A pathway to greener products

A pathway to greener products Recommendations from Green Alliance’s Designing Out Waste consortium Coordinated by Hannah Hislop Published under Green Alliance’s Designing Out Waste theme, which focuses on influencing important decisions on waste and resource policy as part of a long-term mission to radically change our material world.

ISBN 978-1-905869-36-7 Green Alliance Green Alliance is an influential, independent organisation working to bring environmental priorities into the political mainstream.

We work collaboratively with the three main parties, government, the third sector, business and others to ensure that political leaders deliver ambitious solutions to global environmental issues.

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The Designing Out Waste consortium is convened by Green Alliance and is made up of:

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A pathway to greener products

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Introduction As businesses, we are increasingly aware that consumers at all levels of the market want and expect us to provide them with better products with lower environmental impacts. Consumers don’t want to spend time researching their purchases or comparing labels. They don’t want simplistic green spin, but neither do they want a barrage of incomprehensible information.

They want environmental responsibility built into all products.

Tackling products’ hidden shadow Products impact the environment in many different ways. Some impacts are obvious – for example in products that consume a lot of energy in-use; theoretically giving consumers an incentive to choose the best performing product or to modify their use behaviour to reduce the impact. But all products have a hidden shadow comprising a range of lifecycle impacts, some far removed from the eventual consumer or user, such as the quantity of water used in production and manufacture, or different material recovery methods. This makes it hard to see how consumers can be expected to weigh up all these differing impacts and to steer their purchasing accordingly. In these instances, businesses will need incentives, in the form of both commercial and policy drivers, to reconfigure their products along greener lines.

Here, we show that businesses can do much to improve the environmental impact of their products, but that commercial and policy drivers must be correctly aligned to incentivise the right products. Whilst many of these drivers must be developed and agreed at EU or global level, we believe that the UK government can play a catalytic role in this process. We demonstrate specific ways in which this role can be played.

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Executive summary As a group of leading companies, the Designing Out Waste consortium is calling on government to help all businesses to improve the environmental impact of the products they offer.

The consortium believes that business can play an important and proactive role, but that the ability to play this role depends on strong leadership and direction from government to encourage cooperation and coordination across product supply and waste management chains to deliver a common approach and provide the right incentives.

Our recommendations for a progressive government framework for designing out waste are:

1. Evaluating product impacts: meaningful and practical measurement, comparison and judgements In discussion with businesses, and working with the relevant EU and global institutions, the government should take a lead in facilitating the development of a practical, low cost and widely adopted way of holistically evaluating product impacts, and identifying where action should be taken.

This would entail: • With sufficient lead-in time, and taking into account the implications for multinational companies, facilitating the development of standardised and usable methodologies for data collection and evaluation of impacts, so that

businesses know what a good sustainability assessment should cover and how it should be conducted. Such methodologies need not always be full lifecycle analyses (LCA) or unnecessarily complex but should adopt a lifecycle thinking approach. The data gathered should go beyond a focus on carbon to encompass a range of impacts such as water and material use. • Facilitating the routine sharing of this data to minimise the costs of identifying the most important environmental impacts of products, but in a way that retains legitimate commercial confidences. Companies would maintain records of key environmental metrics relating to the raw materials, components or products they supply and the government would encourage the development of standards to aid the sharing of this information up and down the supply chain. • Developing a communications plan for making both industry and consumers aware of significant product impacts in a way which is easily understood and which allows them to take appropriate action.

2. Commercial and industrial waste: tackling the product shadow Government should introduce new measures to tackle the generation of commercial and industrial waste. With appropriate lead times, these could include ambitious sectoral targets and requirements for companies to measure and routinely report material input and output.

A pathway to greener products

3. Towards improved product standards: sustainable choices, or every product the sustainable choice?

Working with businesses and the relevant EU institutions, the government should facilitate the development of a broad set of lifecycle based sustainability performance standards for products.

Companies and trade associations should be encouraged to set their own baselines for products (using the agreed methodologies described above) and to use these to produce improvement strategies to meet the standards.

An expanded Ecodesign Directive could be one way to ensure that these standards apply across all member states. The UK government should take a proactive stance in EU discussions about how best to do this.

4. Upstream incentives to design out waste Government should explore the potential for upstream incentives to encourage businesses, both in the UK and abroad, to design out waste and design in recovery.

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1. The Designing Out Waste consortium The ten leading businesses that make up Green Alliance’s Designing Out Waste consortium recognise the environmental and economic imperative of improving the environmental performance of their products and services, across all stages of their lifecycles.

Extraction of raw materials

Manufacturing

Over the past two years these businesses have helped Green Alliance to research, analyse and debate some of the complex technical, economic and political challenges that must be overcome if we are to be successful in designing out waste.

Dr Tony Taylor, Sustainability & Packaging Technical Manager, Unilever UK “Our aim is to double the size of our business, but to do so in a way that reduces our total environmental impact. This includes not just our own business operations but the impacts associated with the total lifecycle of our products. It is an ambitious goal and one which will require new ways of doing business and working closely with others. Working with a consortium, such as this one created by Green Alliance, really helps us explore possibilities and opportunities further.”

Each consortium partner has brought knowledge and experience from a particular part of the supply chain, from global manufacturing brands and retailers to waste management and producer responsibility organisations.

We all recognise that the nature of the challenge we face means that acting in isolation can be difficult, expensive and have limited impact.

Each player in a supply chain can seek to optimise their own ‘efficiency’, but tackling the negative consequences of our system of production and consumption as a whole requires a joined-up and effective set of policy drivers. As a result, the ‘whole supply chain’ nature of this partnership has been critical to developing a set of robust recommendations for future policy drivers.

Packaging Jane Bickerstaffe, Director, INCPEN “INCPEN is pleased to work with Green Alliance and other stakeholders on Designing Out Waste. We hope that this work will deliver policies that will help companies continue to improve their environmental performance and will support our vision of a sustainable packaging and product supply chain which will enable goods to be produced, distributed, used and recovered with minimum environmental impact at lowest social and economic cost.”

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Post and product delivery

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Product use

Matthew Neilson, Head of Environmental Solutions, Royal Mail “Designing Out Waste has been an important step towards mapping the legislative drivers and future actions required to create products and services that are acceptable to a society that strives for a sustainable world.”

Retail Julian Walker-Palin, Head of Corporate Policy for Sustainability & Ethics, Asda “Whilst we believe that business acting alone can make significant moves towards designing out waste in products, it will also be essential to have in place the right public policy drivers to create a framework in which these activities can flourish. We hope that this report will help government recognise the challenges but also the opportunities in this area.”

Waste management Dr Stephen Wise, Technical Director, Shanks “Green Alliance’s project looking at minimising waste within the supply chain is important as it supports wider objectives that stretch beyond national boundaries and impact upon all of us. For Shanks, this project fits with our strategy of creating value from resources discarded by others.”

Retail Andrew Jenkins, Sustainable Development Manager – Products, Boots UK “Understanding and acting on the real environmental impacts of products requires synergy between policy makers and organisations across the supply chain.

At Boots we adopt this holistic approach within our supply change. We are pleased to support the work of Green Alliance to develop policy that will reduce the environmental impact of products throughout their lifecycle.”

Recycling and compliance Adrian Hawkes, Director of Policy, Valpak “We have always believed that businesses thrive on competition and market efficiencies and that our role is to harness these drivers to help achieve environmental improvements efficiently. We very much hope that this study will help the incoming administration to develop its resource efficiency programme in a way which businesses can fully embrace.”

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2. Background to the recommendations Greener products report In 2009 Green Alliance, on behalf of the Designing Out Waste consortium, mapped all the major environmental policy drivers bearing on products sold in the UK and their production processes, and looked at the effectiveness of these drivers. The resulting report, Greener products,1 breaks down the drivers into four main categories: a. Requirements for organisations to reduce carbon in their operations (eg the EU Emissions Trading Scheme, Climate Change Agreements and CRC Energy Efficiency Scheme); b. Voluntary initiatives to measure and report carbon and other impacts, in ways that seem likely to lead to increased scrutiny of supply chains (the use of carbon footprint and product roadmap initiatives amongst others); c. Instruments designed to increase recycling and reuse (these include fiscal instruments such as the landfill tax, mandatory household waste recycling and composting targets, recycling requirements in EU producer responsibility directives and ‘voluntary’ initiatives such as the Courtauld Commitment); d. Ecodesign standards (currently focussing on energy consumption in the in-use phase but with a future focus on energy related products, which opens the door to ecodesign standards for broader environmental parameters such as resource use, recyclability and water use). Currently public procurement standards provide an incentive for

products and services to meet specified levels of environmental performance, and this experience could be built on.

For each category above, we expanded on the policy drivers in question and assessed how well they work, or are likely to work, in practice, taking into account current and future politics. The primary motivation for this assessment was to determine whether the current policy drivers are coherent, and whether gaps or conflicts exist.

Our conclusions were that product policy is currently developing in a piecemeal fashion, which means that although drivers are relatively complementary at the moment, significant conflicts and gaps do exist. These include: • The lack of any practical means of measuring and setting mandatory standards for a product’s environmental performance other than energy consumption; • The lack of effective drivers bearing on the commercial and industrial waste that makes up much of a product’s ‘shadow’, both in the UK and abroad; • The tension between the mandatory reporting requirements of the carbon reduction commitment (CRC), which targets operational energy use, and voluntary approaches such as carbon footprinting and product roadmaps, which take a more holistic approach to the product supply chain, meaning that mandatory controls on one part of the supply chain could miss out a much bigger impact elsewhere;

A pathway to greener products

• The uncertainty about whether government guidance on measuring and reporting carbon emissions will become mandatory in the next couple of years; • The fact that packaging waste is subject to recycling targets separately from local authority recycling targets. While this approach has met the Packaging Directive’s targets, complex funding arrangements have arisen; • The fact that most products do not have any mandatory recycling targets themselves (other than vehicles, electrical equipment and batteries); • The current lack of prospects for fiscal instruments on products themselves, such as VAT reductions for best-in-class products or taxes on particularly damaging products.

The need to go beyond carbon Through our discussions within the consortium and with other important stakeholders, we have also been exploring the extent to which carbon is a good proxy for environmental impact, and how trade-offs can be made. We also considered how measurement and communication of impacts could be optimised or standardised to avoid consumer and business confusion. A number of the recommendations in this report address these points.

The governance of resource efficiency In this report we make some specific recommendations on the issues of data, commercial and industrial waste, product standards and resource

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pricing. However, we also feel that there are significant institutional and governance barriers that will need to be overcome.

The current institutional set up is not well placed to tackle embedded carbon, let alone to factor in other significant environmental impacts of products and the way they are made. This is mainly because of the overwhelming focus of our politics and policy on energy generation, and the energy we consume in our homes and cars. While our domestic emissions have dropped 12 per cent on 1990 levels,2 recent research suggests that the UK’s consumption emissions (those associated with the total global consumption of products and services by consumers, business and the public sector) are likely to grow by 40 per cent by 2050.

Figures from the Stockholm Environment Institute suggest that in the UK, around 75 per cent of a household’s carbon impact is a result of the products and services we buy and use.3 But the Department of Energy and Climate Change (DECC), the main government department tasked with leading the UK’s response to climate change, concentrates its activities almost exclusively on the other 25 per cent: the direct emissions from the energy we use in our homes and cars. Emissions embedded in products throughout their lifecycle and services are left to Defra and particularly to the Sustainable Products and Consumers division, which is significantly under-resourced relative to the scale of the challenge, particularly as its remit is broader than carbon. Furthermore, the tools at its disposal are limited: to date the approach has been

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to commission research and to broker a number of product roadmaps, essentially whole supply chain voluntary agreements with different product sectors such as clothing, milk and passenger vehicles. Where mandatory standards are being applied as a result of processes such as the EU’s Ecodesign of Energy Using Products Directive, they tend to default to in-use energy consumption, even when products such as computers have other significant impacts such as the use of toxic chemicals.

The picture is equally unclear downstream, where products and materials become waste.

Commentators have warned of a ‘dash for trash’, whereby Defra implements policies to increase waste prevention and recycling while DECC seeks the same resources to use as feedstocks in energyfrom-waste technologies to meet renewable energy targets.

It is difficult for businesses to navigate this degree of complexity and fragmentation, leaving them unsure as to which drivers will dominate in future and, hence, where in their supply chains they should focus and in what ways. It is for this reason that here we are arguing the case for a more ambitious and coordinated approach to resource efficiency from government.

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3. The Designing Out Waste consortium recommendations The shared consensus set out below is a powerful message. It provides a mandate from business to politicians and policy makers at both UK and EU level tasked with developing policy to enable us to achieve national, EU and international aspirations to tackle climate change and resource degradation.

These recommendations build on the mapping work undertaken in Greener products by tackling some of the conflicts and gaps in policy outlined on page six.

They encompass some of the main conclusions of the two-year Designing Out Waste programme.

i. Evaluating product impacts: meaningful and practical measurement, comparison and judgements Recommendations In discussion with businesses, and working with the relevant EU and global institutions, the government should take a lead in facilitating the development of a practical, low cost and widely adopted way of holistically evaluating product impacts, and identifying the most significant for further action.

This would entail: • With sufficient lead-in time, and taking into account the implications for multinational companies, facilitating the development of standardised and usable methodologies for data collection and evaluation of impacts, so that businesses know what a good sustainability assessment should cover and how it should be conducted. Such methodologies need not always be

full lifecycle analyses (LCA) or unnecessarily complex but should adopt a lifecycle thinking approach. The data gathered should go beyond a focus on carbon to encompass a range of impacts such as water and material use. • Facilitating the routine sharing of this data to minimise the costs of identifying the most important environmental impacts of products, but in a way that retains legitimate commercial confidences. Companies would maintain records of key environmental metrics relating to the raw materials, components or products they supply and the government would encourage the development of standards to aid the sharing of this information up and down the supply chain. • Developing a communications plan for making both industry and consumers aware of significant product impacts in a way which is easily understood and which allows them to take appropriate action.

Rationale Successfully tackling the environmental impacts of products and services will be almost impossible without accurate and accessible data about the scale and nature of these impacts across supply chains.

Some leading companies are already taking steps to gather such data, either themselves or by requiring it from their suppliers. However, various organisations are currently developing their own metrics for specific elements such as packaging and supplier performance, and there is a danger of ending up with a number of differing sectoral approaches. Such data will have a tendency to be inconsistent and incomparable, and duplication of effort in multiple

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approaches adds unnecessarily to business costs.

Those that do not see an imperative to better understand the impacts of the products and services they sell can free ride on the system.

What data is needed? In the debate about how to measure the environmental impact of products, carbon has come to the fore because it has its own reduction targets and also has become a politically important way of further justifying recycling and the avoidance of landfill. In Greener products, we reported that there seems to be a consensus that carbon is a reasonable proxy for resource efficiency when considering the ways in which materials are processed and recycled, but it is not overall an adequate proxy for all environmental parameters of the product lifecycle. The biggest impacts that do not seem adequately captured by a carbon metric are: embedded water, the use of potentially scarce or insecure resources; the landscape and biodiversity impacts of resource extraction, and the production of goods and their eventual wastes.

Other groups have recently raised these concerns.

BEUC and ANEC, two European consumer organisations, released a joint position paper on product carbon footprinting which highlights a number of methodological shortcomings, arguing that “climate change and related indicators such as the carbon footprint should not be the only criterion to differentiate the environmental performance of products and services�.4 A recent INCPEN paper on carbon metrics for packaging makes a further point, arguing that such metrics ignore the beneficial effects of packaging to extend shelf life and preserve

quality, as well as omitting consumer-related impacts such as refrigeration and travel to shops.5 The Designing Out Waste consortium partners understand and share these concerns. It is important that judging the carbon footprint of a product is not a cul-de-sac but a stepping-stone to a more holistic assessment of environmental impact (this is particularly important for packaging where productpackage interactions are crucial).

This is why we are calling for government to work with businesses and with the relevant EU institutions to facilitate the development of a practical, low cost and widely adopted methodology to evaluate product impacts and identify the most significant.

This could take the form of a matrix which would build on the experience of carbon footprinting, particularly the development of PAS 2050 which has yielded crucial insights about how impacts are dispersed along supply chains, but ultimately needs to be expanded to embrace other considerations such as water and the wider implications of materials use. It would identify what type of data should be collected and shared, and how, ie which are the most appropriate metrics and units to use. Such a methodology would need to be affordable for companies, and capable of being used over a wide range of products in a reasonable time frame. It should not be unnecessarily complex or costly to implement if it is to be widely taken up. On the other hand, the estimates should be sufficiently accurate to enable distinctions to be made and relative values and priorities assessed. Its development at EU level would require close cooperation and collaboration

A pathway to greener products

with international standards organisations and other relevant initiatives such as the Consumer Goods Forum, as well as with sectoral organisations, who should also take a leadership role in enabling their members to take part and possibly acting as trusted repositories for data gathered. Ideally the methodology should be internationally recognised and accepted.

Such standardisation will facilitate the sharing of data, allowing companies who wish to use a particular data set from a supplier or industry body to input into their assessments, to be confident that it has been produced in a reliable way, and allow consumers to compare published product sustainability information and know that like is being compared with like. Where appropriate, agreed levels of aggregation and other mechanisms such as collective agreements could be set to preserve commercial confidentiality.

Once impacts have been assessed there is still a major task to get the messages over to consumers in a clear and consistent way. This needs to take account of the following: • most consumers do not know what carbon impact is; • they have very little time when making purchases to assess the environmental differences; • the messages have to compete with those on other key product differentiators such as brand image, quality, price, technical performance and nutrition.

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ii. Commercial and industrial waste: tackling the product shadow Recommendation Government should introduce new measures to tackle commercial and industrial waste. With appropriate lead times, these could include ambitious sectoral targets and requirements for companies to measure and routinely report material input and output.

Rationale The concept of a product’s ‘shadow’ turns the current political focus on household waste on its head. What is collected from household bins is usually a minor proportion of the waste associated with a product’s lifecycle. The use of water, energy and material resources at the production phase, and the wider environmental impacts of raw material extraction all make up the shadow that a product casts. The higher the environmental impacts associated with its production, the longer and darker the shadow.

But the importance of tackling this shadow has only recently been recognised, and not yet acted on with the degree of decisiveness needed. This is at least partly due to the fact that modern supply chains are complex and can cross numerous country borders.

Ultimately, supply chain waste will have to be addressed at least at EU level, if not globally, so that the waste associated with imported products is tackled. But we believe that understanding and tackling the UK’s ‘material’ product shadow, in the form of commercial and industrial waste, is an

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important first step that will help reveal the rest of the product shadow as well as reap significant environmental and economic rewards in its own right.

Currently only a limited set of measures bear on UK commercial and industrial waste. The landfill tax is making disposal increasingly expensive, but this is an indirect driver, and there is little evidence that the increased costs of final disposal has a significant impact on the product design and production phase.

Furthermore, there is little routine and ongoing measurement of commercial and industrial waste. An enlarged definition of municipal solid waste to encompass some commercial and industrial waste should help, as will a new survey of commercial and industrial waste arisings this year, but the latter should be made a regular and ongoing requirement rather than an occasional exercise. There are currently no recycling targets or producer responsibility measures beyond EU directives that bear on product end-of-life, although a recent consultation asked for views on higher targets for packaging which go beyond the Packaging Directive.

The Designing Out Waste consortium partners believe that much more emphasis is needed on understanding and tackling commercial and industrial waste in the UK. A range of possible measures should be explored, including regular reporting, mass balance requirements for companies to measure material input and output and voluntary or mandatory sectoral targets. Any targets set should be stretching, requiring a step change in successful business models, rather than being based on current projections of improvement, which is the case with

the construction and demolition waste recycling target. Courtauld Commitment II, whereby WRAP has ownership of a target to reduce supply chain product and packaging waste by five per cent (on 2009 data) by 2012, and is supported by retailers, brand owners and suppliers in meeting this target, is a model that could be extended to other sectors of the economy. An extension of the concept of Site Waste Management Plans, currently used in the construction and demolition sector, to all industry and manufacturing sectors, could be a first step towards a mass balance requirement to measure and report material input and output on all companies over a certain threshold.

iii. Towards improved product standards: sustainable choices, or every product the sustainable choice?

Recommendations Working with businesses and the relevant EU institutions, the government should facilitate the development of a broad set of lifecycle based sustainability performance standards for products.

Companies and trade associations should be encouraged to set their own baselines for products (using the agreed methodologies described above) and to use these to produce improvement strategies to meet the standards.

An expanded Ecodesign Directive could be one way to ensure that these standards apply across all member states. The UK government should take a proactive stance in EU discussions about how best to do this.

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Rationale Consumers claim that they want to purchase greener products, but such opportunities are currently limited. Some consumers may be prompted by labelling to go for the greener option but many more will not. Some will respond to specific issues raised by the media, but not all issues enter mainstream debate. There is little evidence to suggest that consumer choice is driving an underlying shift in all offerings towards more sustainable products.

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where better understanding of a product’s lifecycle impacts will provide strong justification for ensuring that it has an improved standard of performance. This will allow progress to be made in areas where consumer pressure is not enough to drive action.

Why is the current approach reaping such limited rewards? While information provision and choice is important, neither necessarily leads to improved consumer decision-making or changes in consumer behaviour. Consumers rarely seek, read or properly digest all the information available to them when making a purchasing decision. There are plenty of other factors that determine an individual’s behaviour as well, such as the tendency to be highly loss averse and to heavily discount future savings, as well as the huge impact of social influence.

Furthermore, for most products, there is no specific sustainability information. When such comprehensive information is available, both consumers and businesses need support to navigate complex issues and manage trade-offs.

Product standards will need to be developed at EU level to be effective, as is the case with the current Ecodesign of Energy-Using Products Directive, which sets minimum standards for a range of energy-using products, from large industrial heating equipment to consumer white goods. The Directive aims to take a lifecycle approach to total environmental impact but, in reality, the implementing measures focus overwhelmingly on energy efficiency standards for the in-use phase of the product lifecycle. For some significant energyusing products such as boilers this is understandable, however there is concern that, for many other products, issues such as toxicity and recyclability of materials are being sidelined while impacts such as embedded energy and water are virtually ignored. This means that while some products will receive a much needed boost in energy efficiency, the opportunity for a genuine paradigm shift in product conception, design and manufacturing is being missed.

On page nine, we advocated that government should facilitate the development of an effective way of evaluating product impacts, and identifying the most significant. In the case of some products, the identification of major impacts will in itself be sufficient to drive action and encourage continual improvement. However, there will be some instances

The current debate about the expansion of the Ecodesign Directive is an opportunity for EU product policy to take a genuinely lifecycle approach to products, and to ensure that product standards apply to all member states. The Designing Out Waste consortium partners believe that the government should lead the discussion at EU level about how to

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develop effective and dynamic standards through the expansion of this Directive. The UK could lead this initiative by trialling such standards through embedding them in public procurement practices.

We can envisage future standards covering (NB not all of these standards would apply to all products, and the list below is not exhaustive): • Durability: specifying minimum warranty periods, upgradeability, modular design so that components can be updated, replaced or repaired; • Recyclability: to ensure design for recovery and recycling, including eventually which combinations of materials lead to greatest recoverability, how to balance this with other benefits such as lightweighting, and how to ensure that there are energy savings from recycling; • Recycled content: specifying minimum proportion of recycled content, appropriate to the state of development of different technologies and markets; • Use of insecure materials/materials with an unacceptable environmental impact: specifying substitutions.

iv. Upstream incentives to design out waste Recommendation Government should explore the potential for upstream incentives to encourage businesses, both in the UK and abroad, to design out waste.

Rationale In the UK today, we only price wasted resources at one point, the point of disposal. Such measures can be effective in driving materials away from the most environmentally damaging forms of disposal, but do not work strongly enough to influence the design of products and hence their overall use of primary resources.

A number of other constituencies are starting to look at these options in more detail. The Green Fiscal Commission had cross-party support, and we expect the principle of looking to shift the burden of taxation from goods to bads to become part of forthcoming political debate, as indicated by the new coalition government’s commitment to increase the proportion of tax revenue from environmental taxes.

It is for this reason that we believe the government should look further up the product supply chain and explore the mix of fiscal and regulatory measures that could be deployed in combination with more downstream measures. These would have to be deployed at a level that would not introduce barriers to trade, so many may only be suitable for implementation at EU level. They would need to take account of the international basis of trade and not discriminate between local and international players. The possible interactions between these different routes, if adopting more than one, would also need to be fully understood.

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Endnotes Greener products: Mapping the environmental policy drivers on products and production processes, Green Alliance (September 2009). http://www.green-alliance.org. uk/uploadedFiles/Publications/reports/ Greener%20products%20final2.pdf 1

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As measured for the Kyoto Protocol.

In Defra’s interpretation of the Stockholm figures, these ‘indirect’ emissions are indirect emissions from energy use and services, appliances and other products, textiles, food and drink, and aviation & public transport. ‘Direct’ emissions are from fuel for private cars and fuel used in the home.

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Sizing up product carbon footprinting: ANEC, BEUC, ECOS, EEB Joint Position (December 2009). http://www.beuc.eu/BEUCNoFrame/Docs/1/ KKDGCDKCHKNPNNPJPGONILMKPDBG9DBGT19 DW3571KM/BEUC/docs/DLS/2009-00975-01-E. pdf 4

Carbon metrics: walking in LCA’s footprint? INCPEN discussion paper (November 2009).

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