RCI’s position paper: “Commission proposal for a Green Claims Directive (GCD) – Towards science-based substantiation of claims and accurate biogenic carbon accounting” (September 2023)
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Towards science-based substantiation of claims and accurate biogenic carbon accounting
The Renewable Carbon Initiative (RCI) wholeheartedly endorses the Green Claims Directive’s (GCD) mission to provide consumers and businesses with reliable, comparable, and verifiable information to facilitate sustainable choices.
In our position paper, we emphasise three aspects that, in our view, require additional attention to maximise the impact of the GCD and support products and solutions derived from non-fossil, renewable-carbon-based feedstock from biomass, CCU or recycling.
1. Science-Based Life-Cycle Assessment Methodologies: RCI welcomes the acceptance of several life-cycle assessment methods for substantiating environmental claims but emphasises the practical importance of maintaining flexibility in the upcoming trilogue negotiations. We also call for clarification on how to determine if an environmental impact is considered “significant.”
2. Differentiated Biogenic Carbon Accounting Methodology: The RCI advocates for enabling the possibility to better reflect uptake of atmospheric CO2 via biogenic carbon (and principally any process that captures CO2 from the atmosphere) in product assessments. In general, biogenic carbon in LCA is neither credited with carbon uptake through biomass at the beginning nor with the emissions (e.g. from incineration) at end of life. While this is from a proper LCA point-of-view valid and recommended, it leads to issues for stakeholders reporting their biogenic product’s carbon footprint at factory gate, because the uptake of atmospheric carbon cannot be shown and the conceptual advantage over fossil products gets lost. At the same time, we are aware of misleading “carbon negative” claims and argue that only full cradle-to-grave LCAs should qualify for such B2C claims.
3. Ensuring a Reliable Verification Mechanism: Recognising the need for mandated verification of environmental claims before B2C communication, RCI acknowledges the potential challenges posed by these resource-intensive processes. We want to stress the importance of an effective approach and an extended transition period to enable authorities, verifiers, and the industry to smoothly adapt to these processes and mitigate potential delays in communicating claims for innovative products.
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