Memorandum submitted by Oxfam GB
This response to the Environmental Audit Committee's
Environmental Labelling Inquiry has been prepared by Oxfam GB.
In summary, Oxfam GB believes that:
— Food miles and labelling products
on the basis of the mode of transportation are inadequate and
misleading proxy indicators of the level of greenhouse gas emissions
generated in a product's lifecycle.
— Any greenhouse gas labelling standard
needs to consider the climatic impacts of the entire lifecycle
of the product.
— Raising consumers' awareness of a
product's environmental impact should not be at the expense of
considering its positive impact on international development.
Under the right conditions, trade is a powerful engine for reducing
poverty amongst smallholders and waged labourers.
Oxfam GB is a development, relief and campaigning
organisation that works with others to overcome poverty and suffering
around the world. We are currently investing significant resources
in scaling up our direct work on climate change, although dealing
with the escalating side effects of this has been part of our
humanitarian and development work for over 60 years. In the coming
years we will be concentrating on highlighting the impact of climate
change on poor people, and working with them, and with organisations
at all levels, to reduce their vulnerability to its effects. The
current widespread interest in ethical consumerism and the labelling
responses that seek to guide such ethical consumer choices have
potentially important implications for poverty, development, and
climate change. For these reasons, we welcome the Committee's
inquiry and the opportunity to respond to it. Our response focuses
primarily on the lines of inquiry pertaining to content, rationalisation,
and effects of environmental labelling. It does so with reference
specifically to environmental labelling that seeks to address
the climatic impacts of greenhouse gas emissions resulting from
producing, processing, transporting, and storing agricultural
products.
What should be shown under a labelling system?
The Sub-committee would like to assess which
criteria should be illustrated by an environmental label, and
how overlaps between different concerns could be adequately dealt
with. The Sub-committee would also be interested in investigating
how environmental labels could best convey information accurately
and usefully to the consumer. Given the EAC's recent focus on
climate change and related issues, the Sub-committee would be
particularly interested to hear about the development and merit
of labels which demonstrate the carbon footprint of a product—ie
the carbon emitted during its production, storage and transportation.
Consumers are increasingly demanding well-informed,
clear information to help them make decisions on the social and
environmental impacts of what they buy and on how to live "more
ethically".1 As such, environmental labelling may be an important
means of empowering ethical consumers to mitigate their impacts
on climate change. Given increasing interest in having "food
miles" information provided to consumers (41% of adults are
interested in having such information provided to them) 2, there
has been an associated interest in labelling products on this
basis. Oxfam GB fully supports efforts to empower consumers to
make ethical choices, but we believe that product labelling based
on the distance an item has travelled or the means by which it
has been transported cannot be relied upon to provide consumers
with the information they require: food miles labels are an inadequate
proxy indicator of the level of greenhouse gas emissions generated
in food supply chains.
Labelling based on the distance a product has
travelled fails to account for the significant influence that
the mode of transportation has on the level of emissions produced.
For example, over the same distance, sea freight emissions are
approximately 35 times lower than those produced by air freight.
3 One attempt to acknowledge these discrepancies has been the
use of labelling to draw attention to the mode of transportation,
particularly where produce is air freighted. Oxfam GB believes
that labelling products according to their mode of transportation
is a simplistic and misleading measure of the greenhouse gas emissions
produced throughout the lifecycle of food products. In this regard
we do not welcome Marks and Spencer and Tesco's introduction of
air freight labels on their products. 4 We agree with Rt Hon Gareth
Thomas's acknowledgement that these labels "provide only
partial information on the environmental impact of the product.
Air-freight labels don't tell us about the full impact of producing
and delivering all of the products that we might buy." 5
Anecdotally, it is not clear that such existing labels are even
fulfilling their purpose as air freight labels are being interpreted
as having positive connotations of freshness rather than as having
negative associations with high greenhouse gas emissions.
Transportation emissions need to be considered
relative to the climatic impacts of the remainder of the lifecycle
of food, from plough to plate. In many cases substituting tropical
production with local growing of similar products under artificial
greenhouse conditions will, although ostensibly reducing food
miles, in fact result in greater levels of greenhouse gas emissions.
This is due to the energy requirements necessary for maintaining
constant artificial conditions. For example, a study published
in 2000 suggested that growing a rose in Kenya and air-freighting
it to the UK requires around 2-3 MJ of energy, whereas producing
a rose under artificial conditions in the Netherlands requires
around 9 MJ. 6 More recently it was found that the emissions resulting
from growing flowers in Dutch greenhouses can be 5.8 times greater
than growing them in Kenya and flying them to the UK. 7
A labelling scheme that purports to indicate
the global climatic impacts of products must therefore be based
on the rigorous quantification of all parts of their lifecycle
not just the transportation component.
The case for rationalising environmental labels
The Sub-committee would like to assess whether
concerns over the proliferation of environmental labels are justified,
and the extent to which consumers are able to cope and engage
with the many different labels on the market. The Sub-committee
would also like to investigate whether there is a case for rationalising
the system of environmental labelling, or for calling for certain
labels to be given priority when displayed on products.
The Carbon Trust, Defra, and BSI British Standards
are already in the process of developing a Publicly Available
Specification (PAS) for the measurement of the embodied greenhouse
gas emissions in products and services. This single standard is
intended to ensure a consistent and comparable approach to supply
chain measurement of embodied greenhouse gases across markets.
The standards will help companies understand the lifecycle climate
change impacts of their products, and highlight significant emissions
reduction opportunities. Oxfam GB suggests that any greenhouse
gas labelling standard must engage with this process. In addition
to supporting the development of an internationally agreed standard,
this approach avoids duplication and inadequate short-term alternatives
that only consider part of a product's lifecycle. 8
Oxfam GB does not believe that lifecycle emissions
should be considered as part of an overarching "ethical"
label that attempts to communicate the environmental, social,
and economic impacts of the labelled product. The complexities
and the qualitative nature of many of the issues involved do not
lend themselves to one "ethical standard". On many issues,
acting ethically requires making complex decisions that involve
tensions between competing ethical priorities. In these situations
research shows that consumers do not want oversimplified choice
editing to prevent them from making the most ethical choice according
to their own consciences. 9
Nonetheless, raising consumers' awareness of
products' environmental impacts should not be done at the expense
of considering developmental impacts. Therefore, Oxfam GB suggests
that where climate change related labels compete for space with
the FAIRTRADE Mark, the latter should be the most prominent. Poor
people depend overwhelmingly on agriculture to make a living.
Many are involved in producing agricultural products for Western
markets. For example, in Africa an estimated 1.5 million people
depend on agricultural exports to the UK for a living. 10 By encouraging
consumers to switch away from products produced by poor people,
the ability of trade to contribute to poverty reduction is undermined.
Under the right conditions, pro-poor agricultural trade can be
a powerful engine for poverty reduction for smallholders and waged
labourers in the food supply chain. Oxfam GB continues to support
the FAIRTRADE Mark and the principles that lie behind as they
can make qualitatively large differences to the livelihoods of
many of the world's poorest producers. This Mark assures consumers
that, as a result of their purchases, disadvantaged producers
and workers in developing countries are getting a better deal:
receiving a fair and stable price for their products which covers
their costs of production; benefiting from longer-term trading
relationships; receiving the Fairtrade premium for investment
in social and economic development projects; and receiving pre-financing
where requested. All Fairtrade certified producers are also required
to comply with the international Fairtrade environmental standard
as part of the requirements of certification. This standard requires
producers to ensure that they protect the natural environment
and make environmental protection a part of farm management. Producers
are also encouraged to minimize the use of energy, especially
energy from non-renewable sources.
Exports from developing countries
The Sub-committee would also like to investigate
the impact of environmental labelling on exports from developing
countries, and in particular whether labelling of this kind could
have a detrimental impact on the trade opportunities available
to these countries.
For the above-mentioned reasons, we do not support
labelling that only reflects the quantification of emissions from
one portion of a product's lifecycle. As well as being an inaccurate
indicator of lifecycle greenhouse gas emissions, such labelling
may result in consumers switching away from products that support
poor producers' livelihoods. However, in principle, Oxfam GB does
not have any objections to environmental labels that reflect a
standardised and rigorous quantification of emissions from a product's
entire lifecycle. Indeed, such a scheme may help consumers to
appreciate that exports from developing countries can compare
favourably, in climatic terms, with more resource-intensive products
produced within developed nations. Labelling on products imported
from developing countries can also contribute to increasing the
visibility of their provenance to consumers. There is a growing
literature on short food supply chains (SFSCs), one form of which
includes spatially extended produce (for example, "locality"
food, certified Fair Trade or organic food) where products are
"information laden" and can thus create bonds between
producers and consumers. 11 The new economics foundation (nef)
suggest:
It is now time to explore and exploit the
full range of these SFSC models for use in the developing world,
to help family farmers maintain access to markets, create new
markets and capture a greater percentage of the final value of
their produce. 12
CONCLUSION
In summary, Oxfam GB believes that environmental
labelling, specifically greenhouse gas emissions labelling:
— Could be a positive means of empowering
ethical consumers.
— Must not only reflect the mode or
distance of a product's transportation.
— Must reflect rigorous and standardised
quantification of the emissions generated throughout a product's
lifecycle.
— Must not reflect multiple ethical
concerns, and should be limited purely to emissions quantification.
— On Fairtrade certified products,
must not receive placement priority over the FAIRTRADE mark.
October 2007
REFERENCES
1 Future Foundation (2007) Inshoring and Outsourcing,
paper presented at Changing Lives UK: Mastering the Middle
Ground conference, London, January 2007.
2 Mintel (2007) Ethical and Green Retailing,
Special Report, June 2007 London: Mintel International Group
Ltd.
3 Defra (2005) The Validity of Food Miles
as an Indicator of Sustainable Development London: AEA Technology
for the Department for Environment, Food and Rural Affairs.
4 DFID (2007a) Balancing the cost of food
air miles: Listening to trade and environmental concerns, UK
Government: Department for International Development press release,
www.dfid.gov.uk/news/files/foodmiles.asp (last checked by the
author September 2007).
5 DFID (2007b) "Speech by Gareth Thomas,
Minister for Trade and Development, at the launch of the DFID
Air-freight Seminar on 17 September 2007", UK Government:
Department for International Development press release, www.dfid.gov.uk/news/files/Speeches/airfreight-thomas.asp
(last checked by the author September 2007).
6 K Vringer and K Blok (2000) The Energy Requirement
of Cut Flowers and Consumer Options to Reduce It, Resources,
Conservation and Recycling, 28, 3-28.
7 See A Williams (2007) Comparative
Study of Cut Roses for the British Market Produced in Kenya and
the Netherlands, Cranfield: Cranfield University, and DFID
(2007c) Buy African flowers on Valentine's day to help make
poverty history, UK Government: Department for International
Development press release, www.dfid.gov.uk/news/files/speeches/trade/hilary-roses-feb07.asp
(last checked by the author April 2007).
8 Defra (2007) News Release: Step forward
on reducing climate change impacts from products, UK Government
Department for Environment, Food and Rural Affairs, www.defra.gov.uk/news/2007/070530a.htm
(last checked by the author August 2007).
9 Mintel, op cit.
10 J MacGregor and W Vorley (2006) Fair Miles?
The concept of "food miles" through a sustainable development
lens, London: IIED.
11 new economics foundation (2006) A long
row to hoe: family farming and rural poverty in developing countries,
London: nef.
12 Ibid.
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