GENERAL COMMENTARY
published: 30 August 2021
doi: 10.3389/frsus.2021.729267
Frontiers in Sustainability | www.frontiersin.org 1August 2021 | Volume 2 | Article 729267
Edited and reviewed by:
Mikołaj Owsianiak,
Technical University of
Denmark, Denmark
Mélanie Douziech,
MINES ParisTech, PSL
University, France
*Correspondence:
Matthias Finkbeiner
Specialty section:
This article was submitted to
Quantitative Sustainability
Assessment,
a section of the journal
Frontiers in Sustainability
Received: 22 June 2021
Accepted: 06 August 2021
Published: 30 August 2021
Citation:
Finkbeiner M (2021) Commentary:
System Expansion and Substitution in
LCA: A Lost Opportunity of ISO 14044
Amendment 2.
Front. Sustain. 2:729267.
doi: 10.3389/frsus.2021.729267
Commentary: System Expansion and
Substitution in LCA: A Lost
Opportunity of ISO 14044
Amendment 2
Matthias Finkbeiner*
Chair of Sustainable Engineering, Institute of Environmental Technology, Technische Universitaet Berlin, Berlin, Germany
Keywords: ISO 14044, LCA, life cycle assessment, allocation, system expansion
A Commentary on
System Expansion and Substitution in LCA: A Lost Opportunity of ISO 14044 Amendment 2
by Heijungs, R., Allacker, K., Benetto, E., Brandão, M., Guinée, J., Schaubroeck, S., et al. (2021). Front.
Sustain. 2:692055. doi: 10.3389/frsus.2021.692055
INTRODUCTION
Heijungs published recently together with seven co-authors an opinion paper in this journal titled
“System Expansion and Substitution in LCA: A Lost Opportunity of ISO 14044 Amendment 2”
(Heijungs et al., 2021). Their contribution makes mainly two points:
•According to their interpretation, the 2nd amendment of ISO 14044 (ISO 14044, 2020)
“effectively rules out [actual system expansion and] prescribes that expanding the system to
include additional functions must be understood as subtracting avoided burdens with the
substitution method.”
•The amendment has failed to bring the clarification, that “the LCA community has been eagerly
looking forward to [...] to a largely confusing hierarchy to address the multi-functionality issue.”
This reply intends to clarify, that the first of these points is based on an erroneous interpretation of
the standard, respectively, amendment and that the second point is based on a misunderstanding
of the global, stakeholder-oriented standardization process at ISO.
INTERPRETATION OF ISO 14044 AMENDMENT 2
The proper interpretation of International Standards (ISO) requires an understanding of the
specific language and coding rules, which apply to them. While they are ideally as understandable
as possible for as many stakeholders as possible, a certain knowledge of the standard language and
rules is necessary to decipher them correctly. While these codes and norms may appear to some as
superfluous and misleading at first sight, they have the same justification as other formal codes like
e.g., mathematics, legislative language, or the language of certificates of employment. Languages
in such contexts may appear also difficult to understand at first sight. As a consequence, they are
sometimes not interpreted correctly, especially when taken literally, while they are crystal-clear for
those in the know.
The first main conclusion of Heijungs et al., i.e., the interpretation of the Amendment 2
as being prescriptive for only allowing system expansion as substitution (avoided burden) and
Finkbeiner Commentary: Interpreting ISO 14044 Amendment 2 Correctly
therefore restricting what they call “actual system expansion”
is based on the following text in the standard: “Therefore,
the product system that is substituted by the co-product is
integrated in the product system under study. In practice,
the co-products are compared to other substitutable products,
and the environmental burdens associated with the substituted
product(s) are subtracted from the product system under
study.” It is correct, that basically this whole section focusses
on this particular option for system expansion. When taken
separately and when read as colloquial language, this may lead
to the impression of Heijungs et al., but there are several
standardization aspects that make it crystal-clear, that such an
interpretation is not correct:
1. An amendment has to be read together with the main body of
the standard (ISO 14044, 2006). It does not replace the content
of the amended standard, it adds to it. Therefore, as Heijungs
et al. point out by themselves, the generic system expansion
clauses are introduced in the beginning of the amendment.
They are still valid and the amendment just adds to it, it does
not replace it.
2. ISO has in their Directives clear rules, that certain verbal
expressions have to be used to identify the normative content
of the standard, i.e., “shall” for requirements, “should” for
recommendations, “may” for permissions and “can” for
possibilities (ISO, 2021a). The text referred to by Heijungs
et al. does not include any of these verbal forms, i.e., it can
never have any binding meaning or even overrule the “shalls”
and “shoulds” in the main body of the text. It is purely a
description, that is not normative at all.
3. The Amendment is an informative Annex. If an Annex is
qualified in the heading as “informative,” this is an obvious
indication, that its clauses (here: the Amendment) cannot
be interpreted in changing any of the existing requirements
of the associated standard (here: ISO 14044). Annexes are
used to provide additional information to the main body
of the document, e.g., by presenting information regarding
a particular application of the document. There are also
normative annexes, which provide additional normative text
to the main body of the document, but informative annexes—
as the one relevant here—are not normative at all. As such,
an informative annex can never change the actual content or
interpretation of the standard.
The actual intention of these clauses in the amendment was
the consensus, that it should be clarified, that the “subtraction
approach” can also be used as system expansion as is commonly
done in LCA practice. This was always the intention as originally
documented by ISO 14041 (1998) as Heijungs et al. point
out as well. However, recently there were some scholars from
the academic world, who were arguing that the “subtraction
approach” is not covered by system expansion according ISO or
that system expansion altogether would only belong to particular
types of LCA. Therefore, the amendment clarifies, that system
expansion is applicable for all types of LCA and that the
“subtraction approach” is covered by the requirements for system
expansion in ISO 14044.
It was never the intention to make it the only option, it was the
intention to clarify, that it is one of the options. This is properly
reflected by the text of the amendment, if the standardization
rules and language are considered. In a nutshell, the allocation
annex of Amendment 2 did not include any changes to the
requirements and recommendations of ISO 14044 when it comes
to allocation as this is not possible by an informative annex—
per definition. As such, contrary to their interpretation, the
Amendment 2 fully satisfies the request of Heijungs et al. to have
both options for dealing with system expansion.
For the second topic, “the lost opportunity” for clarification
of the multi-functionality issue, there is a common
misunderstanding about the international standardization
process. Standards are sometimes criticized by some stakeholders
(especially from academia) for not being specific enough
on certain issues. There are some scholars with strong
convictions in certain topics, even though they are value
choices, like e.g., allocation. They typically come from a rather
theoretical background.
There is the famous quote of unclear source: “In theory there is
no difference between theory and practice, while in practice there
is.” Standards are for practice, not for academic theory. They
represent the global consensus on those methodological features
for which such a consensus exists. More specific stipulations on,
e.g., allocation procedures or a default set of impact categories, let
alone a particular impact assessment method might be desired by
some stakeholders, but there is no global stakeholder consensus
on them. It is a very democratic procedure to develop an ISO
standard, but democracy does not guarantee that the outcome is
to the liking of everyone. Standards do not have specific authors,
they are collaboratively written by often hundreds of people,
who provide comments as member of the working groups or as
member of the national mirror committees that provide input
to the standard development. It makes no sense to blame the
standards or those involved in the standardization process for
this, as it is the natural result of such a process, that there is no
“a one size fits all-LCA” and that the final text is a compromise.
ISO standards respond to a need in the market (Finkbeiner,
2014). While academic debates are dominated by the providers
of LCA, standards need to focus on the users of LCA. While
Heijungs et al. qualify the ISO hierarchy for multi-functional
processes as “largely confusing,” many users seem to be able to
work with this hierarchy without any show-stopping problems.
Many users identified proper ways, how they handle this within
their sector or for their products. At least, it was not confusing
enough for them to agree on a change of this hierarchy.
ISO standards are based on global expert opinion (Finkbeiner,
2014). ISO standards are developed by groups of experts from
all over the world and standards should not target the 5%
most advanced users, but the whole world. As such, while some
leading experts in the developed world may feel, it is time, that
their ideas are reflected in a standard, many other parts of the
world may have just started to understand and implement the
more established practice documented in the standard. While
established practice starts to get traction, they are not keen to
switch to the latest trend in LCA science immediately.
Frontiers in Sustainability | www.frontiersin.org 2August 2021 | Volume 2 | Article 729267
Finkbeiner Commentary: Interpreting ISO 14044 Amendment 2 Correctly
ISO standards are developed through a multi-stakeholder
process and ISO standards are based on a consensus (Finkbeiner,
2014). This means, they are not primarily about being
theoretically right and academically advanced. They are a
compromise of a democratic consensus building process and not
about academic dogmatism.
CONCLUSION
The take-home message of this reply for LCA practitioners is,
that they can still do system expansion according to ISO 14044
both ways—by adding additional functions or by subtracting
additional functions. The interpretation by Heijungs et al. that
Amendment 2 is supposed to restrict the use of “actual system
expansion” in any way is a misunderstanding and therefore
not correct.
Anyone envisioning future revisions of ISO 14044 can
contribute to the process, but understanding the standardization
process and its rules is important to manage expectations.
Standards are not necessarily about academic excellence.
According to ISO (2021b), “standards are the distilled wisdom
of people with expertise in their subject matter and who know
the needs of the organizations they represent—people such
as manufacturers, sellers, buyers, customers, trade associations,
users or regulators.” While it is acknowledged that some
respected academic colleagues see the completed Amendment 2
as a “lost opportunity,” the actual target audience of the standards
is apparently of a different opinion as the amendment was
approved almost unanimously with 93% positive votes.
AUTHOR CONTRIBUTIONS
MF drafted and edited the text.
FUNDING
There was no third-party funding provided for this paper, but
the support by the Open Access Publication Fund of TU Berlin
is acknowledged.
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S., et al. (2021). System expansion and substitution in LCA: a lost
opportunity of ISO 14044 Amendment 2. Front. Sustain. 2:692055.
doi: 10.3389/frsus.2021.692055
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Conflict of Interest: The author declares that the research was conducted in the
absence of any commercial or financial relationships that could be construed as a
potential conflict of interest.
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Copyright © 2021 Finkbeiner. This is an open-access article distributed under
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