sustainability Article Product Environmental Footprint (PEF) Pilot Phase—Comparability over Flexibility? V anessa Bach * ID , Annekatrin Lehmann *, Marcel Görmer and Matthias Finkbeiner Chair of Sustainable Engineering, Institute of Environmental T echnology , T echnische Universität Berlin, Strasse des 17. Juni 135, 10623 Berlin, Germany; [email protected] (M.G.); [email protected] (M.F .) * Correspondence: [email protected] (V .B.); [email protected] (A.L.); T el.: +49-30-314-27941 (V .B.); +49-30-314-79501 (A.L.) Received: 29 June 2018; Accepted: 13 August 2018; Published: 15 August 2018 Abstract: The main goal of the Eur opean pr oduct environmental footprint (PEF) method is to incr ease comparability of envir onmental impacts of products within certain pr oduct categories by decr easing flexibility and ther efore achieving r epr oducibility of r esults. Comparability is supposed to be further incr eased by developing product category specific r ules (PEFCRs). The aim of this paper is to evaluate if the main goal of the PEF method has been achieved. This is done by a compr ehensive analysis of the PEF guide, the curr ent PEFCR guide, the developed PEFCRs, as well as the insights gained fr om participating in the pilot phase. The analysis reveals that the PEF method as well as its implementation in PEFCRs ar e not able to guarantee fair comparability due to shortcomings r elated to the (1) definition of pr oduct performance; (2) definition of the product category; (3) definition and determination of the r epresentative pr oduct; (4) modeling of electricity; (5) r equir ements for the use of secondary data; (6) cir cular footprint formula; (7) life cycle impact assessment methods; and (8) appr oach to prioritize impact categories. For some of these shortcomings, recommendations for impr ovement are pr ovided. This paper demonstrates that the PEF method has to be further impr oved to guarantee fair comparability . Keywords: p r o d u c t e n v i r o n m e n t a l f oo t p r i n t ; PE F ; p i l o t p h a se ; L C A ; I S O 1 40 4 4 ; I S O 1 40 4 0 ; c o m pa r a b i l i t y ; comparative assertions 1. Introduction In 2013, the Eur opean Commission (EC) launched the communication “Building the Single Market for Gr een Products (COM (2013) 0196 final)” [ 1 ] and the r ecommendation “On the use of common methods to measur e and communicate the life cycle environmental p erformance of pr oducts and organizations (2013/179/EU)” [ 2 ]. The main goal of the so-called pr oduct environmental footprint (PEF) method [ 2 ] is to incr ease comparability between pr oducts of the same product category (and ther efore also allow for comparisons and comparative assertions) applying the “comparability over flexibility” appr oach, meaning that by reducing the flexibility of methodological choices the comparability of pr oducts increases [ 3 , 4 ]. The increased comparability was expected to be achieved by pr edefining specifications for certain methodological aspects based on value choices (e.g., modeling of the end-of-life phase), and thus r educing the flexibility for which ISO 14040/44 [ 5 ] (the international agr eed upon standard for life cycle assessment—LCA) is known for . Furthermor e, by developing pr oduct category specific rules (PEFCRs) for certain pr oduct categories, additional specifications ar e determined [ 2 ]. Comparisons ar e carried out, when competing products that perform the same function ar e compar ed regar ding their envir onmental performance [ 6 , 7 ]. Comparative assertions ar e carried out, Sustainability 2018 , 10 , 2898; doi:10.3390/su10082898 www .mdpi.com/journal/sustainability Sustainability 2018 , 10 , 2898 2 of 18 when a statement—an envir onmental claim—is made regar ding the superiority or equivalence of one pr oduct versus a competing product that performs the same function [ 7 ]. T o better understand the dif ferences and similarities between the PEF method [ 2 ] developed by the EC and the PCR concept based on ISO 14040/44 [ 5 , 7 ] an overview is pr ovided in Figure 1 . ISO 14040/44 is the basis for ISO 14025 [ 8 ] as well as for the PEF guide [ 2 ]. However , it should be noted that the PEF guide is not conform with ISO 14040/44, and even partly contradicting [ 9 ], e.g., PEF allows for comparisons and comparative assertions based on normalized and weighted r esults, which is explicitly excluded in ISO 14040/44. Based on ISO 14025, product category rules (PCRs) ar e developed, which provide detailed r ules on how to model the life cycle of a specific product of a pr oduct category—i.e., groups of pr oducts that ar e able to fulfill equivalent functions. Based on the PCR, envir onmental product declarations (EPD) can be carried out, which can be seen as specific case studies of pr oducts within the considered pr oduct category , following the rules pr ovided within the associated PCR. PEFCRs can be seen as the PEF version of PCRs, i.e., they are r ules complementing and specifying the PEF guide [ 2 ] and the PEFCR guide [ 6 ] for the consider ed product categories. The PEFCR guide is the guidance document of the PEF pilot phase and was updated several times during the pilot phase: overall, seven versions wer e published, starting with version 3.4 in February 2014 and concluding with version 6.3 in December 2017. Based on existing PEFCRs, PEF studies can be carried out, which can be used for comparison and comparative assertions [ 2 , 6 , 10 ]. PEF studies for internal use analogues to LCA studies can be carried out based on the PEF guide only . Sustainability 2018 , 10 , x FOR PEER REVI EW 2 of 18 when a state m ent—an en vironmental c l aim—is mad e regardin g the superiorit y or equiv a lence of on e product versus a competing product th at perform s t h e same funct i on [7]. To better understand the d i ffer e nces and similari tie s b e tween the PEF method [2] develope d by the EC and t h e PC R conc ept base d on ISO 14040/ 44 [5,7] an over view is pr ovided in Figur e 1. ISO 14 0 40/ 44 is t h e bas i s fo r IS O 14 0 25 [ 8 ] a s wel l a s for t h e PEF g u i d e [2 ]. How e ver , it shou ld be not e d tha t the PEF guide i s not conf orm wi th ISO 14 040 /44 , and even partly contradicting [9], e . g., PEF al lows for co mparison s an d compar at iv e a ssert ions based on norm al iz ed and we ight ed res u lt s , which i s expl i c i t l y excl uded i n IS O 1 404 0 /44. Ba sed on IS O 1 402 5, product ca tegory rul e s ( P C R s) a r e developed, w h ich prov ide detailed rules on how to mo del the life cyc l e of a specific product of a product c a t e g o ry—i .e. , g r o u ps o f pro d u c t s t h at are a b le t o fu lf il l e q u i va lent fun c t i ons. Ba sed on t h e PCR, environ m ental pro d uct declar a tion s (EPD) c a n b e ca rrie d o u t , which c a n be seen as spec if ic c a s e studie s of pro d ucts with in the consider e d product c a tegory, fo llow i ng the r u le s provided w i thin the assoc i ated PC R. PEFC Rs c a n be seen as t h e PEF ve rs io n of PCRs , i.e ., t h ey are ru l e s compleme nt ing and spec ify in g the PEF guide [2] an d the PEFCR g u id e [6] for the c o nsider ed pr oduct categor i es. The PEFCR guide is the guid anc e document o f the PEF pilo t phase an d w a s updated se veral tim e s d u ring the pilot phase: overall, se ven versions were p u bl i s h ed, st art i n g wit h vers ion 3. 4 in Feb r ua ry 2 0 1 4 and concl u di ng w i t h ver s i o n 6. 3 in Dec e m b er 20 1 7 . Base d on ex is ting PEFC Rs, PE F stud ies can be carr ied o u t , which c a n be use d fo r co mparison an d compar at iv e a ssert ion s [ 2 , 6 , 1 0 ] . PEF s t udies for int e rna l u s e a n alog ue s t o L C A st ud ies ca n be ca rrie d o u t base d on t h e PEF gu ide only. Figure 1. Com p arison of PEF method [2] a n d the PC R co ncept base d o n ISO 14040/44 [5,7] (own figure). In November 201 3, the PEF pil o t pha s e was la un ched to test the PEF method a n d to develop PEFCRs f o r sel e cted product ca tegori es. The f i r st wa v e sta r ted wi th 1 4 non-f ood products ( b a t teri es and accum u lators, decor ative paint, fo otwear, ho t and co ld w a ter pipes, ho useho l d dete r gents, intermediate paper pro d uc ts, IT equi pm ent, l e a t her, meta l sheets, photovol ta i c el ectri c i t y genera ti on, t h ermal in su lat i on , T - sh ir t s , unint e rr u p t i ble power s u pplie s; di scont i nued : s t at ionar y ) an d w a s complemented in 2014 w i th the secon d wave o f 11 foo d prod ucts (bee r, d a ir y, feed fo r food - producing a n imals, pasta , pa cked wa ter, pet food, olive oil, w i ne; discontin u ed: coffee, mar i n e fish, meat ). Th e p ilot project s were chosen by t h e EC b a sed on cr it e ria su ch a s d i vers it y of pr oduct cat e gor i es co vered and av ai lab i l i t y of g ood qu a lit y s e condar y l i fe cycle d a t a [ 1 1] . The p i l o t p h ase ended in Apr i l 2018 with only 10 p ilot projects (d air y , d e corat i ve paint s , feed for food-pro ducin g anim al s, IT e q u i p m ent , le a t her, p a cked wat e r, p a st a, p e t food , r e ch arge ab le b a t t e ries , and w i ne) ab l e to provi d e fi na l PEFCR s [ 1 2 ] due to delays wi thi n the pi l o t pha s e. For some of the other p i l o ts—e.g., househo l d d e tergents or intermediate paper pr od ucts—PE F CRs ar e expect ed to be publishe d throughout t h e ye ar 2018. Now, the tra n si ti on pha s e ha s sta r ted, whi c h wil l la st until the en d o f 2021. It aims at monitorin g the impleme n tation of the existing PEF C Rs, the dev el opment of new PEFCRs as well a s fi ne tu ni ng Figure 1. Co m pa ri s on o f PE F m et h od [ 2 ] an d t he P CR c o nc ep t b as e d on I SO 1 4 04 0 /4 4 [ 5 , 7 ] (o w n fi gu r e ) . In November 2013, the PEF pilot phase was launched to test the PEF method and to develop PEFCRs for selected pr oduct categories. The first wave started with 14 non-food pr oducts (batteries and accumulators, decorative paint, footwear , hot and cold water pipes, household detergents, intermediate paper pr oducts, IT equipment, leather , metal sheets, photovoltaic electricity generation, thermal insulation, T -shirts, uninterruptible power supplies; discontinued: stationary) and was complemented in 2014 with the second wave of 11 food pr oducts (beer , dairy , feed for food-producing animals, pasta, packed water , pet food, olive oil, wine; discontinued: coffee, marine fish, meat). The pilot pr ojects wer e chosen by the EC based on criteria such as diversity of pr oduct categories covered and availability of good quality secondary life cycle data [ 11 ]. The pilot phase ended in April 2018 with only 10 pilot pr ojects (dairy , decorative paints, feed for food-producing animals, IT equipment, leather , packed water , pasta, pet food, r echar geable batteries, and wine) able to provide final PEFCRs [ 12 ] due to delays within the pilot phase. For some of the other pilots—e.g., household detergents or intermediate paper pr oducts—PEFCRs are expected to be published thr oughout the year 2018. Sustainability 2018 , 10 , 2898 3 of 18 Now , the transition phase has started, which will last until the end of 2021. It aims at monitoring the implementation of the existing PEFCRs, the development of new PEFCRs as well as fine tuning of methodological aspects of the PEF method and the PEFCR guide. W ithin the transition phase, it will be discussed what potential futur e applications PEF and the PEFCRs could have. Numer ous experts and stakeholders were involved in the pilot phase including companies and industry association, nongovernmental or ganizations, academia, the EC, the member countries (r epresented within the steering committee (SC)), and the technical advisory boar d (T AB), which consisted of experts supporting the SC and pr oviding technical advice related to the ongoing pilot pr ojects as well as to overall issues related to PEF and LCA [ 6 , 10 ]. Due to the combined ef fort of these stakeholders several positive outcomes of the PEF pilot phase can be observed: some sectors particularly fr om the food industry have started to apply LCA—or rather PEF—and challenges r elated to methodological and practical requir ements of LCA wer e discussed amongst a variety of stakeholders leading for instance to an improved and updated life cycle impact assessment (LCIA) method for toxicity impacts [ 13 ]. Furthermor e, several pr oduct category rules (or rather PEFCRs) wer e developed for new product categories (e.g., beer). Some of the methodological and practical challenges of the PEF method mentioned in pr evious publications (e.g., [ 3 , 4 , 9 , 10 , 14 ]) wer e tackled, e.g., by introducing mor e matur e LCIA methods for the categories water use (for which now the A W ARE method [ 15 ] is r ecommended), land use (for which now the LANCA method [ 16 ] is r ecommended), particulate matter (for which now the method by Fantke [ 17 ] is r ecommended) and resour ce use (for which now the ADP method based on ultimate r eserves [ 18 , 19 ] is r ecommended) [ 2 , 6 ]. Furthermore, workshops wer e or ganized and cr oss cutting working gr oups were established to discuss issues like the modeling of the end-of-life (EoL) phase. Thus, on the one hand, it should be acknowledged that PEF picked up these topics providing a platform for an exchange of opinions and discussions. However , on the other hand, the amount of resour ces spent in the pilot phase wer e extremely high and several methodological and practical challenges of the PEF method and the developed PEFCRs still exist. These challenges have been alr eady addr essed in several publications by the authors of this paper [ 4 , 9 , 10 , 20 ], but also by industry [ 3 , 21 ] as well as policy makers [ 22 ]. The main goal of this paper is to analyze if the adapted PEF method [ 2 ] (as shown in the curr ent PEFCR guide [ 6 ]) as well as the established PEFCRs allow for comparability , especially comparisons and comparative assertions. As accor ding to the PEF method, comparability can be achieved by r educing flexibility [ 2 ], it is examined if this claim is supported by the developed PEFCRs [ 12 ] and the curr ent PEFCR guide [ 6 ]. Our main concern is that the defined r ules of the PEF method, the PEFCR guide and the existing PEFCRs—thus, the r educed flexibility—do not guarantee r eliable comparability , which is the main goal of the PEF method. The PEF pilot phase is analyzed and remaining challenges ar e discussed. Furthermor e, recommendations ar e pr ovided to support a successful implementation of PEF and the developed PEFCRs. In the following, the pr ocedure how the analysis is carried out is intr oduced (Section 2 ) and existing challenges of the PEF method and PEFCRs impeding fair comparisons and comparative assertions ar e discussed as well as recommendations for impr ovements ar e provided (Section 3 ). Finally , conclusions are drawn (Section 4 ). 2. Materials and Methods A compr ehensive evaluation of the entire PEF pilot phase of almost 4.5 years (November 2013 to April 2018) was carried out. The following documents wer e taken into account: • Pr evious work and publications of the authors (e.g., [ 9 , 10 , 23 ]) • Other existing publications r elated to PEF (e.g., [ 14 , 24 – 26 ]) • All available documents developed within the pilot phase: # All dif ferent versions of the 21 developed PEFCRs: scope definition, 1 draft PEFCR, and 2 draft PEFCRs (with up to 100 pages); # Final PEFCRs for 10 pilots (with up to 150 pages); Sustainability 2018 , 10 , 2898 4 of 18 # Scr eening study reports (with up to 200 pages) for all 21 pilots: scr eening studies ar e the PEF studies for the specific r epresentative pr oducts of a pr oduct category . Their goal is to determine the r elevant environmental impacts (as well as life cycle stages, pr ocesses, and elementary flows) of the consider ed product categories and ther efor e define the specifications of each PEFCR, e.g., when to use primary and when secondary data. The r esults of the screening study also serve as the basis for the benchmark, as the r epresentative pr oduct is automatically set as Class C (e.g., when assuming an A–F scale, with ‘A ’ indicating the best and ‘F’ the worst performance). # V arious issue papers (e.g., [ 27 , 28 ]) addr essing topics like modeling of electricity . Issue papers ar e publications by the EC regar ding summaries of the state of the art as well as pr oposals for solving methodological challenges. They served as the basis for discussions in the T AB. # Seven versions of the PEFCR guide pr ovided by the EC over the course of the pilot phase (the PEFCR guide was adapted accor ding to the outcomes of the pilot phase, e.g., pr edefining more matur e LCIA methods), focusing on the latest version (6.3) [ 6 ]. Besides this, the authors have been actively taking part in the PEF pilot phase as stakeholder in some pilot projects and as T AB member participating in almost all T AB as well as joined SC/T AB meetings. Thus, the authors were able to gain dir ect insight into the or ganization and outcomes of the pilot phase. A compr ehensive analysis was carried out to identify the still-existing challenges of the PEF method. These challenges ar e analyzed with regar d to futur e application options of PEF , which are: • Internal implementation: applying the PEF method for internal pr oduct/process impr ovement • Business-to-business (B2B) communication: comparisons of pr oducts based on a PEF report • Business-to-consumer (B2C) communication: comparisons and comparative assertions of products based on labels [ 6 ] Wher e possible also examples are pr ovided to illustrate the challenges described. The results of this compr ehensive analysis of the pilot phase including recommendations for impr ovement are pr esented in the following section complementing the findings of previous publications. 3. Results and Discussion Several methodological and practical challenges wer e identified with regar d to PEF being able to guarantee fair comparability by r educing flexibility . They include (1) definition of scope (definition of the pr oduct performance with the functional unit, dif ferentiation of pr oducts by defining the pr oduct category and the repr esentative pr oduct); (2) the modeling of the life cycle of a product (modeling of electricity , use of secondary data, modeling of EoL allocation); and (3) impact assessment and interpr etation (applicability and reliability of impact assessment methods and prioritization of impact categories by normalization and weighting). In the following, these challenges ar e explained in detail and r ecommendations are pr ovided for how to solve them. However , it should be pointed out that r ecommendations cannot be provided for all shortcomings—simply because for some of them adequate solutions ar e currently not available. 3.1. Definition of Scope 3.1.1. Definition of Pr oduct Performance The PEF method intr oduced a new approach to determine the functional unit: it has to be defined answering the four questions: ‘what’, ‘how well’, ‘how much’, and ‘how long’. By pr oviding such detailed r equirements, the flexibility pr ovided by ISO 14040/44 is r educed. However , even though the idea of giving mor e guidance for defining the functional unit is good, it was proven to be challenging to Sustainability 2018 , 10 , 2898 5 of 18 define the functional unit considering these r equirements. Several pilots did not address them pr operly in their PEFCRs nor did they provide a functional unit able to allow for fair comparability . Especially the definition of ‘how well’, which shall be used to describe relevant quality/performance aspects of the pr oduct (e.g., washing performance of detergents) is often not carried out pr operly . This is relevant in or der to allow for fair comparability , because only products based on the same performance/with the same quality shall be allowed to be compared. Curr ently , the performance/quality of the analyzed pr oduct is not adequately taken into account in any of the finalized PEFCRs, because ‘how well’ a pr oduct performs is not properly addr essed: for one thing, the functional unit is not defined adequately , but also standar dized tests to check if the defined performance/quality can be fulfilled by the specific pr oduct are not available or declar ed. For example: The pilot ‘feed for food pr oducing animals’ defines the functional unit as 1 kg feed without considering any quality aspects such as metabolizable ener gy , which is a relevant decision factor for farmers to choose a certain type of feed [ 29 , 30 ]. That means, that possibly two feeds (A and B) can be compar ed, which have differ ent performance/quality aspects, e.g., feed A has mor e kilocalories of metabolizable ener gy (kcal ME) than feed B. However , it might be possible that the higher amount of kilocalories is r elated to higher environmental impacts. The consumer —e.g., farmer or a company—who buys feed B based on its better envir onmental pr ofile ends up using more feed to r each the same caloric requir ement as with feed A. Ther efor e, the use of feed B leads to mor e envir onmental impacts. This example shows that without considering the performance of pr oducts, their comparison may lead to incentivizing pr oducts with a worse environmental performance compar ed to its alternatives. W e r ecommend the following: for internal application the pr oduct performance does not have to be tracked as it can be assumed that the company makes sur e that the performance/quality of the pr oduct is consistent. However , for B2B as well as B2C communication, the performance of a pr oduct of a specific pr oduct category are r elevant factors. T o allow for fair comparability , the functional unit has to be defined in a way , that performance/quality aspects (e.g., meet daily caloric and nutritional r equirements) ar e included. Furthermor e, parameters to measur e these performance/quality aspects (e.g., kilocalories of metabolizable ener gy , type of protein, water content, etc.) have to be taken into account and standar dized methods assessing if every product of the pr oduct category fulfills the r equirements have to be set up. 3.1.2. Definition of the Pr oduct Category Accor ding to PEF , the pr oduct category has to be defined based on the Classification of Products by Activity code [ 31 ] (CP A code) [ 6 ]. Thus, by determining the pr oduct category , products that ar e deemed to be comparable alternatives ar e defined. The definition of a pr oduct category based on the CP A code r educes the flexibility provided by ISO 14025, but does not contribute to incr ease comparability . It was shown in the pilot phase that the use of CP A codes to adequately set up pr oduct categories is challenging [ 32 ]. Thus, the EC analyzed possible principles (e.g., consumer ’s perspective, similarity of pr oducts, similarities of rules, etc.), which could be applied to define an appropriate pr oduct category [ 32 ]. However , even though this analysis has contributed to the overall understanding of the challenge, it did not solve it. W ithin the pilot projects the pr oduct categories ar e inconsistently defined: they range fr om very narrow (e.g., heavy duty liquid laundry deter gents) to very br oad (e.g., beer). Curr ently , the definition of the product category of several of the final PEFCRs does not allow for suf ficient differ entiation of pr oducts, which is r equir ed for meaningful comparisons. The definition of the functional unit is closely linked to the challenge of defining the pr oduct category , because in both cases the pr oducts which ar e able to be compared are defined. The curr ent appr oach does not consider comparability fr om a consumer point of view , because a consumer for instance may pr efer to know whether it is better fr om an environmental perspective to buy a liquid or a powder deter gent, but who may not be inter ested in comparing e.g., a wheat beer with a mixed beer . Sustainability 2018 , 10 , 2898 6 of 18 W e r ecommend the following: For internal application, thus optimization of pr oducts and pr ocesses, there is no need to define a pr oduct category . For B2B and B2C communication a suitable appr oach to consistently define product categories is r equir ed to allow for a clear dif ferentiation of pr oducts as well as fair comparability . W e think that using the CP A code alone is not adequate to set up pr oduct categories. However , the CP A code could be one of the aspects considered for determining an adequate method to define the pr oduct category . For this challenge curr ently no ready-to-go solutions ar e available and further resear ch is needed to tackle it. Therefor e, the ECs ef fort to find mor e adequate solutions in the transitioning phase [ 33 ] is appr eciated as well as necessary to allow for fair comparability . 3.1.3. Definition of the Repr esentative Product The aim of establishing a r epresentative pr oduct (RP) is to define the average envir onmental performance of the products (of the pr oduct category) sold in the EU market. Based on the RP model, the most relevant life cycle stages, pr ocesses, elementary flows, impact categories, and data quality needs ar e identified. The RP is further used as a standard or point of r efer ence against which comparisons can be made [ 6 ]. The concept of the RP is a new one which has been established by the PEF method [ 2 ]. The RP is either a r eal pr oduct, which reflects the envir onmental impacts of the entir e considered pr oduct gr oup or a virtual one (which does not exist in r eal life) established based on the economic or mass r elated market average for the consider ed product category . In both cases, the RP aims at displaying the average envir onmental impacts of the entire pr oduct category . As the r epresentative pr oduct is defined based on market shar es, the envir onmental impacts of the RP do not necessarily r epresent the average envir onmental impacts of this pr oduct category . This is further illustrated by two examples in T able 1 . W e want to state that this example should mer ely show that setting up a method to determine the RP is challenging and other aspects besides the market shar e of products may be taken into account. The product category consists of two pr oducts (A and B) with a differ ent market shar e and a dif fer ent individual environmental performance (her e exemplarily expressed in CO 2 eq.). For both examples, it is assumed that Pr oduct A has a small market shar e (10%), while Pr oduct B has a high market share (90%). In Example 1, Pr oduct A has a small environmental impact (1 kg CO 2 eq.) and Pr oduct B has a high environmental impact (10 kg CO 2 eq.) . If the average envir onmental impact of the product category is calculated as arithmetic average, it would be 5.5 kg CO 2 eq. If it is calculated based on the r epr esentative product appr oach (defined based on the market share), the average environmental impact of the pr oduct category would be 9.1 kg CO 2 eq. It can be seen that the average environmental impact is much higher when it is calculated based on market shar es. The benchmark is dominated by Pr oduct B, which has a high market shar e and high environmental impacts. In Example 2, it is assumed that Product A has a high envir onmental impact (10 kg CO 2 eq), while Pr oduct B has a small environmental impact (1 kg CO 2 eq) . If the average envir onmental impact is calculated based on the RP appr oach, it would be 1.9 kg CO 2 eq. and ther efore lower compared to the impact based on arithmetic average (which is 5.5). Comparing these results, the average envir onmental impacts of the RP dif fer . Therefor e, based on how the RP is set up, the determined benchmarks differ and consequently the incentives and steering ef fects they have for the market. T able 1. A verage environmental performance of Pr oducts A and B, calculated based on the market share (r epr esentative pr oduct) and as arithmetic average. Product & Market Share Example 1 Example 2 Environmental Performance (kg CO 2 eq.) Environmental Performance (kg CO 2 eq.) Individual Arithmetic A verage Representative Product Approach Individual Arithmetic A verage Representative Product Approach A (10%) 1 (1 + 10)/2 = 5.5 (0.1 × 1) + (0.9 × 10) = 9.1 10 (10 + 1)/2 = 5.5 (0.1 × 10) + (0.9 × 1) = 1.9 B (90%) 10 1 Sustainability 2018 , 10 , 2898 7 of 18 Another challenge r egarding the curr ent definition of the RP is that certain assumptions ar e made in its bill of materials (BoM) that can lead to over - and/or under estimations of environmental impacts. When e.g., additives ar e considered by their maximum dose allowed as done in the beer pilot, over estimations in the RP can occur . This would lead to the fact, that r eal pr oducts would perform better , because most of them do not use the maximum dose allowed. Underestimations in the RP can occur , when not all substances/materials that have environmental impacts ar e included in the BoM. This leads to the fact that r eal products would perform worse, because they utilize certain substances/materials. In both cases, the established benchmark (based on the RP) cannot be used to compar e the performance of real pr oducts of the consider ed pr oduct category . Due to these two challenges, real pr oducts might perform better than the benchmark. In fact, it was often observed in the supporting studies (i.e., studies with r eal products carried out in the pilot phase) that most of the analyzed pr oducts perform much better than the benchmark. The question is, if this r eally means that the pr oducts analyzed in the pilot studies are in fact ‘gr eener ’ than the market average or if this rather implies that the defined RP is not that r epresentative and cannot guarantee fair comparison and comparative assertions. W ith setting up a RP very strict rules ar e established with r egard to how the benchmark (class C) is defined. It was shown that based on how the RP is calculated (based on the market share or as arithmetic average) as well as how the BoM is defined, the benchmark r esult can vary significantly and ther efore also the steering ef fect it has on the market. As the definition of the RP depends on the application of PEF , we r ecommend the following: for internal application, the use of a RP is not needed. For B2B and B2C communication it is necessary to allow for a clear dif ferentiation of pr oducts. As shown above to achieve the desired ef fect for the market (pr omotion of products with less envir onmental impacts and ther efor e, incentives for companies to impr ove their products) it seems as determining the r epr esentative envir onmental impacts based on the actual average might be mor e suited, at least when the market is dominated by products with rather high envir onmental impacts (as shown in T able 1 ). On the other hand, for tracking the overall impacts of the Eur opean market over time, the market-average seems more appr opriate. Thus, the RP appr oach needs to be revised. Currently , no r eady-to-go solution is available and further r esearch is needed. Ther efor e, the EC’s effort to find mor e adequate solutions in the transitioning phase [ 34 ] is appr eciated. Alternatives to the concept of setting a benchmark could be discussed. Instead of using the RP for setting the benchmark, the best performing product on the market could be used as the benchmark. That would serve as the strongest incentive to impr ove the envir onmental performance of pr oducts on the market. 3.2. Modeling the Life Cycle of a Pr oduct 3.2.1. Modeling of Electricity The PEFCR guide clearly defines which electricity mix shall be used for modeling [ 6 ]. If possible, the electricity mix shall always be modeled by using the company specific mix. If the company mix is not available, the mix of the electricity supplier shall be used. If this information is not available, the country specific mix shall be applied. The use of the EU mix is not foreseen [ 6 ]. W ithin ISO, no clear rules ar e pr ovided r egarding the electricity mix used in the model, just that the choice has to fit the scope [ 7 ]. In most PEFCRs, country specific electricity mixes ar e used, because it is believed these r eflect the real impacts of a particular pr oduct as closely as possible. The r eduction of flexibility which electricity mix to use does not necessarily increase comparability of pr oducts. For example: for a pr oduct/material produced in Poland the Polish electricity consumption mix is applied, wher eas the French electricity mix is used for pr oducts/materials pr oduced in France. Thus, companies in countries with coal-based electricity mixes like Poland always perform worse (e.g., in the impact category climate change) than companies in countries using nuclear power like France. However , just because a company is located in a specific country does Sustainability 2018 , 10 , 2898 8 of 18 not necessarily mean they use the country’s electricity mix. For companies in the for eground system, wher e the electricity mix is known, there is no need to apply the country mix, as also stated by the PEF method. However , the electricity mix of companies along the supply chain and life cycle of the product is often not known due to missing data. Thus, it would rather be to the company’s disadvantage to assume they use the country’s electricity mix. For example, a company in Poland which puts ef forts in improving the envir onmental performance would be disadvantaged compar ed to a company in France, because of the electricity mix which is outside the control of the company carrying out the study . Similarly , companies located in countries wher e, e.g., renewable ener gy is subsidized would be advantaged. By using the Eur opean electricity mix for all companies, for which the electricity mix is not known, these disadvantages and advantages would not occur , because for all companies the same electricity mix is applied. Ther efore, we r ecommend using the pur chased electricity mix of the company carrying out the study for modeling. For companies within the supply chain, for which the company carrying out the study does not know the pur chased electricity mix, the EU mix should be applied to allow for fair comparisons and comparative assertions. Furthermor e, for internal application the PEFCR guide [ 6 ] can be followed and data for company or country specific electricity mixes can be applied. When B2C communication is the intended application, the EU electricity mix or the actually purchased mix by the company should be used. For B2B communication (based on a detailed PEF r eport) the PEFCR guide can be followed and data for company specific electricity mixes can be used, because it is transpar ently communicated which electricity mix is modeled. Furthermor e, if a country-specific electricity modeling is foreseen for certain applications, all other unit pr ocesses and data have to be based on country-specific data as well—i.e., country specific material pr oduction data, packaging data, use data, and end-of-life data—for consistency reasons. None of the pilots followed a consistent appr oach in this regar d. 3.2.2. Use of Secondary Data Each PEFCR has to specify for which pr ocesses primary (i.e., specific) or secondary (i.e., average or pr oxy) data have to be used. W ithin existing PCRs the need for primary specific data is also defined as well as for which pr ocesses/materials secondary data can be applied. If secondary data ar e used for certain pr ocesses, e.g., for material acquisition, diff erences of these pr ocesses cannot r eflected in the modeling of the pr oducts. That means, that producers buying materials with high envir onmental impacts would be r ewarded, because the r eal envir onmental impacts of their materials ar e not taken into account if average data instead of their worst specific data is used. Conversely , producers buying materials with low impacts are at a disadvantage, because the r eal envir onmental impacts of their materials cannot be accounted for . For example, if a material is modeled with specific data reflecting, e.g., best available technologies (BA T), the environmental impacts ar e significantly lower than if the average import mix of the material is used. Thus, by decr easing the flexibility r egarding the use of primary data, fair comparability is no longer guaranteed. Thus, we recommend the following pr ocedure: for internal application, the use of secondary data for certain materials and pr ocesses does not pr esent a challenge, because it is assumed that the company defines primary data when necessary to identify the full optimization potential of their product/pr ocess. For B2B and B2C communication, modeling with default secondary data is challenging particularly when secondary data is used for materials/pr ocesses, which are identified as r elevant (as curr ently done in several PEFCRs). Thus, we r ecommend that more specific data is pr ovided by the EC for the r elevant pr ocesses within the product life cycles or that all datasets ar e designed in a way that they can be specifically adapted to reflect company-specific aspects. 3.2.3. Modeling of EoL Allocation with the Cir cular Footprint Formula W ithin the PEF method [ 2 ] the EoL formula, published in 2013, was introduced to standar dize the allocation of bur dens and benefits in the EoL stage and thus to enhance comparability of differ ent Sustainability 2018 , 10 , 2898 9 of 18 pr oduct systems. It deals with multi-functionality in recycling, r e-use, and ener gy r ecovery situations. It considers the bur dens of virgin material acquisition and pr e-pr ocessing, of the recycled material input, of the recycling (or r e-use) pr ocess, of the energy r ecovery pr ocess as well as of the disposal. Overall, 17 parameters are consider ed, describing e.g., quality of primary and secondary material, lower heating value, recycling fraction of material. All these parameters as well as the entire EoL formula ar e explained in detail in the PEF guide [ 2 ]. The formula led to many discussions due to its obvious shortcomings (e.g., pr omotion of energy r ecovery of materials) [ 6 , 34 ]. T owar ds the end of the pilot phase, a new formula—the cir cular footprint formula (CFF)—was introduced [ 6 ]. It considers the pr oduction burdens, the bur dens and benefits r elated to secondary material inputs as well as outputs, bur dens and benefits of energy r ecovery as well as of disposal. The CFF also considers 17 differ ent parameters, which differ fr om the original EoL formula, e.g., the A factor , which allocates bur dens and cr edits between two life cycles is introduced. The CFF is explained in detail in the current PEFCR guide [ 6 ]. An advantage of this formula is that it no longer arbitrarily favors incineration of materials over r euse and recycling. However , several challenges with regar d to ensuring fair comparability exist also for the CFF . W ithin ISO, no formula or appr oach is defined to model the EoL stage. By decr easing the flexibility with r egard to modelling the EoL phase and pr oviding a formula, which has to be applied within every pr oduct model, PEF actually reduces fair comparability instead of incr easing it. The following shortcomings demonstrate this: • How often a material is r ecycled is not considered. Hence, a material that is r ecycled once gets the same bur den/credit as a material that is r ecycled several times. Only for packaging material is an exception made as the bur den of the virgin material is divided by the number of r ecycling cycles. • The default data pr ovided for the quality term (quality of primary material related to quality of secondary material) is not adequate: for all metals, the same value of 1 is assigned, even though secondary metal qualities dif fer significantly . Furthermor e, for most plastic materials (high-density polyethylene, polypropylene, polyethylene terephthalate; except of low-density polyethylene film) a value of 1 is assigned as well, even though plastic is usually down-cycled, meaning that secondary material usually does not r each the same quality as the virgin material. For some materials (e.g., paper , plastic) the quality of the secondary material even depends on the original use. For example: for paper only one quality term is pr ovided, but printing paper is usually r ecycled to printing paper with equal quality , which is not possible for glossy paper of magazines. • The newly intr oduced parameter A ranges between 0.2 and 0.8 and is supposed to reflect the curr ent market situation (e.g., 0.2: low supply/high demand; 0.8: high supply/low demand). Thus, the CFF is in conflict with ISO 14044 for closed loop systems, because only 80% of the cr edits can be given with CFF , wher eas ISO allows that 100% of the cr edits are allocated to the pr oduct system. Even though the company is mor e aware of the value choices made in the CFF , we r ecommend that the CFF is applied with caution. For B2B and B2C communication, we r ecommend not using the CFF due to its many bias assumptions. Therefor e, we recommend to r eview and r evise the quality terms and allocation factors and to consider r euse rates for all materials and products. One simple solution to impr ove the CFF would be to adapt the specifications of ISO for closed loop recycling. 3.3. Impact Assessment and Interpr etation 3.3.1. Applicability and Reliability of Life Cycle Impact Assessment Methods The PEF method pr edefines 17 LCIA methods. W ithin ISO 14040/44 no methods ar e r equir ed to be applied. Existing PCRs often set a minimum requir ement of categories to be consider ed and sometimes also pr edefine LCIA methods to be used. However , it is allowed to apply a variety of methods when r equested by the user of the PCR. By decr easing the flexibility of the users to choose their own categories and methods, fair comparability is rather decr eased than incr eased as demonstrated in the following. Sustainability 2018 , 10 , 2898 10 of 18 Implicit W eighting of Impact Categories The granularity of the impact categories is inconsistent and therefor e leads to implicit weighting. For the evaluation of land use, only one impact category is considered with five sub-categories (or five indicators), whereas impacts of eutr ophication ar e addr essed in three categories (eutr ophication, marine; eutr ophication, freshwater; eutr ophication, terr estrial). Implicit weighting may also distort the normalized and weighted results, because existing weighting schemes pr ovide thr ee weighting factors for eutr ophication, whereas land use is only consider ed once. Therefor e, we r ecommend r econsidering the current str uctur e of the impact categories of eutrophication, acidification, r esour ces, and toxicity and to cluster them the same way it is pr oposed for land use to increase consistency and avoid implicit weighting. A vailability of Inventory Data As most life cycles ar e global, the applied LCIA methods should also have a global perspective. This means that r egionally derived characterization factors (CFs) should be used when CFs are available for most r egions worldwide and regionalized inventory data can be applied. If this is not the case as curr ently for most of the considered impact categories, global average CFs should be used instead of Eur opean average or country specific CFs. The importance of the use of such global average CFs is illustrated in the following two examples: (1) The A W ARE method [ 16 ] for the category water scarcity pr ovides CFs for several countries and has to be applied with r egionalized inventory data. W ithin the pilot phase, the pilots applied Eur opean average water scarcity factor for all inventory data (even for pr ocesses taking place outside of Eur ope). This is contrary to the basic idea of water scarcity appr oaches, namely to identify those pr oduction locations where water consumptions lead to the highest impacts [ 35 – 37 ]. By determining how impacts of water depletion have to be assessed, the PEF reduces the flexibility of ISO 14046. By not using r egionalized CFs and inventory data, fair comparability is not guaranteed. Thus, we r ecommend applying r egionalized inventory data and r egionalized CFs for the category water depletion. Not for all secondary data, r egionalized inventory data are available yet [ 38 , 39 ]. However , we recommend that within upcoming calls for data by the EC, the implementation of r egionalized water inventory flows should be a requir ement. (2) The CFs of the categories acidification and eutr ophication ar e based on European fate models [ 40 – 42 ] and thus ar e only valid for evaluating European based pr ocesses. However , within the pilot phase the CFs wer e applied to assess all processes (inside and outside of Eur ope). As eutr ophying and acidifying emissions are r egulated dif fer ently worldwide (e.g., strictly within Eur ope since the 80-ies [ 43 ] and har dly or not in emerging countries like China [ 44 ]) such an application of Eur opean based regionalized CFs is not adequate. As the CFs of the predefined LCIA methods ar e based on European specific fate models, the amount of emissions emitted into the envir onment in Europe is consider ed. Based on the emitted amount the CFs vary as shown by Seppälä et al. [ 42 ]. By r educing the flexibility to apply LCIA methods appr opriate for the available inventory data, fair comparability of pr oduct systems is reduced. Thus, we r ecommend to apply r egionalized inventory data for regionalized methods, at least for the r elevant pr ocesses. If these data ar e not available for some methods like acidification and eutr ophication, we recommend to apply global LCIA methods. Furthermor e, inventory data of the category particulate matter (PM) are often not r eliable due to dif ficulties in measuring PM2.5 [ 45 , 46 ]. The newly developed LCIA method for PM [ 17 ] covering PM2.5 emissions is classified by PEF as with a Level 1 maturity , thus considered as very r obust. However , as inventory data for PM2.5 is missing, the determined results cannot be consider ed as r eliable as the Level 1 classification implies. Classifying the method for PM as Level I means that it gets a higher weight in the weighting system (accor ding to the appr oach by the EC [ 28 ]). Thus, we Sustainability 2018 , 10 , 2898 11 of 18 r ecommend to decrease the rating for this category to better r eflect the uncertainties of the PM2.5 inventory data in the curr ent weighting set. Arbitrary Exclusion of Impact Categories During the pilot phase, the EC decided that all thr ee toxicity categories (human toxicity , cancer; human toxicity , non-cancer; ecotoxicity , freshwater) ar e excluded fr om any communication and cannot be chosen as r elevant impact categories due to high uncertainties in the results. However , their exclusion can lead to bur den shifting, i.e., when the impact categories, which are communicated, ar e improved at the expense of the excluded ones. Thus, by decr easing the flexibility to choose these methods as r elevant ones, fair comparability is decreased. W e therefor e r ecommend considering the toxicity categories when determining r elevant life cycle stages, processes, and elementary flows. Overall, we recommend the following pr ocedur e: As long as the company applying PEF is awar e of the addressed challenges PEF can be used for internal application. This is differ ent for B2B and especially for B2C communication, because fair comparability cannot be guaranteed due to the addr essed challenges. Ther efore, our r ecommendation for impr ovement thr oughout this section should be put in practice during the PEF transitioning phase Furthermor e, as clearly stated by ISO 14040/44 [ 5 ] in general, comparative assertions shall not be based on LCIA r esults only . Assuming all addr essed shortcomings ar e solved satisfactory , the determined r esults based on the PEF method are only r eflecting part of the envir onmental impacts of a pr oduct, because other impacts—like loss of biodiversity , noise, animal welfare, etc.—are not taken into account. Thus, we recommend integrating additional aspects when applicable methods ar e available. Moreover , as long as relevant aspects ar e not addr essed—e.g., animal welfar e—these shortcomings have to be communicated to the user , especially when B2C communication is the intended application of PEF . 3.3.2. Prioritization of Impact Categories by Normalization and W eighting In PEF , normalization and weighting have to be applied to determine the most r elevant impact categories as well as life cycle stages, processes, and elementary flows. The underlying concept of normalization is to set pr oduct system specific emissions in relation with emissions of a r efer ence r egion (expressed by normalization factors—NF). For PEF NFs, a global r efer ence r egion was chosen. Normalization can help to pr ovide and communicate the r elative magnitude of indicator results and is an optional step accor ding to ISO 14040/44. W eighting is carried out to rate and possibly aggr egate normalized indicator r esults using numerical values and is one optional step in ISO 14040/44 as well [ 5 ]. For PEF , an own weighting scheme was set up [ 28 ]. Regar dless of the proposed weighting factors, it is important to understand, that there is no ‘perfect’ or ‘science-based’ weighting set. W eighting as such is always a value choice and thus repr esents the subjective understanding of (one or several) stakeholder . Thus, by reducing the flexibility to determine r elevant impact categories based on expert judgments (as done in the last decades), fair comparability is no longer guaranteed as the following explanations will demonstrate. Normalization As normalization is a relative appr oach, normalized LCIA r esults are low when the r efer ence values (e.g., global emissions) ar e high, whereas they ar e high when emissions in the r efer ence r egion ar e small. This means that a specific amount of emissions of a product system is consider ed as mor e r elevant when the overall emissions in the refer ence r egion ar e low and less important in r egions where alr eady high background emissions exist. T o demonstrate the influence of normalization, the indicator r esults of the impact category acidification of an exemplary pilot pr oject are normalized with dif fer ent normalization factors (NF): the original NFs provided by the Joint Resear ch Center (JRC) and two modified NFs r epresenting scenarios in which two- and four -times higher and lower global emissions ar e assumed, respectively (see Figur e 2 ). Sustainability 2018 , 10 , 2898 12 of 18 Sustainability 2018 , 10 , x FOR PE ER RE VI E W 12 of 18 Figure 2. I n fluence of normalization factors (NF) on no rm alized resu lts de m onstrated for the im pact categ ory acid if ication of an e x em plary pilot project ( f u lly f ille d g r ey bars : norm alized resu lts when orig inal NF i s applied; fu l l y fille d b l ack ba rs: no rm alized resu lt s when orig inal BF i s decrease d; striped bar s : norm alized re su lts when or ig inal NF s are in creased) (own d i ag ram ) . It can be seen that the normalized results get sm aller the higher the NF is, i.e . , the higher t h e overall global emissions are. In p a rallel, it can be se en that the n o rmalized re sults get h i g h er the smaller the NF is, i.e., the smaller the global em issions are. Nor m alization th erefore implies that emitted emissions (or re so urce use) associated w i th a product system are considered less relevant when high e m iss i ons (o r r e source use ) are alre ad y present in a re gion an d mor e relev a nt when only low emission s (or reso urce use ) ex ist. However, th e reversed ar gument could also be plausib l e: r e le as ing prod uct system spec ific emissions (or resourc e use) in a reg i on w h ere the ov er all em issions (or re sourc e use) are alre ad y hig h c a n b e c o n s i d e r e d t o b e m o r e r e l e v a n t t h a n r e l e a s i n g t h e m i n a r e g i o n w i t h a l o w a m o u n t o f e m i s s i o n s ( o r r e s o u r c e u s e ) . T h i s i s t h e n o t i o n o f m o s t p o l i t i cal st rategies, e . g. , due to the al rea d y hi g h emi s si ons of part ic ul at e mat t e r, meas ures are deve loped and im plement e d fo r it s reduct io n [4 7] . The t r ut h lie s somewhere in the middle : product specific em issions (o r reso urce use) c a n be rele vant both in regions where the ov erall emission s (or reso urce use ) are a l re a d y hi gh or st i ll low. The second c h al lenge i s t h at d a t a for c a l c ul at in g t h e n o rmal iz at ion fact ors a r e o f t e n incomplet e . For exa m pl e, f o r the toxi ci ty ca tegori es tens of thousa nds of sub s ta nces ha ve theoreti cal l y to be consider ed, b u t dat a for f a r le ss t h an 10 0 0 act u a lly exist [ 4 8 ] . Hence, norm al iz at ion fact ors ar e typically based on a sm all amount of su b s tances only , i.e., are set to o low. Weightin g Normal iza t i o n a l wa ys ha s to be a ppl ied together wi th a d eq ua te wei g hti n g fa ctors to determi n e relev a nt impact cat e gor i es . Over t h e course o f t h e P E F pilot pha s e, t h e JRC de veloped a w e ight ing set t o b e used for P E F st ud i e s [ 2 8] . The c h al lenge i s t h at , aft e r norm al iz at ion , t h e resu lt s o f t h e v a rio u s i m p a c t c a t e g o r i e s d i f f e r i n u p t o t w o d e c i m a l p o w e rs, but the d i fference in t h e current w e ighting f a ctors f o r the di ff erent ca tegori es i s onl y up to f o ur ti m e s [6 ,1 2,28 ]. Hence, th e rele vance of the impact cat e gor i es is main ly det e rmined by t h e normal i z a t ion resu lt s. As shown in Fig u re 3, t h e four ca tegori es wi t h the hi ghest norma l i z ed resul t a r e al so the ca tegori es wi th th e h i gh est norm alize d and weight ed r e s u lt . E s t a bl ish i ng a repres en t a t i ve an d acc e pted weighting method agreed on by several st akeho l der s is an ambit i o u s go a l , wh ic h could not be ach i eved so fa r. W e ight in g is a po lit ic a l iss u e, not a sc ient i f i c one, and as such shou ld be disconn e ct ed from t h e s c ient if ic as ses s ment met h od. 0. 00 E + 0 0 2. 00E - 1 4 4. 00E - 1 4 6. 00E - 1 4 8. 00E - 1 4 1. 00E - 1 3 1. 20E - 1 3 1. 40E - 1 3 R esu lt s w i t h origi nal N F R esu lt s w h en ori ginal N F divided/m ult iplied by 2 R esu lt s w hen ori ginal NF i s di vi ded/m ult ipli ed by 4 N orm al i z ed re sul ts [- ] No rm alize d res ult wh en or igin al NF is de crea sed No rm alize d res ult wh en or igin al NF is in cre a se d 1. 4 x 10 -13 1. 2 x 10 -13 1. 0 x 10 -13 8. 0 x 10 -14 6. 0 x 10 -14 4. 0 x 10 -14 2. 0 x 10 -14 0 Figure 2. Influence of normalization factors (NF) on normalized results demonstrated for the impact category acidification of an exemplary pilot pr oject (fully filled grey bars: normalized results when original NF is applied; fully filled black bars: normalized results when original BF is decr eased; striped bars: normalized results when original NFs ar e incr eased) (own diagram). It can be seen that the normalized results get smaller the higher the NF is, i.e., the higher the overall global emissions ar e. In parallel, it can be seen that the normalized results get higher the smaller the NF is, i.e., the smaller the global emissions are. Normalization ther efore implies that emitted emissions (or r esource use) associated with a pr oduct system ar e consider ed less r elevant when high emissions (or r esource use) ar e alr eady pr esent in a r egion and more r elevant when only low emissions (or r esource use) exist. However , the r eversed argument could also be plausible: releasing pr oduct system specific emissions (or r esource use) in a r egion wher e the overall emissions (or r esour ce use) ar e already high can be consider ed to be mor e relevant than r eleasing them in a r egion with a low amount of emissions (or r esource use). This is the notion of most political strategies, e.g., due to the alr eady high emissions of particulate matter , measures ar e developed and implemented for its reduction [ 47 ]. The truth lies somewher e in the middle: product specific emissions (or r esour ce use) can be r elevant both in regions wher e the overall emissions (or resour ce use) ar e alr eady high or still low . The second challenge is that data for calculating the normalization factors are often incomplete. For example, for the toxicity categories tens of thousands of substances have theoretically to be consider ed, but data for far less than 1000 actually exist [ 48 ]. Hence, normalization factors are typically based on a small amount of substances only , i.e., ar e set too low . W eighting Normalization always has to be applied together with adequate weighting factors to determine r elevant impact categories. Over the course of the PEF pilot phase, the JRC developed a weighting set to be used for PEF studies [ 28 ]. The challenge is that, after normalization, the results of the various impact categories dif fer in up to two decimal powers, but the differ ence in the curr ent weighting factors for the dif ferent categories is only up to four times [ 6 , 12 , 28 ]. Hence, the relevance of the impact categories is mainly determined by the normalization results. As shown in Figur e 3 , the four categories with the highest normalized r esult are also the categories with the highest normalized and weighted r esult. Establishing a r epresentative and accepted weighting method agr eed on by several stakeholders is an ambitious goal, which could not be achieved so far . W eighting is a political issue, not a scientific one, and as such should be disconnected fr om the scientific assessment method. Sustainability 2018 , 10 , 2898 13 of 18 Sustainability 2018 , 10 , x FOR PE ER RE VI E W 13 of 18 Figure 3. Normalized and nor m alized and w e ighted resu lt s for all impact categories deter m ined with the newly pro p osed weighting set, separat e d into re levan t and not relev a nt categ o rie s ( a ccording to the P E FCR guid e) (own d i agram). Moreover, ac cording to th e PEFC R guide impact c a tegori es tha t cumula ti vel y contri bute to a t l e ast 80 % of the tota l env i ronmental impa ct of the RP are considered as re levant, where a s the remain ing c a t e gories ar e c l a ssi fi ed as n o t relevant . As shown in Fig u re 3 for t h e chosen ex ample , difference s in the impact c a tegory re sults of ‘land u s e’ and ‘re s our c e u s e, fo ss il’ are very sm al l (onl y 8%) . Is t h e d i st inct ion of t h e res u lt s t o o sma ll as in t h is c a se , s u ch a c l a s s i f i cat i on int o ‘relev ant ’ and ‘not relevant ’ is n o t ade q uat e as ‘rele v ant ’ li fe cy c l e st ages, pro c esses an d e l ementary flo ws are determined o n ly for the c h osen imp a ct categor i es. T h at mean s (1 ) t h at re lev a nt lif e cyc l e st age s , processes an d e l ementar y flows are o n ly determi n ed for c a tego ries, wh ich may not be t h e most relev a nt ones for the considered prod uc t system; and ( 2 ) tha t f o r most of the impa ct ca tegori es the relev a nt life c y cle st age s , p r ocesse s an d elementar y flows are not even analy s ed . This is important especially wh en determin i ng re levant life c y cle stage s , proce sse s and elementar y flows (as d e fine d within the P E F g u ide [2]) and when specific me asur es li ke a l t e rnat ive m a t e rials are considered, to ma ke sure tha t tra d e- off s are ta ken i n to a ccount. Wit h in t h e chose n example , fo r inst ance, on ly 5 ou t of 13 ca tegories a r e taken into a ccount and theref ore trade-o f fs wit h in the neg l e c ted c a tegories are like l y . Overall, we r ecommend the fo llow i ng procedure : A ll 17 c a tegor i es sho u ld be consider ed fo r every PE F c a se study . Wh ic h of the re sults ar e fi n a lly c o mmunicate d to the consumer is indep endent of t h e an a l ys is o f t h e pro d uct sy st em and sho u l d b e disc us sed s e parat e ly, me aning t h e sc i e nt ific procedure ho w to determine relevancy shall not be influenced b y the question what the consumer is able to under stand. Depending o n the implementation of P E F, norm a l i z at ion an d/ or weight ing m i ght not even be necess ary . Fo r int e rna l applic at ion, al l cat e gor i es h a ve t o be considered ( a ccor d ing t o PE F rule s) , which renders normalization and/or weighting re dund ant. For B2B communication , all impact Figure 3. Normalized and normalized and weighted results for all impact categories determined with the newly proposed weigh ting set, separated into relevant and not r elevant categories (accor ding to the PEFCR guide) (own diagram). Mor eover , accor ding to the PEFCR guide impact categories that cumulatively contribute to at least 80% of the total envir onmental impact of the RP are consider ed as r elevant, wher eas the r emaining categories ar e classified as not relevant. As shown in Figure 3 for the chosen example, differ ences in the impact category r esults of ‘land use’ and ‘resour ce use, fossil’ ar e very small (only 8%). Is the distinction of the r esults too small as in this case, such a classification into ‘relevant’ and ‘not r elevant’ is not adequate as ‘r elevant’ life cycle stages, pr ocesses and elementary flows are determined only for the chosen impact categories. That means (1) that r elevant life cycle stages, processes and elementary flows ar e only determined for categories, which may not be the most r elevant ones for the considered pr oduct system; and (2) that for most of the impact categories the relevant life cycle stages, pr ocesses and elementary flows ar e not even analysed. This is important especially when determining relevant life cycle stages, processes and elementary flows (as defined within the PEF guide [ 2 ]) and when specific measur es like alternative materials are consider ed, to make sur e that trade-of fs are taken into account. W ithin the chosen example, for instance, only 5 out of 13 categories ar e taken into account and ther efore trade-of fs within the neglected categories ar e likely . Overall, we recommend the following pr ocedure: All 17 categories should be considered for every PEF case study . Which of the r esults ar e finally communicated to the consumer is independent of the analysis of the pr oduct system and should be discussed separately , meaning the scientific pr ocedure how to determine r elevancy shall not be influenced by the question what the consumer is able to understand. Depending on the implementation of PEF , normalization and/or weighting might not even be necessary . For internal application, all categories have to be considered (accor ding to PEF rules), Sustainability 2018 , 10 , 2898 14 of 18 which r enders normalization and/or weighting redundant. For B2B communication, all impact categories ar e included in the PEF report (accor ding to the PEFCR guide [ 6 ]). Thus, there is no need for normalization and/or weighting. There ar e several possibilities for how PEF can be used for B2C communication, which also determines if normalization and/or weighting are necessary . PEF can be implemented as an independent environmental label based on a single-scor e r esult by aggr egating the results of the individual categories. This can be done with normalization (based on global emissions) and weighting as curr ently requir ed by PEF , but also by applying other normalization methods, e.g., based on carrying capacity [ 49 ] or by applying other aggr egation methods such as the distance-to-tar get approach [ 50 ]. The decision of which categories are important should be made later in a political pr ocess by the decision makers. Thus, weighting should be addressed during policy implementation, as this will define the need for it depending on the specific application. This will also determine which stakeholders should have a say in the weighting and what an inclusive, r epresentative pr ocess to come up with weighting factors should look like. When PEF is implemented as an independent envir onmental label based on relevant impact categories, but without aggr egation, only weighting is r equired to identify the r elevant categories. When PEF is implemented as an evaluation method for existing labels (e.g., by r edefining criteria), a single-score r esult is not necessary and even counterpr oductive in this case, because the detailed non-aggregated r esults ar e needed. The r elevant categories have already been identified during the establishment of the label. These categories however could be extended based on the weighting developed for PEF . For that, a weighting scheme developed by policy makers is necessary , but no normalization is needed. Furthermor e, instead of considering only categories that contribute to 80% of the overall impacts, we r ecommend including all categories or at least with a contribution to 90% (or even higher). Another option could be to set a minimum threshold—e.g., all impact categories which contribute mor e than 5% should be taken into account. Furthermor e, we recommend that r elevant pr ocesses should not be determined simply on their contribution to the overall envir onmental impact, but also other aspects such as influence of company carrying out the study to r educe the impacts, corporate annual accounts, or expert judgments. Concluding this section, in T able 2 an overview of all identified challenges, their implication for comparability , and our r ecommendations are pr ovided. T able 2. Overview of identified challenges, their implication for comparability , and recommendations from the authors. Challenges Implications for Comparability Recommendations Measuring of the product performance Products with dif fer ent performances can be compared Include the products performance in the functional unit Define standardized test to measur e the product performance Definition of product category Products with dif fer ent applications from a consumer ’s points of view can be compared Consistently define the product category 1,2 Definition of the repr esentative pr oduct Established benchmark is often too high to have a steering effect for the market Improve the appr oach to define the repr esentative pr oduct 1,2 Use of country specific electricity mix Influence of production locations is too high The use of country specific electricity mix should not be allowed Use of secondary data Secondary data cannot reflect individual improvements of companies Use of specific primary data for relevant processes/materials Provision of specific data or adaptable datasets by the EC Sustainability 2018 , 10 , 2898 15 of 18 T able 2. Cont. Challenges Implications for Comparability Recommendations Modeling of End-of-Life: (i) It is not considered how often a material is recycled (ii) Quality of recycled materials is not addressed adequately (iii) For closed-loop systems only 80% of the credits as maximum can be given Environmental impacts of many materials and efforts of companies to establish closed-loop-systems are not accounted for properly Refine the formula, so that the recycling cycles and the quality of the recycled material are consider ed 1,2 as well as allow for 100% credits for closed-loop systems Applicability of life cycle impact assessment methods: (i) Granularity of impact categories leads to implicit weighting (ii) Regionalized methods are applied without regionalized inventory data (iii) Exclusion of toxicity categories Environmental impacts ar e not accounted for properly (i) Cluster categories consistently (ii) Apply regionalized methods only when regionalized inventory data is available or chose global methods for global inventory data (iii) Consider toxicity categories Prioritization of impact categories by normalization and weighting: (i) Normalization is a relative appr oach (ii) Missing normalization factors (iii) W eighting is subjective The identification of the relevant categories for the considered pr oduct system is not ensured Normalization should be skipped W eighting should be disconnected fr om the scientific assessment method Relevant categories should be defined during policy implementation Analyze differ ent appr oaches to determine single score r esults 1 1 For these challenges, no ready-to-go solutions ar e available and further r esearch is needed to tackle them; 2 These challenges will be addressed in the PEF transitioning phase. 4. Conclusions W e want to str ess that in general, LCA—and hence also PEF—is a useful tool to analyze potential envir onmental impacts of products, e.g., for in-house pr oduct improvement or external B2B or B2C communication. By identifying potential envir onmental impacts (including trade-of fs) and showing dir ections, LCA/PEF can support/guide decisions towards “gr een pr oducts” and a “cir cular economy” [ 51 – 53 ]. Thus, we support the PEF appr oach to address all r elevant impact categories and the full life cycle of pr oducts as well as the pr oposal of further guidance for a method for quantifying and communicating envir onmental performance from cradle-to-grave. Mor eover , we appreciate the work done by the numer ous stakeholders which were and ar e involved in the PEF pilot phase and the transition phase. However , a number of challenges related to the PEF method and the developed PEFCRs still exist. Only few of the early identified challenges (as shown by e.g., [ 4 ]) wer e addressed in the pilot phase, but most challenges still exist and have not been tackled successfully in the pilot phase. W ith regar d to the claim of “comparability over flexibility”, it was shown that neither comparability can be achieved, nor that a decrease of flexibility is adequately implemented. PEF r educes the flexibility of the user significantly , which led to higher r eproducibility of r esults. If the variability of the r eal world is expressed in models considering certain value choices (e.g., using the same dataset for a raw material, which in real life can be pr oduced in differ ent ways such as agricultural pr oducts), which every study has to apply , r epr oducibility instead of comparability is pr omoted and inflexibility is increased. Thus, r eproducibility does not automatically introduce comparability , but rather bias. This paper pr ovides an evaluation of the main challenges and concerns we see with regar d to a potential application of PEF and the PEFCR for comparisons and comparative assertions. First ideas and r ecommendations on how these challenges could be tackled are pr ovided. T o determine the applications of PEF is extr emely important as methodological r equirements for a PEF study depend lar gely on the goal of the study , usually defined within the first step. As explained in this paper , most of the requir ements defined in the PEF method and the established PEFCRs ar e adequate for application for internal product and pr ocess optimization. They ar e however not suitable for fair comparability . Addr essing the challenges outlined in this paper and considering the Sustainability 2018 , 10 , 2898 16 of 18 r ecommendations provided would help to position PEF as a useful instrument which can facilitate the use of LCA and pr ovide the basis for sound political decisions. Author Contributions: V .B. and A.L. ar e both the leading composers of this manuscript and both contributed substantially to the structur e and text of the manuscript. All authors contributed to the content, i.e., to the evaluation of the PEF-pilot phase. All authors proofr ead and appr oved the final manuscript. Funding: This resear ch was funded by the German Envir onmental Agency (Umweltbundesamt) as part of the environmental r esear ch plan—pr oject code number 3712 95 337—and financed with federal funding. Acknowledgments: W e would like to thank our project partner as well as the anonymous r esear chers for their valuable comments and suggestions. Conflicts of Interest: The authors declare no conflict of inter est. References 1. European Union. Building the Single Market for Gr een Products Facilitating Better information on the Envir onmental Performance of Products and Or ganisations ; Eur opean Union: Brussels, Belgium, 2013. 2. European Commission. 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