appear to have increased as might be expected by a highly successful labeling scheme.25 As mentioned in the conclusion of the first section, this could be in part be due to complex presentation of the EPD which is difficult for buyers and consumers to interpret, and in part because of the potential expense of preparing and obtaining an EPD. Both of these factors can potentially be improved with further improvements in new and existing EPD programs that would make the EPD process less time and resource intensive, more internationally legitimate, and more user-friendly for buyers and consumers.

25

The total number of products with current certification through some of the popular Type I certification programs in Europe (German Blue Angel (10,860) EU Ecolabel (4,615), Nordic Swan (3,859) as reported at ecolabelling.org) dwarfs the total number of EPDs globally, which as the total number of EPDs registered in Sweden, Japan, Korea and China reviewed here, is less than 350.

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

COSTA RICAN INSTITUTIONAL CONTEXT As mentioned in the first section, a number of environmental labels, representing Type I, II, and single issue product labels as well as company labels are currently present in Costa Rica. Most of these labels were founded and are currently administered without government involvement. These includes labels for agricultural products like Fairtrade and Rainforest Alliance. An objective of this study is to explore the potential of developing an EPD system in the Costa Rican context. Based on the EPD programs reviewed in the previous section, initiation and support by government entities was common to all existing general EPD systems. A government-created administrative body would likely be integral to an EPD system in Costa Rica. Also integral to the programs are interested producers, third party experts for help in development of these standards, certification bodies, and supporting agencies or other institutions that could provide common data for the LCA, assist in establishment of standards and regulations, and work toward international consistency. Much of the institutional context that would be necessary for an EPD program in Costa Rica was created through the Sistema Nacional de Calidad (National Quality System). The following section reviews the legal basis and entities created by this system that would be relevant to a future EPD system. Sistema Nacional de Calidad The Sistema Nacional de Calidad was created though the Law Nº 8279: in 2002, primarily as a result of Costa Rica’s signing of the Technical Barriers to Trade in the WTO.26 The purpose of the system is to boost the implementation of good production practices across all industries, public and private, and to assist in assuring that products meet existing international regulations and technical guidelines. Through this law, various institutions were created which could further serve the institutional need for a Costa Rican EPD system. In particular, this law created a national Standardization Entity, to which it renamed INTECO, first recognized as the national standardization entity in 1995, as the official standardization entity of Costa Rica.27 INTECO is a non-profit private association whose purpose is to adopt international standards, oversee international certification processes, and to help capacitate public and private industry in the implementation of these standards that contribute to the general improvement of the quality of production of goods and services. INTECO is affiliated with ISO and various other international standardization organizations.

26

Gonzalez Vasquez, J. M. 2005. The Costa Rican National Quality System: Responding to WTO Requirements. ITC Executive Forum. 27 Asamblea Legislativa de la República de Costa Rica. 2002. Ley Nº 8279: Sistema Nacional para la Calidad, La Gaceta, May 21.

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

Another significant entity designated in the Sistema Nacional de Calidad was the national accredidation entity, the Entidad Costarricense de Accredidacion (ECA). This entity was vested with the authority to accredit certification entities, as well as other inspection and control entities. As a result of these institutions, private certification companies based in Costa Rica are able to become accredited as certification bodies for international standards. An alternative program: The Programa Nacional de Agricultura Organica28 The national organic program (PNAO) presents a parallel but distinct model of another similar institutional context created explicitly to manage the certification of organic agriculture in Costa Rica. This program was created by a decree of the Ministry of Agriculture, Decree No. 2997129, as opposed to by the national assembly. The PNAO defines its own accreditation entity, and works with universities, ministries of the government, producer associations, and interest groups to promote and expand the organic agriculture program. Although there is not an ISO standard for organic production, there is a recognition of the need for international acceptance of the certification. The PNAO has developed mutual recognition agreements to this end with Switzerland. LCA – Technical and Data Support Another requisite to an EPD program is experience in LCA. While it may be possible that this experience can come from abroad, it is notable that experience exists within Costa Rica. The practice of LCA has preceded the development of EPDs in Costa Rica and because of this there are professionals and academics with LCA experience within the country. The Association of Life Cycle Assessment of Latin American (ALCALA) was founded and is currently based in San Jose. ALCALA’s objective is to increase LCA awareness and capacity in Latin American, and does so in part through collaboration with LCA associations in other parts of the world.30 Academic and research institutions are also involved in LCA work in Costa Rica, particularly in the agricultural sector, including CATIE and the Center for Political Economy (CINPE) at the Universidad Nacional. The National Center of Clean Production (CNP+L) has a life cyclerelated mission of helping small and medium-sized enterprises improve eco-efficiency and prevent pollution.31 Another optional, but potentially critical component to support an EPD program is an Life Cycle Inventory Database.32 The Japanese EPD program is supported by a national LCI database, and other large scale LCI databases exist in Europe, United States, Brazil, China, 28

See http://www.infoagro.go.cr/organico/ Ministro de Agricultura y Ganadería. 2001. Decreto Nº 29971 – MAG: Crea Programa Nacional de Agricultura Orgánica. Decreto Nº 29971 – MAG: Crea Programa Nacional de Agricultura Orgánica, La Gaceta 223, November 20. 30 See http://jp1.estis.net/includes/file.asp?site=alcala&file=DAD1A79A-E5EA-43B9-97B3-84F6CFDFC6D9 31 See http://www.cicr.com//index.php?option=com_content&task=view&id=27&Itemid=38 32 A Life Cycle Inventory Database (LCI DB) consists of a set of agricultural and industrial processes that provide inputs to other sectors in the economy. 29

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

Thailand, Malaysia and are expanding elsewhere.33,34. An effort is now underway as part of the UNEP-SETAC life cycle initiative to create an initial national LCI database for the energy sector, which could be further expanded upon to provide the secondary data needed to produce accurate EPDs.

33

Norris, G. 2009. International Views of LCI Data. US LCI Database Stakeholders Meeting, Washington, DC, American Center for Life Cycle Assessment. 34 European Platform on LCA. 2009. "International Cooperation." from http://lct.jrc.ec.europa.eu/eplca/cooperation/international-cooperation.

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

FRESH PINEAPPLE: AN INVESTIGATION INTO A FIRST PRODUCT CATEGORY EPDs are an environmental label appropriate for all goods and services. However, rules for creating an EPD for each category of good or service may be defined independently according to ISO 14025, in the process of defining the product category rules (PCR). Each PCR will require participation from a variety of parties with specific interest in that product category group, from producers to consumers and the interested public; therefore it is necessary to explore and identify product categories where they a potential interest and demand for an EPD may exist. Why pineapple? Using EPDs for export products in Costa Rica could be a tool that helps environmentallyconscience markets in Europe and North America select those products that have the best environmental performance, thus allowing more sustainable production operations to win market share among both Costa Rican and global producers. The combination of its growing importance as an export and emerging concerns about associated environmental impacts make pineapple a prime candidate in Costa Rica for an EPD. Driven by the export market and the entry of major world suppliers into Costa Rica, pineapple production has expanded more rapidly than production of any other agricultural commodity in Costa Rica the last decade.35 Fresh pineapple export has overtaken coffee to become Costa Rica’s second largest agriculture export (to bananas) in terms of international exchange.36 This production has resulted in a rapid expansion of pineapple plantations in the Limon, Alajuela, Heredia, and Puntarenas provinces. There are a number of environmental and health-related concerns surrounding this recent expansion and the modern production process. Public concerns include soil erosion, pesticide contamination of water supplies and natural areas, lowering of regional water tables, worker exposure to agrochemicals, and impacts of organic wastes, among others.37 Recent responses to mismanagement of chemicals used pineapple production have included a moratorium on expansion of pineapple in the county of Siquirres.38 While such policy responses may be rare, they reflect the increasing public distrust and antagonism toward the industry, and could result in diminishing producer incentive to cooperate with public inquiries into production practices, further compounding antagonism and eventually threatening the future of the industry and those that depend upon it. Alternatively, the use of EPDs could provide a mechanism that provides mutual benefit to both the public and producers, by providing rewards to producers with better environmental performance, and at the same time increasing the transparency of pineapple production and perhaps increasing public trust in producers who participate.

35

Estado de la Nación XI 2005. La Nación, October 19, 2008. 37 Estado de la Nación XI 2005. 38 Tico Times, March 6, 2008. “Pineapple Farms face moratorium”. 36

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

Pineapple EPD workshop On July 23, 2009, an evenly-represented group including persons from the pineapple sector, government agencies that provide assistance to the sector, certification agents, LCA practitioners, and the director of the National Institute of Technical Standards (INTECO), attended a half-day workshop to learn and discuss the potential of developing an Environmental Product Declaration (EPD) system in Costa Rica and the process for making a set of rules for creating an EPD for pineapple.39 Workshop participants were given an introduction to EPDs and explained the basic steps necessary for creating an EPD for pineapple. Participants discussed aspects of the PCR for pineapple including steps from the life cycle to include and the unit of comparison to use. In the second part of the workshop, half of the participants continued the discussion of a pineapple PCR, and half discussed how an EPD program might be structured in Costa Rica at a national level. Outcomes Some general consensus conclusions resulted from the workshop. The following points synthesize responses from a questionnaire: • The vast majority responded that an EPD would be valuable for pineapple in the immediate future, given appropriate conditions, such as a demand in the market for EPDs, an adequate structure to assure they are accurate and verifiable, and that they are understood by producers as well as consumers. While most found value in EPDs for producers, consumers, and the general public, some participants mentioned that it has more value for the final consumer than producer or public. • All those who perceived the value of an EPD were interested in being involved in furthering the process. • An EPD program should be open to all products and not just pineapple. The Director of INTECO mentioned their support would be conditional on the openness of EPDs to all sectors. • Further progress towards development of PCRs needs to involve more representation from interested parties including agencies of the government, industry, and NGOs. • For a pineapple EPD, the LCA indicators used might include a measure of soil impacts, global warming impact, pesticide toxicity, energy use or efficiency, solid waste impacts, and water use. The final list should included both local and global impacts40 be based on data availability, measurability, and their value for producers and consumers. • Regarding the structure of an EPD system in Costa Rica, the benefits of developing a system in Costa Rica would include the ability to determine the terms of evaluation (rules for the PCRs). There was consensus that the control of the system should not reside 39

Workshop participants are listed in Appendix I. Pictures and a summary of workshop activities are available on the project website, http://www.epdcostarica.info 40 For example, soil erosion effects the local area but emissions of greenhouse gases have an effect on a global scale.

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

•

within one institution. The roles in the process should be well-defined. A number of agencies mentioned that could be involved included product-specific trade associations such as CANAPEP for pineapple and general trade associations such as CADEXCO, AMCHAM, CACIA, and CNAA. INTECO was named as the potential facilitator for an EPD system. Potential challenges to the development of a system in Costa Rica include the time to develop the system, the cost of operating the system, and the international credibility of the system.

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

SYNTHESIS: RECOMMENDATIONS ON EPDS IN COSTA RICA General recommendations An EPD program should be established in Costa Rica given the satisfaction of the following conditions: 1. A minimum of one sector where potential EPDs could be utilized needs to be identified, and stakeholders from that sector must agree to participate in the initial creation of a PCR for that sector before an EPD program is established. 2. The EPD program should be established by a national government entity. 3. The EPD program should be a general program open to all product sectors, and as internationally-compatible with other EPD programs as possible. 4. A public LCI database for Costa Rica should be created and required for use in EPD preparation. Efforts to compile LCA data should be done in collaboration with international partners, and draw from the experience of other countries in LCI database development. 5. All PCRs should be made as simple and consistent across product categories as possible while addressing the most significant environmental aspects and scientific credibility. The format for EPDs should be condensed and reader-friendly. 6. Appropriate mechanisms for including multi-stakeholder input in PCR development should be clearly defined and supported, although proposals to create a PCR could be made by one producer. 7. Technical support should be provided for participation of all industry, in the form of education and training in EPD publication, with a focus on those industries where PCRs exist. 8. Public financial support should be available to small and medium-sized enterprises to offset LCA and EPD registration costs, so that EPDs are not limited to the largest enterprises. 9. Appropriate ministries with connections to the global market (e.g. PROCOMER) should market and publicize the program to reach buyers abroad. Identifying a product category where an EPD is in demand Any EPD program should exist to support the publication of EPDs only if EPDs are appropriate for a product category. The appropriateness of an EPD in a sector are dependent upon: (1) a stated interest by buyers in that sector for preferential treatment for those products with EPDs, and the willingness of those buyers to collaborate with the EPD program by providing end-of-life life cycle information for the products; (2) the availability of life cycle data on the inputs to production necessary for products from that sector; (3) the interest of multiple producers within a product category in obtaining EPDs. Establishment and structure of the EPD program An EPD program in Costa Rica should be established by an act of the national assembly, or by decree of ministry of government, such as the Ministry of Industry and Commerce

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

(MEIC)41 or the Ministry of Energy and the Environment (MINEAT)42, that has a sufficient governance scope that extends to all product sectors. The structure of existing EPD programs, consisting of a program operator working in conjunction with a standards institute, independent verifiers and an accreditation agency, should be mimicked in Costa Rica. The program operator should consist of a secretariat, steering committee, and technical committee(s), in the style of the International EPD system. The program operator should be a government-sponsored but independently operated agency, like that of the International EPD system. The existing standardization (INTECO) and accreditation (ENA) agencies created through the Sistema Nacional de Calidad should be considered first as potential institutes to serve their respective roles in a new EPD program. National LCI Database A national database will be key to assuring accurate life cycle inventory data on common inputs to production, which will increase the accuracy of measures of life cycle impacts and the comparability of EPDs. Costa Rica could benefit from existing national and independent LCI databases, both as sources of data and as models for the development of databases. The US LCI database and ELCD project should be examined as potential sources and models.43 A national database could be managed by a single research institution, but should involved the collaboration with national and international institutions with LCA expertise and access to data sources. Alternatives to a national EPD system 1. The first alternative to a national EPD system would be to lead an effort to create the PCR(s) for one or more product category in an existing EPD program in another country. Pineapple would be a good candidate for such a product because Costa Rica commands the largest share of this commodity in the world market. The International EPD system in Sweden would be the most logical EPD program to participate in, since it is the only existing system with the participation of international producers, and because the European market is a large market for Costa Rican exports. The advantages of this alternative include a more rapid appearance of EPDs in Costa Rica because they do not have to wait on the development of a new program, and existing credibility of the EPDs in the European market. Limitations of this alternative are related to the lack of control and process support for registering an EPD that would come with a national system. These limitations might include the likelihood of a more limited involvement of national actors in developing the PCRs, increased expense for certification without national 41

This would mimic the role of the Japanese Ministry of the Economy, Industry and Trade in establishing the Ecoleaf program. 42 This would reflect the role of the Swedish Ministry of the Environment in establishing the International EPD program. 43 Information on the US LCI database and ELCD can be found at http://www.nrel.gov/lci/about.html and http://lca.jrc.ec.europa.eu/lcainfohub/datasetArea.vm, respectively.

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

support, decreased availability of accredited certifiers, the potential absence of a national Costa Rica LCI database for providing data to support producers. 2. A national alternative that could fulfill a similar function of improving the environmental performance of products could be the development of a national Type I “seal of approval” label, still based in life cycle impacts, to certify Costa Rican products for domestic and exterior consumption. The advantages would be a simpler, more recognizable label, for which purchasing decisions could be made based on the presence of the label on its own. Disadvantages of this alternative would include the disadvantages of Type I labels (see Table 3) including the lack of an LCA-based rule structure for evaluating products, the absence of the disclosure of data and impacts of products with the label. A potentially controversial requirement, this type of label would require setting environmentally-sensitive limits or management standards that would prevent some producers from qualifying for the certification. Additional considerations A broader policy context for EPDs In Europe, environmental labeling policies fall under broader efforts towards sustainable production and consumption. Central to the EU’s Sustainable Consumption and Production Action Plan of 2008, is a plan to improve the environmental performance of products 44. Strategies of doing this include product labeling and other means of improving the environmental performance of products over their life cycle. Efforts to this end in Europe include the creation of the European Life Cycle Database, the EcoDesign initiative, creation of a set of life-cycle based indicators to measure EU progress, and carbon footprinting.45 An overarching policy in Costa Rica could give an EPD program a place in a broader policy context and make the collaboration with related programs, such as the creation of the LCI database, more clear.

44

Commission of the European Communities. 2008. Communication on the Sustainable Consumption and Production and Sustainable Industrial Policy Action Plan. COM(2008) 397 final. 45 European Commission - Joint Research Centre - Institute for Environment and Sustainability. 2009. "Life Cycle Thinking." from http://lct.jrc.ec.europa.eu/.

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

CONCLUSIONS Environmental Product Declarations (EPDs) are a recent evolution in environmental labeling that provide quantitative environmental information on products over their life cycle. EPDs are neutral and can theoretically by applied to any product in any category, but their use depends upon the existence of an EPD program and its associated institutions. Because they are quantitative, based on strict, common rules, and subject to independent reviews, EPDs may be used to overcome the problem of “greenwashing”.46 However because of their novelty and thus far limited use in comparison with other types of labels, EPDs are potential but yet unproven drivers of more sustainable consumption and production. Costa Rica does not yet have an EPD program in place, nor have Costa Rican products been registered in programs based elsewhere abroad, but sufficient models exist to base a Costa Rican EPD program upon. Using the support of existing institutions, and in collaboration with international partners, we recommend that Costa Rica develop an EPD system and LCI database to support this system. Although the development of such a program would require significant logistic and financial investment, it could provide multiple benefits to the country, including: providing participating products with a competitive advantages in international markets; satisfying local and international demand for environmental data from the supply chain; providing producers with another tool to measure their environmental performance; and generally improving the country’s image in the area of sustainable production. In order for an EPD program to be successful, a demand for EPDs needs to exists in markets for products, and the industry has to be willing to participate in writing rules for their product categories and in obtaining EPDs. Pineapple was the first product identified as a potential candidate in a new system, but the market demand and buyer participation in the EPD process needs to be identified and encouraged. Aside from involving producers and consumers, EPDs for Costa Rican products that satisfy the public interest need to involve public representatives in the rule-making process and include in them information on local environmental impacts.

46

TerraChoice Environmental Marketing Inc. 2007. "The “Six Sins of Greenwashing”: A Study of Environmental Claims in North American Consumer Markets." from http://www.terrachoice.com/files/6_sins.pdf.

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

ACKNOWLEDGEMENTS We would like to acknowledge the support of the University of Costa Rica Environmental Law Consultancy for providing workspace throughout the project duration and the Organization of Tropical Studies, who provided the meeting space in San Jose for the pineapple EPD workshop. The authors would also like thank the workshop participants for their contribution. APPENDIX Pineapple EPD workshop participants Name Ana Quiròs Yamileth Astorga Felicia Echeverría Hermoso Eliza Pasos Muñoz Carlos Rodriguez Lopez Alfonso Murillo Randall Arias Alexander Bolaños N. Anonymous Faelen Kolln Alex Rodriguez Blanco Sergio Musmanni Marjorie Hartley B. Jesus Evelio Ruano Leonardo Guerra Anna Norden Ana Elizondo Porras Delanie Kellon Adalberto Rodríguez Franklin Paniagua

Institution Eco Global S.A./ ALCALA UCR Eco-LOGICA Eco-LOGICA INTECO PROCOMER PROCOMER Hacienda Ojo de Agua, S.A. MEIC Compania Agricola San Alejandro del Norte Compania Agricola San Alejandro del Norte German Development Agency CINPE - UNA CINPE - UNA CATIE University of Gotenburg, Sweden Consejo Nacional de Produccion Michigan State University DLV Plant UFL

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Environmental Product Declarations: An introduction and recommendations for their use in Costa Rica

Questions from post-workshop evaluation (original in Spanish) 1. Based on what you’ve seen and discussed today, in your opinion, would an EPD for pineapple be valuable? Justify your answer. 2. If Costa Rica develops an EPD system, do you think you or your organization could be involved. In what way? 3. What do you consider to be the next step to continue with the development of an EPD for pineapple in Costa Rica?

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