House of Commons - Environmental Audit Committee

Environmental Labelling - Environmental Audit Committee Contents

Memorandum submitted by Department for Environment, Food and Rural Affairs

1. INTRODUCTION—THE ROLE OF DEFRA AND OTHER PUBLIC AUTHORITIES IN RELATION TO ENVIRONMENTAL LABELLING

1.1 Defra has a number of direct interests in the subject of environmental labelling.

— At a general policy level, we are interested in the use of information and labelling as part of a wider potential toolkit for helping to reduce the environmental impacts of products and services.

— We have formal responsibilities in relation to some particular labelling regimes—for example, the EU ecolabelling scheme and the EU energy labelling regime, which are established by legal instruments at EU level.

— We are responsible (with the agreement of the Devolved Administrations) for implementing the standards for the production of organic food and feed which are set out in EU law.

1.2 Other Government Departments also have formal responsibilities for rating and labelling regimes which cover a significant environmental issues, for example:

— The Department for Transport in relation to the labelling of new cars to show their CO2 emissions.

— Communities and Local Government in relation to the energy efficiency of homes (the Energy Performance Certificate included in Home Information Packs).

1.3 The Health and Safety Executive has responsibilities in relation to the regulatory regime for the classification and labelling of hazardous chemicals. This alerts users to hazards to the environment and human health, and provides instructions for the safe use of the chemical.

1.4 The Food Standards Agency leads within Government on the regulation of horizontal labelling requirements which are harmonised at EU level. Food labelling rules aim to ensure that consumers can make safer, healthier, and more informed choices, and to promote free trade within the EU.

1.5 At a broader level, the Department for Business, Enterprise and Regulatory Reform (BERR) has responsibilities for consumer protection, and the legislation on unfair commercial practices, which BERR is currently introducing, is capable of applying to labelling claims which mislead consumers. (The new legislation on unfair commercial practices will replace existing legislation on trade descriptions and, so far as business-to-consumer advertising is concerned, existing legislation on misleading advertising.) However, this framework extends across a potentially very wide range of issues, of which environmental claims is only one.

2. GENERAL BACKGROUND—INFORMATION AND LABELLING AS A TOOL FOR ENVIRONMENTAL IMPROVEMENT

2.1 This memorandum goes on to offer factual material and comment on the specific topics which the Committee has highlighted as its principal lines of inquiry.

2.2 However, Defra would like to offer first some wider background about the issues and developments surrounding environmental labelling. The subject has evolved considerably over the last 15 years or so:

— In the early 1990s the general thinking was dominated by assumptions that good information about products would directly create consumer demand for greener products and "pull" them through the supply chain. Debate was concerned mainly with high-level award schemes (such as the EU Ecolabel, introduced in 1992) and the quality of self-declared "green claims" which businesses made about their products.

Securing the Future

Making Product Information Work for the Environment

2.3 The 2006 report, to which Defra made a significant contribution, represents the most up-to-date policy analysis of environmental product information. The report received broad support at a meeting of EU stakeholders and member state representatives in June 2006. The analysis part of the document (p 5-21) could therefore be a useful input to the Committee's inquiry.

3. BACKGROUND ON THE VARIOUS TYPES OF ENVIRONMENTAL LABELLING

3.1 Environmental labels, claims and declarations come in very varied forms and there is no simple way of categorising them all. But the International Organization for Standardisation (ISO) has produced technical classifications and standards which capture much of the field.

— ISO 14024 is for what are known as "Type I" claims—declarations which meet criteria set by third parties (not by a manufacturer or retailer themselves) and based on life-cycle impacts. These are award-type labels, like the EU Ecolabel and national ecolabelling schemes, requiring compliance with the criteria to be verified by a third party. In theory, products bearing a Type I label should be of a fairly high environmental standard, though in practice this depends on how the criteria for a particular scheme are set and on the effectiveness of the management of the scheme.

The Green Claims Code,

— ISO 14025 is for "Type III" claims, which give quantified information about products based on life-cycle impacts. Type III claims—sometimes known as Environmental Product Declarations (EPDs) or eco-profiles—consist of quantified information about key impacts, such as energy in use. The idea is to allow products to be compared on a like-for-like basis. They have mainly been used in the business-to-business market (though the feature of rating and comparability can also be seen in regimes like energy labelling, which are not technically "Type III" claims).

3.2 Various other schemes or symbols overlap with environmental labels in some way. For example, there are ethical schemes which have links with certain environmental factors or which include some environmental requirement (like the Fairtrade scheme); and there are informative symbols, such as the Mobius loop.

3.3 Defra's explanatory leaflet, A Shopper's Guide to Green Labels—submitted with this memorandum[5]—summarises the characteristics of many of the major labelling schemes seen in the UK, and illustrates their logos.

3.4 The Shopper's Guide looks at the different types of labels in less formal categories and may be a more helpful way of looking at what the labels are trying to achieve. (Some schemes fit into more than one of the following categories, and the categories themselves are not mutually exclusive.)

— Energy labels, which focus on the energy-in-use impacts of products—especially the EU energy label, which is mandatory for certain domestic products such as washing machines, refrigerators and lightbulbs. Other labels focusing on energy efficiency and reduced CO2 have recently been developed in the UK which echo the energy label's colour-coded ratings, such as the UK's fuel efficiency and CO2 label for cars. Other examples of energy labels include the "Energy Saving Recommended" label for a wide range of energy efficient products in the UK market (also a form of "award" label) and the "Energy Star" scheme which appears in Europe and America on a wide range of office products.

— Sector-specific labels, which apply to one kind of product, like timber or textiles. The international Forest Stewardship Council (FSC) scheme (also a form of ecolabel award) is the most well-known of these, but there are many different schemes for products as diverse as flowers and textiles.

— Organic labelling. The word "organic" can only be used to describe food, feed or livestock if the relevant EU standards are complied with. At present the use of the organic logo prescribed by the EU standards is optional, but its use will be compulsory after 2008 when a food or feed product is sold as organic. The logos of the bodies like the Soil Association, which have been approved by Defra to certify organic produce, may accompany the EU logo. Some of these bodies also certify non-food products like textiles, wood products and cosmetics, which are not covered by EU law on organic production.

— Food labels—there are many schemes, for many different types of food, which have an environmental dimension. One of the better known examples is the Marine Stewardship Council (MSC) scheme, but several other schemes also operate just in the fish and seafood sector alone. Some suppliers' "own brand" labels, covering a range of foods, may also be linked to environmental criteria.

— Social and "wider world" labels primarily address specific ethical (and sometimes environmental) issues associated with the places where products are sourced, such as Fairtrade and Rainforest Alliance (which is why Fairtrade is occasionally mentioned in this memorandum even though it is not primarily an environmental label). These can cover crops such as bananas, coffee, timber, as well as products like footballs and activities like tourism.

— Green claims (the "Type II" labels of the ISO classification above). This covers a multitude of labels, declarations and claims which are self-declared on the initiative of the producer. They are not generally associated with any third-party regime. They are however subject to consumer protection regimes on trades descriptions and misleading advertising.

3.5 There are variations and hybrids of these categories—and some other kinds of labels as well. For example, a few companies have their own quite specific "schemes" behind their self-declared labelling, such as Philips' "Green Flagship". Within the last year or so, initiatives using the term "carbon labelling" have started to appear—see Section 5.8.

3.6 Even the more systematised schemes vary in quite basic aspects, such as the strictness of their standards (eg, whether aiming for a very high standard or a reasonably good standard). They also vary considerably in their visibility in the marketplace.

4. THE SCOPE AND COVERAGE OF LABELLING

Products requiring labelling.

Compulsory schemes

4.1 The EU Energy Label is the longest-established mandatory scheme operating in the UK market. It covers most of the more significant energy-using consumer products in the home.

4.2 A similar approach of comparable performance "ratings", presented on a colour-coded scale, is used in the Energy Performance Certificates (EPC) element of Home Information Packs (HIPs).

4.3 The approach is also used in the UK Fuel Economy Label. The label has been agreed voluntarily by all the companies selling new cars in the UK, but it is in effect a standardised way of presenting consumers with legally required information on fuel and emissions.

4.4 The approaches now followed for homes and cars can be traced back to recommendations made by ACCPE in 2000, around the idea of a "family" of labels for major consumer products contributing to carbon emissions in their use phase.[7]

4.5 The Chemicals (Hazard Information and Packaging for Supply) Regulations 2002, implement the existing European Directives on the classification and labelling of hazardous chemicals, a long-established and widely understood system. The Regulations require hazards to the environment and human health to be communicated to the user (both consumer and professional) via agreed symbols and warning phrases. The existing system is due to be replaced by the forthcoming European Regulation based on the United Nations Globally Harmonised System of Classification and Labelling of Chemicals (GHS).

4.6 The crossed-out "wheelie bin" symbol is a mandatory mark that manufacturers are required to apply to products which fall within the 10 categories of electrical and electronic equipment (EEE) covered by the WEEE directive—to indicate to consumers that the EEE should not be disposed of as general waste to landfill. End-users are strongly encouraged to separate such WEEE from their general waste.

4.7 The Eco-design for Energy-Using Products (EuP) directive will require a new approach when it is implemented for various types of product—by requiring environmental criteria to be met before the product can receive the CE Mark it needs in order to appear in the market. In this way environmental criteria will be incorporated into a non-environmental label.

Mandatory food labelling in the UK

4.8 As the Sub-Committee has flagged up a particular interest in food labelling, here is a summary picture:

— The labelling of most food in the UK is governed by the provisions of the Food Safety Act 1990 and the Food Labelling Regulations 1996. These implement EU Directive 2000/13/EC on the labelling, presentation and advertising of foodstuffs.

— Additional labelling requirements are contained in over 40 horizontal and vertical pieces of legislation (for example, GM labelling, wine, beef and EU marketing standards).

— These rules aim to ensure that consumers are properly informed about the nature and substance of the foods they buy, protected from false or misleading descriptions, and that industry has a clear regulatory framework which does not restrict product innovation or inhibit the free movement of goods within the EU.

— The European Commission is reviewing the General Food Labelling and Nutrition Labelling legislation. A draft proposal is expected in by end of 2007, at which point the Food Standards Agency will conduct a full public consultation.

Voluntary environmental labels

4.9 As noted in the Section 3 above, there is a very wide range of voluntary environmental labelling approaches covering products and services, including food.

4.10 The most visible voluntary schemes operating in the UK are featured in The Shopper's Guide to Green Labels. It would be hard to agree a meaningful and comprehensive list of the many other schemes of varying standards operating in the UK, but Defra publishes an on-line list of many of the less familiar schemes in its Directory of Green Labels.[8]

4.11 For some types of products, such as timber and textiles, there are several schemes which highlight different aspects of sourcing or production, depending on what messages the supplier wishes to communicate.

4.12 Although participation in these schemes is voluntary on the part of business, there are a few which actually operate within a legal framework. For example, organic food labelling schemes are not mandatory, but the use of the word "organic" is controlled by law. And while business participation in the EU Ecolabel scheme is voluntary, all Member States are required by law to establish a Competent Body to run it in their countries, and are also required to promote it.[9]

The case for trying to cover further products or sectors in an environmental labelling scheme

4.13 "Better labelling" is often advocated as a solution to reducing the environmental impact of products, and the idea has stimulated a host of labelling schemes around the world. But labelling is certainly not the only means of effecting change, as noted in Section 2 above. Nor is labelling necessarily the best means of effecting change, especially if pursued in isolation.

4.14 It is quite instructive to look at some of the more successful examples of labelling schemes, in terms of recognition and take-up. The experience of cases like FSC, organic labels and Fairtrade, for example, suggests that market interest is stronger where there is a clear, specific issue which can be readily identified with certain products—eg (in the three examples just mentioned) sustainable sources of timber; food grown without artificial chemical fertilisers and pesticides; and equitable treatment of suppliers in developing countries.

4.15 By contrast, award schemes which aim to cover a complex mixture of environmental issues across a product's life-cycle have often found it much harder to make headway in the market. (The exceptions in the European market have been the "Blue Angel" label in Germany and the "Nordic Swan" in Scandinavia, which have achieved reasonable recognition in their regional markets.)

4.16 Over many years the Government has consistently held the view that it would not be worthwhile to set up a new publicly-owned, multi-criteria award label for the national market. This was also the firm view of ACCPE, when it was asked to consider this question in depth.[10]

4.17 The UK has however continued to support the official EU Ecolabel scheme, working hard to make the existing scheme effective and, increasingly, to advocate reforms which would help to streamline the scheme and get it working closer to the market. The European Commission expects to publish its formal proposals for revision by the end of 2007.

4.18 There are many types of products for which there are no ready-made third-party "schemes" which a company can participate in. With that in mind, Defra offers information to businesses about alternative marketing approaches—in an on-line guide called Pitching Green.[11]

4.19 Labelling schemes that aim to make a virtue of high environmental standards in farming, such as the "LEAF Marque" label, can help raise farmers' environmental performance as well as improving consumer choice. These schemes have the potential to make a positive contribution to environmental goals, if they were adopted more widely and covered the range of environmental issues. However, uptake of these schemes is currently low and Defra is investigating how it might be increased, for example through more explicit government recognition of these standards. Defra is also considering the possibility of developing some form of generic standard for an integrated farm management and environmental management scheme, which would allow consumers to know more about the environmental provenance of food products and improve recognition in the market place.

5. THE ISSUES BEST COVERED BY ENVIRONMENTAL LABELLING

What should be shown under a labelling system.

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.

Types of criteria

5.1 In general environmental labelling tends to address three main kinds of environmental issue:

— measurable impacts connected with energy and resource use;

— the sustainability of supply, particularly the implications for biodiversity; and

— the presence or absence of substances which may be held to constitute a problem.

5.2 However, as noted in Sections 3 and 4 above, the market is often interested in other aspects of the product, combining social and environmental factors. A good example of this is the FSC labelling scheme for timber products—and arguably this combination is one of the scheme's real strengths in the market.

Communicating with consumers

5.3 Labelling is a flexible instrument, and there are no hard-and-fast rules about the best way of conveying information usefully and accurately to the consumer. Even though the internet can now provide far more detailed information about products, on-product labelling remains highly popular as a conveyor of key messages of all kinds.

5.4 Environmental labels have two main functions vis-a"-vis consumers:

— they inform—where plain factual information is provided, perhaps because this is required by law, or because consumers are thought very likely to expect it.

— they influence, directly or indirectly—this might be promotional (aimed at trying to encourage the consumer to buy the product); or advisory (for example, saying how the product is best used or disposed of).

5.5 Some labels combine the two—for example, in "warning" mode, where a label provides essential safety information about the composition of a product and tries to influence consumers to use it safely, because the product may be dangerous to the consumer or to the environment if used incorrectly. As such, labels are covered by legislation preventing or requiring certain features.

5.6 All these aspects may be covered by legal requirements about what information must be put on the labels of certain types of products (especially factual labelling), and laws prohibiting certain kinds of statements (for example, misrepresentation when promoting products).

5.7 Labels which aim to influence are more complex. Another consideration is that labelling schemes (or types of labels) which aim to influence the consumer are themselves also brands or "products". Like brands, they can:

— create a unique selling point, which advertising tries to sell to consumers (what marketers term "mind share branding"—the use of the FSC logo on tissue paper, for example); or

— be valued not so much for what they do, as for how they make consumers feel about themselves (what marketers term "identity brands").

Carbon footprinting and labelling

5.8 Carbon footprinting—and how it can be used in the market—is an area of fast-growing interest. It is important, however, to distinguish between the measurement of the carbon footprint (or, more properly, the "embodied" greenhouse gas emissions in products across their life cycle) and the various uses to which that information can be put—of which product labelling is only one of the possibilities.

5.9 A vital first step is to get a commonly accepted method for doing the measurement. That is why Defra is supporting and helping to fund BSI British Standards (BSI) to develop a Publicly Available Specification (PAS) that will give businesses a standard methodology for assessing the "embodied emissions" in their products.[12] The Carbon Trust is also supporting that work and the steering group arrangements to take it forward as quickly as possible.

5.10 Once there is a common measurement standard, there are various uses which companies can make of the information about their products. Footprinting information could be used:

— to help companies reduce impacts through changes in product design or process management;

— to help companies reduce impacts through supply chain management—the choice of materials or the standards demanded from their suppliers;

— to communicate to groups of stakeholders the steps being taken to reduce impacts—eg, through company reporting or other corporate materials; and

— to communicate to individual consumers at the point of sale—through product labelling or other advertising material.

5.11 All of these possible uses have potential value. Communication to end-consumers is the one which throws up most challenges. There are issues about how in practice a business can provide information that is meaningful and generally helpful to consumers, does not give any misleading messages, and actually empowers consumers to take useful action.

5.12 The pilot scheme which the Carbon Trust is currently running (the Carbon Reduction Label) should help to tease out some of the issues about how communication to consumers could be made to work in practice.

5.13 Defra's main concerns in this field are:

— to get a method of measurement for "embodied" emissions which the whole of the market can use with confidence;

— to encourage businesses to act on this information to reduce the climate change footprint of their products;

— to keep in view, nonetheless, that the range of environmental impacts varies for different products, and that the climate change impact is but one aspect; and

— to ensure that whatever kinds of product information are eventually provided to consumers are going to be fair, reliable, helpful and genuinely useful to them.

6. THE CASE FOR RATIONALISING ENVIRONMENTAL LABELS

The case for rationalising environmental labels.

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.

6.1 Existing labelling schemes cover many different issues, including some overlap between certain schemes. But having a wide range of different labels on the market is not necessarily a disadvantage.

6.2 "Rationalisation" is difficult to consider when there is no fully comprehensive model of labelling which covers all aspects of sustainability. In fact, the striving for balance between different factors may mean that the more issues a scheme covers, the less effective it is as a label.

6.3 Although the number of labelling schemes can seem confusing, some have become well known by consumers, who are able to differentiate between them in the same way as between the many different brands and retailers. Suppliers are likely to continue to want a range of labels to reinforce a variety of key messages about their products. And retailers in particular can aim to make their own brand a desirable environmental and social label.

6.4 There are several important sectors in which well-known standards or labels do not address all of the issues which matter to buyers, or where there is no good labelling scheme, or where existing labels do not meet market needs in other ways. So there is room for initiative in the market to consider new labels which address issues not covered by others. This helps fresh approaches to be tried out and can help inform wider debate.

6.5 Even where separate labelling schemes cover similar territory, a degree of choice can help business. The first-rate schemes obviously help to encourage better environmental standards, and stimulate other organisations to create better schemes. At present it seems likely that there will continue to be a core range of good green labels in the market.

6.6 There was a helpful discussion of some of these issues in a report by the Cabinet Office Performance and Innovation Unit in 2000,[13] which looked across a range of social, health and environmental issues in the trading system, and included a look at some of the issues raised by labelling. Among the conclusions were that "labelling can often be left to the market to deliver, responding to consumer and producer demand for schemes. Voluntary approaches have a number of advantages including greater flexibility and capacity to reward market leadership through setting high standards. Government still has a role to play in terms of guarding against misleading claims, promoting adherence to best practice (eg to avoid the creation of de facto trade barriers) and in promoting mutual recognition of schemes." These points were reflected in subsequent inter-departmental work on common principles to apply in policy towards labelling schemes.[14]

6.7 Defra's approach towards promoting voluntary schemes is to encourage businesses to use the best of them, and to help consumers to recognise those schemes through initiatives like The Shopper's Guide to Green Labels, which shows the main types of green labelling schemes operating in the UK, and its Green Labelling News.[15] We have also been working to encourage cooperation and convergence of approach (and therefore less proliferation) in the field of formal "Type I" award labels, particularly in the EU market.

7. THE IMPACT OF ENVIRONMENTAL LABELLING ON CONSUMER BEHAVIOUR

The impact of environmental labelling on consumer behaviour.

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.

7.1 Surveys normally find that consumers say they want more or better labelling, and would use it to guide their choices. However, other evidence suggests that environmental labelling in itself actually has limited impact on consumer choice at present. This is partly because of the complex factors behind choice and behaviour (referred to in the introduction to this memorandum). But sometimes it is simply because consumers are unsure about specific aspects of labelling. For example, a very recent study by ANEC, the European body representing the consumer voice in standardisation, said that new "A+" and "A++" Energy Label ratings were confusing to consumers—in what is one of the most familiar areas of green product labelling, and one with clear factual backing.

7.2 Whether labels cause consumers to switch from one brand to another is not known with any precision. It appears that environmental labels are held by consumers to be more important in some areas (eg, cleaning products, paint and textiles) than others. And also that there are different headline issues for consumers for different types of product (eg, no peat for soil improvers; recycled paper for kitchen roll).

8. THE REGULATION OF ENVIRONMENTAL LABELLING

The regulation of environmental labelling.

The Sub-committee would welcome assessments of whether current levels of regulation are adequate, or whether further regulation, be it wider in scope or stricter in demand, is required.

8.1 As noted above, the UK has legal requirements about the accuracy of claims made about products. Defra keeps The Green Claims Code and other guidance to manufacturers and retailers under review, and occasionally meets the ASA and other bodies to discuss this.

8.2 It is worth noting that the European Commission has raised the possibility of strengthening the application of rules on misleading advertising to green product information.[16]

How standards for labels are set and labels are awarded

8.3 This varies with the scheme. Type I ecolabel award labels normally set their criteria after consultation with interested parties and circulation of drafts, which is intended to be a transparent process; applicants then have to obtain some kind of independent verification to prove that they comply with the scheme's requirements. Type III `profile' labels typically set their criteria through some form of sectoral collaboration. Type II labels and declarations are by definition self-declared. And the criteria for legally-backed schemes (such as the EU energy label) are agreed as part of a legislative process.

Regulation of voluntary labelling schemes in the market

8.4 Most green labelling schemes start as industry or sector initiatives, or are independent. Many schemes are run by private organisations and some are international. There is little scope for Government to control these, beyond the legal framework to deter inaccurate, unfair or unhelpful claims. Governments are also wary about intervening beyond that—in their own fields many independent labelling schemes have a valuable profile, with strong promotional strategies for focusing public attention on key areas of environmental concern.

9. EXPORTS FROM DEVELOPING COUNTRIES

Exports from developing countries.

9.1 Environmental labelling has sometimes been seen as a threat to developing countries, and debate about ecolabelling in the 1990s frequently questioned whether it was a Technical Barrier to Trade (see also section 10).

9.2 It tends now to be seen more as an opportunity. The development of an African eco-labelling scheme was one of the activities identified in the African 10-Year Framework Programme on Sustainable Consumption and Production. The African Union Commission is currently working with the Economic Commission for Africa and the United Nations Environment Programme (UNEP) to develop an ecolabelling scheme for Africa, to exploit the global market for greener products, to increase access for its products and contribute to poverty reduction.

9.3 UNEP also held the first Steering Committee meeting this summer for its project on enabling ecolabelling opportunities for developing countries, which will be formally launched in December this year. The project supports the implementation of ecolabels in developing countries, and aims at developing a roadmap in the direction of mutual recognition of ecolabelling schemes. The countries involved include Brazil, China, India, Kenya, Mexico, and South Africa, as well as representatives of the European Commission.

9.4 At the opening session, the Chair of the Global Ecolabelling Network expressed his appreciation for the project "in reversing the misperception of ecolabels as trade barriers and transforming them into an accessible tool for enhancing trade opportunities of developing countries".

9.5 Other kinds of labelling, especially "wider world" labels such as Fairtrade and Rainforest Alliance, have built relatively strong support by focusing on the impacts of products on the communities and environments in the areas where they are produced. For example, Unilever announced in May that it would certify its tea producers in East Africa to Rainforest Alliance Standards as the first move in a plan to source its entire tea supply sustainably.

9.6 There is a legitimate concern, however, that labelling which focuses exclusively on the issue of "food miles" may be damaging to developing economies (eg, as in debates about the environmental downside of green beans air-freighted from Africa, as against the social and economic upside for the producing country.) The concept of "food miles" has gained wide currency, but is often unhelpful if taken in isolation: as one study has put it, "a single indicator based on total food kilometres is an inadequate indicator of sustainability".[17] It can also be misleading in terms of the total environmental impacts of a product—for example, a focus on overseas transportation ignores the climate impact from other stages of the production cycle, such as cultivation, preparation, refrigeration, and transport within the UK. As an illustration of this, one recent study has found Kenyan cut flowers to be five times less carbon-intensive than flowers imported from the Netherlands.[18] Defra's work in developing a robust standard for measuring all the embodied greenhouse gases in products (see Section 5 above) is intended to enable a more balanced view of this complex subject.

10. INTERNATIONAL LABELLING

International labelling.

10.1 The EU Ecolabel is the largest scheme in the world in terms of the number of countries which formally operate it. The scheme is already watched with interest around the world and can also be awarded outside to products from outside the EU (Defra has awarded it to companies in Asia, North America and Australia), so the scheme has the potential to be a much more influential player on the world stage.

10.2 Several international voluntary organisations exist to coordinate information about each type of labelling system and to promote good practice, but they have no regulatory powers. These include the Global Ecolabelling Network (GEN), for Type I labels; and GEDnet (the Global Type III Environmental Product Declarations Network) for Type III labels. These bodies do not have formal powers to coordinate labels, and do not "own" the labels, some of which are subject to owners' copyright and other restrictions, and are effectively products or brands in their own right.

10.3 GEN has been working for some time on proposals for an International Coordinated Ecolabelling System (GENICES). The intention is to develop a coordinated system, not a replacement international system. Proposals include the development of 12 harmonised or core criteria. As noted in Section 9, UNEP's project on enabling ecolabelling opportunities for developing countries aims at establishing a roadmap in the direction of mutual recognition of ecolabelling schemes.

10.4 A big new international scheme is therefore not on the cards in the foreseeable future, but international cooperation is likely to increase, and indeed international cooperation in other areas of labelling will promote this in environmental labelling. For example, the European Commission is proposing to align the current EU system of classification of chemicals to the United Nations Globally Harmonised System (GHS)—see Section 4.5 above—integrating the internationally accepted classification and labelling system in new EU legislation.

10.5 The GHS, which is currently under negotiation, is expected to boost trade and competitiveness, and this is also one of the potential benefits of harmonised labelling schemes. International cooperation is in the interests of all stakeholders, but is perhaps particularly important for multinational companies, which need to know the environmental standards that they are expected to meet and stay ahead of in many different markets around the world. The development of labelling schemes therefore needs to take account of the global supply chain of a great many products, and hence to meet international industry requirements as well as those at a national level. Defra's work to develop a methodology on the measurement of embodied greenhouse gas emissions, with its potential to form the basis for agreement of future international standards, is an example of keeping this international perspective in view.

11. CONCLUSIONS

11.1 A wide and very diverse range of environmental labels currently appears on food and other products and services in the UK.

11.2 Most labelling schemes cover the environmental impacts for one kind of product, such as timber; or focus on one major environmental impact, like energy. A few schemes, like the EU Ecolabel, cover a range of environmental impacts for a wide range of product groups.

11.3 The key issue underlying such initiatives is the difference that the scheme is intended to make. The environmental benefits of voluntary green labels vary. Most provide a high environmental standard for producers to aim at, and there is evidence that this is important to manufacturers and retailers. If producers communicate a product's green credentials to consumers, the label may also help to raise awareness about environmental issues, and may change consumer behaviour in some cases by building up allegiance.

11.4 However, environmental labelling in itself appears to have limited impact on consumer choice at present. Defra feels that the environmental impacts of products need to be addressed in many other ways as well, as part of an overall strategy for improving key types of product.

— At a cross-cutting level, this involves for example promoting the development and use of standards and sound methodologies for assessing impacts (as for example Defra is currently doing in relation to the carbon footprint of products).

— At a sectoral level it involves engagement with industry to encourage good practice to reduce the environmental footprint of its activities (as for example with various Defra programmes in relation to the food sector, and further consideration being given to the development of integrated farm management).

— And at a product level it may more detailed engagement with the supply chain to agree specific improvements to the performance of products placed on the market (as for example with Defra's work on key energy-using products like domestic lightbulbs).

Defra is continuing to develop its strategy for raising the environmental performance of products and is planning to report on progress in Spring 2008.[19]

11.5 Defra does not regard the number of existing labelling schemes in itself as a major problem for consumers, because the development of such schemes has been mainly led by the market for a specific purpose, indeed sometimes with encouragement from Government for that purpose. A degree of choice between labels can help the many different interests in a very diverse market, and has resulted in some excellent schemes. Although there is now a large range of labels, the leading few are becoming better known to consumers, and their purpose seems generally understood. As with "brands" generally, promotion of different schemes is a matter for the label owners, but Defra can and does help by focusing the attention of domestic consumers and professional purchasers on the best schemes.

1 October 2007