Political Hotspot March 2023
After a postponement in November 2022, on 22 March 2023 the European Commision’s proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive) has been published. While we welcome the withdrawal of prevalence of the Product Environmental Footprint (PEF) in the text, we are still calling for caution when it comes to the mention of Life Cycle Assessment.
A text originally based on the PEF
It is crucial to keep in mind that the Green Claims proposal is led by the European Commision’s Directorate-General for Environment (DG ENV), the same DG that have been working for 10 years to develop the PEF methodology. Therefore, the text was written based on that methodology and aiming to make it the standard for labelling harmonization in the European Union. However, thanks to the efforts of various NGOs, trade associations and civil society which repeatedly raised concerns to the Commission, the references to the PEF have been greatly diminished in the proposal. If we welcome the improvements made by the Commission to the Green Claims proposal, the Directive still leaves space and advocates for the development of Life Cycle Analysis (LCA) methodologies such as the PEF.
Our concerns on the application of LCA methodologies for agricultural products, food and textiles
Life Cycle Assessment (LCA) methodologies, in general, are not adequate to assess the environmental performance of agri-food products as they are unable to correctly capture the complexity of the agri-food system and its external impacts. These types of methodologies are only accounting annual flows. Positive and negative externalities of agricultural systems do not appear in LCA calculations, making it impossible to assess them in a holistic way. All “stable” positive externalities such as the value of the presence of hedges, plots of limited size, diversified crop rotations, long-term practices, etc. do not appear in a LCA evaluation. This narrow perspective on functions of agricultural systems is disregarding many aspects of the methods of production and cannot accurately distinguish between them. It is particularly striking with the example of the PEF that gives misleading results, since the more extensive the agricultural practice is, the worse it scores. For instance, eggs from hens in cages score better than free range eggs, which in turn score better than organic eggs. When it comes to agri-food products PEF is predominantly an indicator of yields, favouring the most intensive methods of production while disregarding both a number of positive elements and the negative externalities of the food production process. You can find more information on the limitations of the PEF in our technical briefing.
The EU must promote methodologies that are aiming to support the transition towards more sustainable food systems
IFOAM Organics Europe supports the idea of protecting consumers from deceiving green claims on food but believes methodologies to assess the environmental value of food products should be properly discussed and aligned with the objectives of Farm to Fork and Biodiversity strategies. Environmental labelling schemes should be evaluated in regards of their capacity to promote the transition towards a more sustainable food systems based on an agroecological vision. Therefore, a special attention must be taken when regulating environmental labelling schemes and setting requirements for them.
What comes up and what do we do?
- The Directive will now be presented to the European Parliament and the Council. We will continue to advocate for adapted methodologies to be applied for agricultural, food and textile products towards these two institutions.
To ensure this, we believe that the upcoming Legislative Framework for Sustainable Food Systems, that will include a part on sustainability labelling, represents a better opportunity to discuss the topic with a broad consultation of the stakeholders involved, including NGOs and civil society.