Q&A - The Greenwashing Challenge and LCA

Here we have collected some questions that were not all answered in our webinar on December 12th 2022 because of time constraints.

Q: It was mentioned that we should do first, communicate later. I have also been told that companies should "set bold targets, publicly

A: The best communication is action. Setting bold targets and holding yourself accountable can be seen as a good strategy, but if you do so, you have to make sure that you follow up on those targets. There must be continuity, sustainability has to be part of your strategy. The public remebers your promises! Another suggestion is to look for Product Category Rules for EPD's (Environmental Product Declarations) in your product category.

Q: What if a company does a LCA and chooses the scope in a wrong way. This can lead to greenwashing, but its harder to discover...

A: First, it's good to remember that the ISO 14040 standards for LCA call for LCAs to be iterative: things you learn or discover at any stage can lead you to go back and adjust, improve, aspects of the study that were set or done previously. For this reason, projects should build in time/resources for such iteration, and provide opportunities to take stock along the way. One way to do this, for the specific question of scope, is to engage a critical review panel already during the goal and scope stage of the project.

Q: Now that we are at the LCA topic: How can we avoid companies choosing wrong scope or making wrong assumptions when creating a LCA? As this can lead to a more subtle kind of greenwashing. Harder to disprove, as "it comes from an LCA"

A: It is hard to fully prevent any companies from making wrong assumptions. The best defense on this point is a combination of transparency -- full and clear documentation of all assumptions and testing of their influence, in the report; and critical review: engaging outside experts to review the full study including the assumptions and goal and scope. The notion of a "wrong scope" is something to be careful about: the scope should serve the goals and purpose and intended use and resources available; it can be narrow or broad as a result.

Q: Surely critical here is the choice of assumptions for LCAs and then the regular reassessment of those on a regular basis (and the re-evaluation of LCAs if changes call for it)?

A: When it comes to assumptions, one should check their impact through what's called a Sensitivity Analysis: seeing the effect if those assumptions were to be different. If changing the assumptions dramatically change the conclussions, we should be very weary of those conclusions. That's why at Earthster we make sensitivity analysis as easy as changing a few numbers, and you immediately see the effects.

Q: Comparing emissions reductions to say '2000 households', couldn't this also be a form of greenwashing? These savings might not be enough for larger companies, may not be aligned to science based targets etc.

A: Of course, you should use concrete examples that are relevant to your company and your industry. So my example of "2000 households" doesn't work for everyone, and like you said, using examples that are not relevant could be considered greenwashing. Make sure that all the examples you communicate are based on facts, data or science and not just "pulled out of a hat" to make them sound concrete. If in doubt, I'd advise to work with a reputable (external) comms professional who can ask the tough questions before you make your efforts public.

Q: Hi Marjo, Thanks for your presentation! Have you already seen some monetary penalization for companies that greenwash in some way? Or just the scratch in the reputation...?

A: I haven't seen monetary penalties, but you could argue that a dent to your reputation is also a kind of monetary penalty. In many greenwashing cases, there are always financial consequences, as well as reputational consequences.

Q: Through biogenic carbon accounting, cradle-to-grave assessment of novel biobased materials can result in negative (beneficial) impacts that lead to greenwashing ("carbon negative" etc). How can we change this habit?

A: In fact, "carbon negative" is not necessarily a false outcome nor greenwashing. It is technically feasible. If an LCA is done thoroughly with an adequate scope, it is less likely for products to have a false beneficial impact. When the modeling is done correctly the sequestered carbon is treated in the right way in the end of life stage of the product. If a larger quantity of CO2 is sequestered than emitted over the life cycle, or if a more potent greenhouse gas such as methane is captured and then only CO2 is released, then the life cycle greenhouse gas balance can at least in theory be beneficial. It is important to consider though that a product will have also impacts other than global warming ones.

Q: Do you expect (or know of) any upcoming regulatory requirements for corporate annual disclosures to include LCA of their products/services?

A: Product Environmental Footprint (PEF) is a standardized method for conducting and communicating about product life cycle assessments, which has been developed, pilot-tested and refined by projects of the European Commission. The EC's product policy website had forecast an announcement in relation to PEF for November 2022, hinting at possible connections to regulations. So far no new annoucement has been made, but stay tuned!

The EU's Corporate Sustainability Reporting Directive (CSRD) requires companies in scope to disclose impacts on Global Warming, Water, Biodiversity, several kinds of Pollution and also Circularity. Not just their own operations but impacts throughout the value chain. CSRD was approved in November and will require companies to comply gradually, the biggest ones starting in 2024. https://www.europarl.europa.eu/news/en/press-room/20221107IPR49611/sustainable-economy-parliament-adopts-new-reporting-rules-for-multinationals

Q: Isn't it past time for there to be an ISO for LCAs? One that covers standards, governance, processes, etc?

A: Important indeed! The ISO14040 and ISO14044 standards, released in the 1990s, define how a Life Cycle Assessment should be done

Q: Will PEF or GHG become the standard for calculations?

A: Well, GHG means greenhouse gases, or global warming impacts. They can be reported for organizations and for products. This is an important impact category for LCA, and there are standards for how companies should account for, and report, their GHG inventories. These include ISO 14067 for products, and standards for both products and organizations released by multistakeholder initiatives under the name of "GHG Protocol." PEF on the other hand, as noted above, is a standardized method for conducting and communicating about product life cycle assessments. It generally (but not entirely) conforms to the requirements laid out in the ISO standards for LCA (14040 and 14044), and also adds considerable additional details and requirements. GHG reporting will surely remain important, as a subset of LCAs, while the future of PEF remains to be determined in large part by decisions by the EC.

Q: the majority of journal articles do not go through critical review, can we rely on the results from those papers as they went through peer review but not critical review?

A: Scientific peer reviews require a number of other scientists to have approved the scientific validity of the paper, so they can be even more demanding than a critical review. In addition, journal articles will typically go through more scrutiny from a methodological point of view.

Of course, both types of reviews have risks of excessive complacency, so at Earthster we advocate for review and validations of the actual models in all cases.

Q: How much Information e.g. on resources/raw materials should be shared with the customers, especially when keeping in mind that the situation is always developing and changing?

A: Each business can decide case by case how much or how little detail they want to share with the public. Critical reviewers need access to the full life cycle model and all data but it does not mean that the public would need to have those same details. LCA's can be updated relatively easily when there are changes, if the organization who owns the LCA has in-house competence and software available.

Q: Primary data is a huge problem in LCAs, how do you think we can cope with this?

A: Greg @Earthster: This is at the core of why we started Earthster. We've come accross many companies that want others to share their data (and call that "a problem to get primary data"), and then are reluctant to share their own data because it includes trade secrets. Our solution is controlled sharing, so you can decide what to share (from full model to just impacts) and with whom (specific customers, all your customers, or the public). The fact that this will be LCAs instead of PDFs is part of the solution to the problem of primary data availability.

Q: LCA data can also be quite proprietary. How can you do an LCA without giving out critical information when the LCA is shared publicly?

A: This is partly answered in the preidous answer. Not all data needs to be shared publicly, data only needs to be shared with the person conducting the LCA and with the critical reviewer(s) and is usually protected by an NDA

Q: The challenge with PEF is, that they require data-quality that most of the time cant be achieved due to lack of data. How to deal with that?

A: Lack of data or data quality is an issue in general in LCA. Data will never be perfect and does nto need to be perfect for every detail. You shoud hwever make an effort to get your hands on primary data, for example from your suppliers, when that is relevant. For example in Earthster, you can request your suppliers to update their LCA data into your model and crate a so called "Connected LCA"

Q: Would the panel agree that no LCA can be perfect, but any LCA is better than none?

A: I would definitely agree that no LCA can be perfect. And while the phrase "any LCA" is perhaps overly optimistic, it is also true that any LCA will provide informative results to the persons doing the analysis.

Q: How can different impact categories be weighed against each other, to know what is significant and what is not. For example, impacts on Global warming, water scarcity, biodiversity loss.

A: There is a process called Normalization. It involves comparing the impacts of your product system versus those of some larger reference system, generally the impacts of a continent or the world in a recent year. This comparison provides both a materiality assessment and a leverage assessment, because it enables you to identify those impact categories on which the life cycle of your product makes a larger contribution to total impacts of the reference system.

Q: If we hire a consultant to do an LCA, do we also need to hire another consultant to do a critical review?

A: If you wish to make what ISO 14044 calls a "comparative assertion" which is a public claim about the environmental superiority of one product system to another, then a critical review panel must be convened and they generally require financial compensation, yes. If, however, you are simply making a public statement about the results of your study without making any comparative claims, this is called a "third party communication", and in this case, the critical review can be done by a single person, and that person can be a member of one of the companies already involved, as long as they were not involved in the study. Finally, if you are doing an LCA strictly for internal use, no critical review is called-for by the ISO standards.

Q: How can you communicate on the advantages of your product when you have burden-shifting ?

A: Being transparent is a good way: showing that there's an upside and a downside, and justifying why the upside justifies it being an advantage (e.g. through normalization, stakeholder weighing, etc)

Q: Is the burden shifting not addressed via Ellen McArthur Circular Design?

A: Both concepts are independent. Circularity focuses on what should be done to avoid burdens (with an emphasis on materials-related impacts), whilst LCA focuses on impact on given impact categories. Burden shifting happens when the impact on one category is reduced, at the expense of increasing the impact on another impact category (e.g. making it better in relation to climate change, but worse in relation to ecosystem quality). You could for example have a product that's more circular (less burden on materials), but at the expense of a higher burden on climate change (e.g. more transportation)

Q: To summarize, how can you avoid Greenwashing?

A: Don't lie, be transparent, communicate both your positive and negative impacts. So don't cherry pick only positive things. Get to know your (prduct/process/service/organization) Life Cycle impacts through LCA. LCA has become much more accessible than before! One way to get started is to hire an intern from the Environmental Impacts Academy LCA internship program.

Q: Is the Videolink personal or can I share with others, more needs this good presentation. A good one hour spent here thanks!

A: All our webinars are recorded and they will be available on our web page https://www.environmentalacademy.org/events

Q: Thank you EIA for great webinar - learned a lot, interested to learn more!

A: Thank you! One opportunity to learn more as an individual is to apply to the Environmental Impacts Academy's internship program. If you find a company to intern for or if we find a company that wants you, then you will receive two weeks of intensive LCA training, support during a two month LCA project and become familiar with the Earthster LCA software

Q: How can my business get started with doing Environmental Life Cycle Assessment?

A: Hire an intern from the Environmental Impacts Academy LCA internship program. More information on our web page https://www.environmentalacademy.org/lca-starter