With regards to paragraph 3. Declared unit, why does it refer to Declared Unit instead of Functional Unit, considering that all stages of the product life cycle (also the use phase) are included in the system boundaries?
Quoting from General Programme Instructions vers. 2.01, pag.31 "A declared unit is defined as a quantity of a product for use as a reference unit for an environmental declaration based on an information module, where an information module is compilation of data covering a unit process or a combination of unit processes that are part of a life cycle for a product.
With regards to paragraph 6. General system boundaries, Figure 1 does not clarify whether or not the downstream has be considered in the calculation.
With regards to paragraph 6.1 Upstream processes, given that the semiproduct production may have a lower impact compared to packaging material production, we would suggest to specify (in paragraph 10) that impacts of these two productions have to be reported separately.
With regards to paragraph 7.3 Allocation rules for product, based on our experience if the allocation between the sauce and the byproducts of its production (eg, seeds and skins) is calculated based on the mass, the sauce would have about 60% of the impact of the transformation process while, if the allocation is calculated on an economic basis, the sauce would have about 99% of that impact. Because the transformation process is specifically made to produce the sauce, the impact is mainly due to the sauce and therefore the allocation should be calculated on an economic basis.
With regards to paragraph 8.4 Packaging production, the requirements for data quality to be used for tertiary packaging are indicated, however the tertiary packaging is excluded from the system boundaries as described in section 6.1
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