With regards to paragraph 3. Declared unit, we would like to point out that packaging is an integral part of the final product because olive oil can not be sold without packaging, in fact distribution and use of olive oil would not be possible. Therefore, the packaging is functional to the olive oil and it contributes to the environmental performance of the final product.
For this reason, in order to allow comparison between olive oils packaged in different formats (eg 0,75 liters or 5 liters), it is necessary to provide the reader with a parameter to easily convert the environmental performance of the olive oil to a declared unit of reference (1 liter).
For the same reason, the performance of olive oil packaged with different materials (glass, cans, plastic) must be reported separately for each single packaging.
The requirement of 5% is applicable only to packaging of the same material, in order to simplify the communication of the results (not the calculation as to verify the applicability of the 5% requirement, it is needed to collect and to process data for all packages).
Also, if different packaging materials have an environmental impact lower than 5%, it is not clear which method should be used in order to consider them as a group. Would the average of their performances be the correct way to do it?
With regards to paragraph 8.3.2 Time boundaries, we would point out that option 1 derives from our experience when the olive oil manufacturer has no direct control on the cultivation phase since it buys olive oils from different Countries.
Ambiente Italia srl