Comments from Ostfold Research AS (Erik Svanes), Norway, received 2011-01-10:
The PCR is well written and seems to based on a solid scientific foundation. It is well structured and seems to comply with the relevant ISO standards and the framework of the International EPD Foundation. We do, however, have some critical remarks:
1. The PCR allows the development of site specific but average EPDs. It is possible to develop an EPD for the European market based on average numbers. It is also possible to use specific numbers for a certain market. This opens up the possibility for a manufacturer to choose the approach that gives the best result, by either choosing the national or regional approach.
Answer ACE: We foresee that in most cases beverage carton producers will prepare EPDs with a wider geographic scope (such as EU average) but in order to be able to meet customer demands we have to include the option for preparation of specific EPDs for certain beverage cartons. We believe also that the complexity of the supply chains requires some flexibility because average EPDs will not sufficiently represent all specific cases while a general requirement for specific EPDs does not seem practical since beverage carton producers offer too many different beverage carton solutions and will never be able to produce EPDs for all those variants.
2. The PCR allows the use of generic data to a very large extent. For certain raw materials like plastics and aluminum this is OK, and in the present situation necessary. However the use of generic data is more problematic when generic data for board is allowed. In this standard the use of a North European average is possible. This means that a large part of the products total impact is based on generic data. This does not encourage competition between producers of Beverage Carton based on environmental performance. The use of generic data for board should not be allowed. The EPDs should be based on site-specific data as far as possible.
Answer ACE: Since the environmental impact of liquid packaging board (LPB) production is actually low compared to polymers and aluminum foil production (based on weight) we do not share the opinion that there should be an explicit requirement on site specific data for LPB. If site specific data is to be used for raw material production, we believe that should apply to all types of raw materials. In almost all cases, LPB for a certain beverage carton type comes not only from one but from several suppliers, which means that aggregated data from several suppliers has to be used. The ACE LPB data is aggregated data from the European LPB board suppliers and is representative for beverage cartons on the European market.
3. There seems to be a conflict between the text in 7.1.5 (Boundaries to other product life cycles) and 9.4.2. (Potential credit from end-of-life waste management) . The conflict regards the credits from end-of-life waste management. We support to keep ch 7.1.5. but remove or rewrite ch 9.4.2.
Answer ACE: We recognize the conflict between 7.1.5 and 9.4.2 but we believe it is important to include impacts and benefits from end-of-life recycling and recovery processes in the scope of the beverage carton PCR. We propose the following solution to solve the conflict: The Intl. EPD scheme allows for a separate presentation of benefits from end-of-life processes under “additional environmental information” (see extract below). In the revised PCR draft we have restructured the document and require now that results for impacts and benefits (credits) from recycling and recovery processes are to be reported under “additional environmental information” (which separates them clearly from the main environmental results presentation).
Extract from Intl. EPD scheme supporting annex A.7.1:
If the suggested “PP allocation method” causes problems from the point of view of giving an accurate description of the environmental benefits of a product, there is a possibility to address product-specific allocation rules and justify this in the PCR document and present an additional approach with quantitative information in the EPD under “Additional environmental information”.
4. Default values for some processes of (supposedly) minor importance are OK, e.g. transport distances and transport modes makes the PCR easier to use for small and mediumsized companies. However, there should be a general rule that default values should not be used in cases where the process is a major contributor to the overall impact of one or more impact categories.
Answer ACE: We believe we have already taken the approach in the PCR to suggest only default values for processes of minor importance and specific data is always suggested to be used as primary data source.