FILE/14021_VER_REP_EN_(02-20…  · Web view2021. 4. 29. · In case that the environmental claims...

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Client name Specify the claim Verification Report DRAFT /FINAL RINA file number xxxx Rev. 0 Description First issue Prepared by XXXXX (Team Leader) Checked by ITR name Approved by Certification Manager: xx VERIFICATION REPORT ON SELF-DECLARED ENVIRONMENTAL CLAIM

Transcript of FILE/14021_VER_REP_EN_(02-20…  · Web view2021. 4. 29. · In case that the environmental claims...

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Client name

Specify the claim

Verification Report DRAFT/FINAL

RINA file number xxxx

Rev. 0

Description First issue

Prepared by XXXXX (Team Leader)

Checked by ITR name

Approved by Certification Manager: xx

Date dd/mm/yyyy

VERIFICATION REPORTON SELF-DECLARED ENVIRONMENTAL CLAIM

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Rev. Description Prepared by Checked by Approvaed by Date

0 First issue XXXXX (ITR name)Xx

(Certification Manager)DD/MM/YYYY

xxxx

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INDEX

Pag.

ABBREVIATIONS AND ACRONYMS 2

SUMMARY 3

1 PRESENTATION OF RINA 4

2 VERIFICATION METHODOLOGY 5

2.1 GENERAL

2.2 VERIFICATION TEAM AND INDIPENDENT REVIEW

2.3 DOCUMENTAL REVIEW

2.4 ON-SITE VISIT AND INTERVIEWS WITH THE KEY SUBJECTS OF THE ORGANIZATION

2.5 RESOLUTION OF FINDINGS

2.6 ISSUE OF THE VERIFICATION REPORT

3 VERIFICATION OPINION 7

3.1 OBSERVATIONS AND RESERVATIONS

ANNEX A – FINDINGS MANAGEMENT 8

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ABBREVIATIONS AND ACRONYMS

CAR Non conformity/Corrective Action Request

CL Request for clarification

GHG Greenhouse gas

GWP Global Warming Potential

IPCC Intergovernmental Panel on Climate Change

Organisation Client name

R Recommendation

RINA RINA Services S.p.A.

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SUMMARYRINA Services S.p.A. (RINA) has been appointed by the client xx to verify the self-declared environmental claim of the “products” Specify products, with regard to the relevant requirements for UNI EN ISO 14021.

The reference documents for verification are shown in the following table:

/A/UNI EN ISO 14021: Environmental labels and declarations - Self-declared environmental claims (Type II environmental labelling), 2016

/B/ISO 14064-3: Greenhouse gases - Part 3: Specification with guidance for the validation and verification of greenhouse gas statement, 2019

Other documents used for verification:

/i/RINA, Rules for the concession and maintenance of certification of self-declared environmental claims in compliance with the ISO 14021 standard, date

/ii/ RINA, On-site Verification plan, rev. xx, date

/iii/ Author, title of document, rev., date

Type of self-declared claim:

Comparative Non comparative

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1 PRESENTATION OF RINARINA Services S.p.A. (RINA) is the company of the RINA Group that deals with providing naval classification, certification, testing and inspection services. RINA operates as an independent entity and makes its experience and expertise available through a wide range of services aimed at supporting industry and the community and improving activities and quality of life.

For over 20 years, RINA has developed well-established skills on environment issues and the greenhouse effect, life cycle analysis, energy efficiency and sustainability of organisations, products, services, processes and systems.

RINA offers certification and conformity assessment services to public and private organisations that are committed to sustainability, environmental protection and the fight against climate change.

To guarantee the value of its certifications and assessments, RINA has acquired over the years a wide range of international, community and national awards, issued by accreditation bodies such as: ACCREDIA, ANAB, ASI, INMETRO, SAAS, ISPRA, UNFCCC , ANSF, COMPETENT MINISTRIES.

It is also notified by the competent ministries to operate according to the most important European directives for the issue of the CE mark.

RINA is a member of the Management Committee of the CEOC (International Confederation of inspection and certification organisations) and it is also a member of CONFORMA and of the CISQ Federation (Italian Certification of the Company Quality System), which gather the main national certification bodies. RINA adheres to the international agreement IQNet (The International Certification Network), which represents the largest international network for the certification of management systems for quality, the environment and safety.

For the services covered by this activity, RINA has:

• an accreditation certificate issued by the UNFCCC (United Nations Framework Convention on Climate Change, an ONU operational agency that deals with climate change) for the validation and verification of Clean Development Mechanism (CDM) projects;

• an accreditation certificate issued by ACCREDIA in compliance with UNI EN ISO 14065: 2013 - Verification of greenhouse gas emissions for the EU Emissions Trading Scheme;

• an accreditation certificate issued by ACCREDIA pursuant to Regulation (EC) no. 1221/2009 of the European Parliament and of the Council of 25 November 2009 on the voluntary participation of organisations in a Community eco-management and audit system (EMAS);

• an accreditation certificate issued by ACCREDIA in compliance with ISO 14001 (as well as a certificate issued by ANAB and one by INMETRO);

• an accreditation certificate issued by ACCREDIA in compliance with ISO 50001;• an accreditation certificate issued by ACCREDIA for the verification and validation of

environmental product declarations;• an accreditation certificate issued by ACCREDIA for the UNI CEI 11352 certification.

RINA recognizes the fundamental guiding principles of the validation, evaluation and verification processes and conducts all activities ensuring accuracy, prudence, relevance, credibility, reliability, completeness, consistency, transparency, impartiality, independence and safeguarding from conflicts of interest and confidentiality.

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2 VERIFICATION METHODOLOGY

2.1 GENERALThis verification was carried out by a team selected on the basis of competence and independence criteria. The team is completely independent of all aspects regarding the self-declared environmental claims of the Organisation and has not participated in any way in the design of any part of it or of the supporting documents.

The verification team performed the following activities:

• a strategic and risk analysis that includes a review of the documents prepared by the Organization to explain the purpose and complexity of the verification activities;

• interviews with key Organisation subjects;• an on-site visit to interview the representatives of the Organisation and check the evidence

supporting the self-declared environmental claims;• verification that the findings of the Organisation that emerged from the documentary examination

and from the on-site visit have been resolved satisfactorily;• the issue of this verification report.

2.2 VERIFICATION TEAM AND INDIPENDENT REVIEWThe table below shows the members of the independent verification and review team.

Role Name and Surname

Team Leader xxx

Verificator xxx

Independent reviewer xx

2.3 DOCUMENTAL REVIEWThe documents examined are shown in the following table.

/01/

Author, title of document, rev., date

/02/

Author, title of document, rev., date

/03/

Author, title of document, rev., date

No distribution without permission from the Client or organizational unit responsible

Strictly confidential

Unrestricted distribution

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2.4 ON-SITE VISIT AND INTERVIEWS WITH THE KEY SUBJECTS OF THE ORGANISATIONOn date, the RINA team visited the site of xx, in street xx. During the visit, the team examined the documentation, carried out the on-site visit, examined the information flow, the quality assurance procedures, the records supporting the report, re-checked the calculations and interviewed the organisation’s key personnel (see on-site verification plan).

Provide clear indications on whether the visits have been made and justify any visits not made.

The interviewed personnel, the organisation and responsibility are shown in the following table:

Role Name and Surname

2.5 RESOLUTION OF FINDINGSAfter the documental review and the interviews, the team presented to the Organisation a list of findings which summarises the areas that need further processing, investigations or additions by the representatives of the Organisation in order to confirm that the self-declared environmental claims is in line with the verification criteria identified.

Findings classifies as CAR and CL must be resolved before continuing the verification process, while findings classified with R consist in recommendations for improvement.

The Organisation has provided further clarifications or made the necessary improvements to the documentation, in order to obtain a positive outcome of the verification.

The appendix A to this report contains two table, the first table contains the requirements of the reference standard (ISO 14020/14021) and the notes that the team wants to highlight and the table 2 that contains the findings issued by RINA (CAR, CL, R) and their status of resolution.

2.6 ISSUE OF THE VERIFICATION REPORTUpon receipt of the replies formulated by the Organisation representatives and of the documents modified following the findings (CRs and CARs), the team prepared this Verification Report with the verification opinion.

The Verification Report was issued and approved by the authorised person once all the findings issued have been resolved by the Organisation and accepted by RINA.

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3 VERIFICATION OPINIONConclusion for the DRAFT Verification Report, delete if not applicable

In conclusion xx Corrective Action Requests (CARs) and xx Clarification Requests (CLs) and xx recommendations (R) are identified. RINA thus requests the resolution of these CARs and CLs prior to proceeding with the verification process. The client is invited to respond to the RINA requests and to revise the necessary documents

Conclusion for the FINAL Verification Report - in case of a positive outcome, delete if not applicable

The purpose of the verification was to check that the documentation supporting the self-declared environmental claims is pertinent, adequate and correct in order to demonstrate the truthfulness and validity of the self-declaration and any related explanatory declaration for compliance with the requirements of the reference standard, UNI EN ISO 14021: 2016.

Based on documentary evidence and corroborated by an on-site evaluation, RINA can confirm that the self-declared environmental declaration of the products specify which products is correctly declared.

Conclusion for the FINAL Verification Report - in case of a negative outcome , delete if not applicable :

In view of the above, it is hereby declared that it is not possible to issue a positive verification. The reasons for this declaration are: xx.

3.1 OBSERVATIONS AND RESERVATIONSReport any observations and reservations concerning any suggestions.

The positive statement is based on the assumption that the observations indicated above do not have a significant influence on the calculation of GHG emissions.

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AN

NE

X A

ANNEX A – FINDINGS MANAGEMENT

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Annex A

Table 1 – Requirements

14021 DescriptionComment(Compliant or description of the finding)

Conclusion

ISO 14020 – 4 - PRINCIPLES

4.2.1 Are the labels and environmental declarations accurate, verifiable, relevant, understandable and not misleading?

4.4.1 Are the labels and environmental claims based on a scientific methodology sufficiently exhaustive and complete that produce results accurate and reproducible?

4.4.2 Are the methods used adequate to the claim and give the relevant information needed in order to support the claim and are accurate and reproducible?

4.5.1Are the information related to the procedure, methodology and all the criteria used to support the labels and environmental claims available and provided upon request to all the interested parties?

4.5.2

Does the information clearly report if the label or the environmental claim is a self-declared environmental claim or if it’s based on an independent validation?This information should be sufficient and reasonable understandable to give the possibility to the buyers, or to the potential buyers and to all the other interested parties to evaluate and compare the labels and the environmental claims in terms of scientific principles, relevance and overall validity and to evaluate if the label or the environmental claim is consistent with the ISO 14020 standard

The means to obtain this information are disclosed to the buyers and potential buyers everywhere is commercialized the product or the service?There may be limits to the availability of specific information due to confidential business information, intellectual property rights, or similar legal restrictions.

4.6.1

Does the development of the labels and environmental claims take into account all the aspects relevant of the product life cycle?It should be taken into account the product/service life cycle in order to identify the features and the proper and relevant criteria to the labels and environmental claims or to determine the relevance of the environmental claim. This doesn’t necessarily mean that it should undertake a life cycle evaluation.

4.7.1 Does the labels and environmental claims avoid to inhibit the innovation that allows the maintenance or the improvement of the environmental performance?

4.7.2 Are the requirements described in terms of performance rather than description features or

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14021 DescriptionComment(Compliant or description of the finding)

Conclusion

design features?It should be avoided prescriptive design criteria or the implicit preference for a technology, because of the possibility to limit or discourage improvements to products and services that affect the conformity to the environmental applicable criteria or that could take to a relevant environmental improvement.

4.8.1

Are all the administrative requirements or the requests of the information related to labels and environmental claims limited to what is needed to determine the compliance to the requirements and to the criteria to the applicable rules for the labels and for the declarations?

4.10.1Are the information related to the environmental aspects of products and services, relevant to a label or to an environmental claim made available to buyers and potential buyers of the label or environmental claim developer?

4.10.2 Are the information provided adequate and sufficient for the type and the scope of the environmental claim performed?

UNI EN ISO 14021 - 5 - REQUIREMENTS APPLICABLE TO ALL SELF-DECLARED ENVIRONMENTAL CLAIMS

5.3 – VAGUE OR NOT SPECIFIC CLAIMS

5.3

Is the environmental claim not specific and not vague, in a way do not imply that a product is environmentally beneficent or environmentally benign?Environmental assertions such as “environmentally safe”, “environmentally friendly”, “earth friendly”, “non-polluting”, “green”, “nature’s friend”, “ozone friendly” shall not be used.

5.4 – CLAIMS OF “…FREE”

5.4Is the environmental claim “….free” only made when the level of the specified substance is no more than that which would be found as an acknowledged trace of contaminant or background level?

5.5 – CLAIMS OF SUSTAINABILITY

5.5 Has it been avoided to use claims related to the achieving of the sustainability?

5.6 – USE OF EXPLANATORY STATEMENTS

5.6 In case of self-declared environmental claims that are likely to result in misunderstanding, are those claims accompanied by an explanatory statement?An environmental claim must be issued without an explicit declaration just in case it’s valid in all the

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14021 DescriptionComment(Compliant or description of the finding)

Conclusion

foreseen circumstances without any limitations.

5.7 – SPECIFIC REQUIREMENTS

5.7a Are the environmental claims and their explanatory statements accurate and not misleading?

5.7b Are the environmental claims and their explanatory statements substantiated and verified?

5.7c Are the environmental claims and their explanatory statements relevant to that particular product and used just in an appropriate context or setting?

5.7dAre the environmental claims and their explanatory statements presented in a manner to clearly indicate whether the claim is applicable to the complete product or only to a product component or packaging, or to an element of the service?

5.7e Are the environmental claims with their explanatory statements specific for what concern the environmental aspect or the environmental improvement which is claimed?

5.7fHas it been avoided that the environmental claims with their explanatory statements are restated using different terminology to imply multiple benefits for a single environmental change?

5.7g Has it been avoided that environmental claims with their explanatory statements are unlikely to result in misinterpretation?

5.7h

Are the environmental claims with their explanatory statements true not only in relation to the final product but also take into consideration all relevant aspects of the product life cycle in order to identify the potential for one impact to be increased in the process of decreasing another?This doesn’t necessarily mean that a life cycle assessment should be undertaken.

5.7iAre the environmental claims with their explanatory statements presented in a manner which does not imply that the product is endorsed or certified by an independent third party organization when it is not?

5.7j

Has it been provided to avoid that the environmental claims with their explanatory statements suggest an environmental improvement which does not exist?

Has it been provided to avoid that the environmental claims with their explanatory statements exaggerate the environmental aspect of the product to which the claim relates?

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14021 DescriptionComment(Compliant or description of the finding)

Conclusion

5.7kHas it been provided to avoid to use the environmental claims with their explanatory statements if, despite the claim being literally true, it is likely to be misinterpreted by purchasers or is misleading through the omission of relevant facts?

5.7lAre the environmental claims with their explanatory statements only related to an environmental aspect that either exists or is likely to be realized, during the life cycle of the product?

5.7m

Are the environmental claims with their explanatory statements presented in a manner that clearly indicates that the environmental claim and its explanatory statement should be read together?

Is the explanatory statement be of reasonable size and in reasonable proximity to the environmental claim it accompanies?

5.7n

In case in which the environmental claims are comparative assertions of environmental superiority or improvement is made, are the environmental claims specific and is made clear the basis for the comparison?

Is the comparative environmental claim relevant in terms of how recently have been made any improvement?

5.7o

In case that the environmental claims with the explanatory statements are based on a pre-existing aspect but previously undisclosed aspect, are the environmental claims presented in a manner that does not lead purchasers, potential purchasers and users of the product to believe that the claim is based on a recent product or process modification?

5.7pHas it been provided to avoid that the environmental claims with their explanatory statement are based on the absent of ingredients or features which have never been associated with the product category?

5.7qAre the environmental claims with their explanatory statements reassessed and updated as necessary to reflect changes in technology, competitive products or other circumstances that could alter the accuracy of the claim?

5.7r Are the environmental claims with their explanatory statements relevant to the area where the corresponding environmental impact occurs?A claim related to a process can be made anywhere, so long as the environmental impact occurs in the area where the production process is located. The size of the area will be determined by the

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Conclusion

nature of the impact.

5.8 – USE OF SYMBOLS TO MAKE ENVIRONMENTAL CLAIMS

5.8.2

Are the symbols used for performing the self-declared environmental claim simple, easily reproducible and capable of being positioned and sized to suit the product to which the symbol is likely to be applied?The use of the symbol is optional in the self-declared environmental claims.

5.8.3 Are the symbols used for a type of environmental claim easily distinguishable from other symbols, including the symbols for other environmental claims?

5.8.4Has a symbol used to express implementation of an environmental management system been used in such a way that it could be misunderstood as an environmental symbol indicating the environmental aspects of a product?

5.8.5

Are the natural objects be used only if there is a direct and verifiable link between the object and the benefit claimed?There are many advantages to be gained by the use of the same symbol to denote the same environmental aspect on competing products. As new symbols are developed, claimants are encouraged to adopt a consistent approach and not to discourage the use of the same symbol to denote the same environmental aspect by others. In selection of a new symbol, due consideration should be given so as not to violate the intellectual property rights (e.g. registered designs) of third parties.

5.9 - OTHER INFORMATION OR CLAIMS

5.9.2

Has it been avoided to use words, numbers or symbols used for non-environmental claims purposes in a manner that is likely to be misunderstood as making an environmental claim?Words, numbers or symbols may be used in addition to environmental symbols to communicate information such as material identification, disposal instructions or hazard warnings.

5.9.3 Has it been avoided to modify an environmental symbol to relate the symbol to a specific brand, company or corporate position?

5.10 – SPECIFIC SYMBOLS

5.10.1 Has it been avoided to use specific symbols (wide recognized at international level) in a manner to imply that the environmental claims represented by these symbols are superior to other environmental claims?

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Conclusion

Example the Mobius loop symbol.

5.10.2.1

Whenever it’s used, does the Mobius cycle symbol design meet the graphical requirements for ISO 7000 (Symbol n. 1135)?

Is there a sufficient contrast so that the symbol is clear and distinguishable?

5.10.2.2Has the Mobius cycle, if used, been applied to the product or to the packaging?If there is any potential for confusion about whether it applies to the product or to the packaging, is the symbol accompanied by an explanatory statement?

5.10.2.3 If the symbol is used for claims of recyclable or recycled content, then does that symbol respect the requirements at point 7.7 and 7.8?

5.10.2.4 Is the Mobius cycle used just for claims of recycled content and recyclable, as described at point 7.7 and 7.8?

UNI EN ISO 14021 - 6 – EVALUATION AND CLAIM VERIFICATION REQUIREMENTS1

6.2 - RELIABILITY OF EVALUATION METHODOLOGY

6.2.1 Prior to making a claim, have evaluation measures been implemented to achieve reliable and reproducible results necessary to verify the claim?

6.2.2

Is the evaluation fully documented and the documentation retained by the claimant for the purpose of the information disclosure referred to 6.5.2?

Is this documentation retained for all the period that the product is on the market and for a reasonable period thereafter, taking into account the life of the product?

6.3 - EVALUATION OF COMPARATIVE CLAIMS

6.3.1 Have the comparative claims been evaluated against one or more of the following? :- an organization’s own prior process;- an organization’s own prior product;- another organization’s process or- another organization’s product?

1 The claimant shall be responsible for the evaluation and provision of data necessary for the verification of self-declared environmental claims.

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Conclusion

Has the comparison been made just using an published standard or a recognized test method (as set out in 6.4) and against comparable products serving similar functions, provided by the same or another producer, currently or recently in the same marketplace?

6.3.2

Are the comparative claims involving the environmental aspects of product’s life cycle:- quantified and calculated using the same units of measurement? - based on the same functional unit? and- - calculated over an appropriate time interval, typically 12 months?

6.3.3

Are the comparative claims be based on one of these 2 following aspects?:a) percentages orb) absolute (measured)

In case it has been used percentages, are the comparative claims expressed as absolute differences?Example: for a change from 10% to 15% recycled content, the absolute difference is 15% - 10% = 5%, in which case a claim of an additional of 5% recycled content could be made; however, a claim of 50% increase, while accurate, could be misleading.

In case it has been used absolute (measured) values, has it been expressed as relative improvements?Example: for an improvement that results in a product lasting 15 months instead of the previous of 10 months, the relative difference is (15 months – 10 months) / 10 months x 100 = 50% in which case, a claim of 50% longer life could be made. If one of the values is nil, the absolute difference should be used.

6.3.4 Has the claim been worded to be clear that it is a claim of absolute difference and not a claim of relative difference?

6.3.5 Are the improvements related to a product and to its packaging be stated separately and not aggregated?

6.4 – SELECTION OF METHODS

6.4 Does the methods for evaluation and claim verification follow, in order of preference, International Standards, recognized standards that have international acceptability (these may include regional or national standards)

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Conclusion

or industry or trade methods which have been subjected to peer review?If there are no methods already in existence, a claimant may develop a method, provided it meets the other requirements of clause 6 and is available for peer review.

6.5 - ACCESS TO INFORMATION

6.5.1Has a self-declared environmental claim been verified without access to confidential business information?Claims shall not be made if they can only be verified by confidential business information.

6.5.2

If not voluntary release to the public the information necessary for verification of an environmental claim, does the claimant foreseen the disclosure the claim, upon request, at a reasonable cost (to cover administration), time and place, to any person seeking to verify the claim?

6.5.3

Are the following minimum information, documented and retained in compliance to the point 6.2 of the standard?a) identification of the standard or method used;b) documentary evidences if verification of the claim cannot be made by testing the

finished product;c) test results, where these are necessary for claim verification;d) if testing is carried out by an independent party, the name and address of the

independent party;e) evidence that the claim is in compliance to requirements of 5.7h and 5.7r;f) If the self-declared environmental claim involves a comparison with other products,

then a description of the method used, the results of any tests of those products and any assumptions made shall be clearly stated;

g) Evidences that the claimant’s evaluation gives assurance of the continuing accuracy of the self-declared environmental claim during the period over which the product is on the market and for a reasonable period thereafter, taking into account the life cycle of the product

UNI EN ISO 14021 - 7 – SPECIFIC REQUIREMENTS FOR SELECTED CLAIMS2

7.2 - COMPOSTABLE

2 It is not intended to imply that the claims at point 7 are superior to other environmental claims. The principal reason for their selection has been their current or potential wide use, no their environmental importance. These claims can be applied, where relevant, to the stages of manufacturing and distribution, product usage and product recovery and disposal.

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14021 DescriptionComment(Compliant or description of the finding)

Conclusion

7.2.1Has the word “compostable” been used to indicate a characteristic of a product, packaging or associated component that allows it to biodegrade, generating a relatively homogeneous and stable humus-like substance?

7.2.2.1

Has it been avoided to use a compostability claim for a product or a packaging or a component of a product or packaging that:a) negatively affects the overall value of the compost as a soil amendment;b) release substances in concentrations harmful to the environment at any point during

decomposition or subsequent use; orc) significantly reduces the rate of composting in those systems in which the product or

component is likely to be composted?

7.2.2.2

Are all the compostability claims clearly qualified as follow?a) the claim shall specify whether the type of composting facility or process in which the

identified component is compostable a home-composting facility or an on-site or central composting facility, unless the product is compostable in all types of composting facilities, in which case no qualification is necessary

b) if the entire product is not compostable, the claim shall identify specifically which components are compostable. If the user of the product is required to separate those components, clear direction on how to do so shall be provided

c) If problems or risks are associated with introducing the product into either a home-composting facility or on-site or central composting facilities, then the claim shall identify which of these types of facility are capable of composting the product.

7.2.2.3

In case that a compostability claims refers to home composting, have it been applied the following additional requirements? :a) If significant preparation or product modification is necessary to ensure satisfactory

compostability, or if significant additional treatment of the finished compost is requested as a direct result of the composting of the product or component, the compostability claim shall not be made.

b) If home composting of the product or component would require materials, equipment (other than a composting unit) or specialized skills that are unlikely to be available in most households, the claim of home compostability shall not be made.

7.2.2.4 In case that a compostability claim is dependent on processes or facilities other than home composters, has it been applied what follow:a) Such facilities for the purpose of composting the product or packaging shall be

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conveniently available to a reasonable proportion of purchasers, potential purchasers and users where the packaging or product is sold.

b) If such facilities are not conveniently available to a reasonable proportion of purchasers, potential purchasers and users of the product, explanatory statements shall be used which are adequate to convey the limited availability of these facilities.

c) General qualifications, such as “Compostable where facilities exist”, which do not convey the limited availability of facilities are not adequate.

7.2.3 Has the evaluation been undertaken in accordance to clause 6?

7.3 - DEGRADABLE

7.3.1

Has the term “degradable” been used to indicate a characteristic of a product or packaging that, with respect to specific conditions, allows it to break down to a specific extent within a given time?Degradability is a function of susceptibility to changes in chemical structure. Consequent changes is physical and mechanical properties lead to the disintegration of the product or material.

7.3.2.1

Have the degradability claims been made just in relation to a specific test method that includes maximum level of degradation and test duration?

Are the degradable claims relevant to the circumstances in which the product or packaging is likely to be disposed?

Has it been avoided to associate a degradable claim for a product or a packaging, or for a component of a product or packaging, that release substances in concentrations harmful to the environment?

7.3.3 Has the evaluation been undertaken in accordance to clause 6?

7.4 – DESIGNED FOR DISASSEMBLY

7.4.1

Has the term “designed for disassembly” been used to indicate a characteristic of a product’s design that enables the product to be taken apart at the end of its useful life in such a way that allows components and parts be reused, recycled, recovered for energy or, in some other way, diverted from the waste stream?

7.4.2.1 Has a claim of designed for disassembly been accompanied by an explanatory statement that specifies the components or parts to be reused, recycled, recovered for energy or, in

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some other way, diverted form the waste stream?

7.4.2.2 If a claim of designed for disassembly accompanies another claim, such as a claim of recyclable, have the other requirements applying to the other claim also be followed?

7.4.2.3Does all the claims that a product is designed for disassembly specify whether the disassembly is to be done by a purchaser or user, or whether it is to be returned for disassembly by specialists?

7.4.2.4

If a special process is required to disassemble the product, then has it been applied what follows?a) Collection or drop-off facilities shall be available to a reasonable proportion of

purchasers, potential purchasers and users of the product where the product is sold.b) If such facilities are not conveniently available to a reasonable proportion of

purchasers, potential purchasers and users of the product, explanatory statements shall be used which are adequate to convey the limited availability of these facilities.

c) General qualifications, such as “Can be disassembled where facilities exist”, which do not convey the limited availability of facilities are not adequate.

7.4.2.5 Have the products designed for disassembly by the purchaser, potential purchaser or user of the product been accompanying information on disassembly tools and methods used?

7.4.2.6

Have a claim that a product is designed to be disassembled by the purchaser, potential purchaser or user of the product been made if:a) Specialized tools or expertise are not required andb) Clear information on the method of disassembly and reuse, recycling, recovery or

disposal of the parts is provided?

7.4.2.7 Have the products designed for disassembly by specialists accompanying information on equipment and facilities needed to carry out the disassembly?

7.4.3 Has the evaluation been undertaken in accordance to clause 6?

7.5 – EXTENDED LIFE PRODUCT

7.5.1Has the term “extended life product” been used to indicate a product designed to provide prolonged use, based on either improved durability or an upgradability feature, hat results in reduced resource use or reduced waste?

7.5.2.1 Have all claims regarding extended life been qualified?

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As extended life claims are comparative claims, are the requirements at point 6.3 met?

7.5.2.2

Where a claim of extended life is based upon an upgradability feature, have specific information on how to achieve the required upgrade been provided?

Has it been available an infrastructure to enable upgrading?

7.5.2.3Do the extended life claims that are based on the improved durability of the product state the extended life period or the percentage improvement and the measured value (e.g. repetitive number of operations before breakage) or reasoning that supports the claim?

7.5.3 Has the evaluation been undertaken in accordance to clause 6?

7.6 – RECOVERED ENERGY

7.6.1

Has the term “recovered energy” been used to indicate a characteristic of a product that has been made using energy recovered from material or energy that would have been disposed of as waste but instead has been collected through managed processes?In this context, the product can be the recovered energy itself.

7.6.2

Does the energy used satisfy the following qualifications?a) Energy recovery from waste materials refers to the collection and conversion of waste

material into useful energy. This includes any collection and conversion b) Before a claim of recovered energy can be made, the claimant shall ensure that

adverse effects on the environment resulting from this activity are managed and controlled

c) The type and quantity of waste that has been used for recovery shall be stated and has it been evaluated for compliance to paragraph 7.6.3?

7.6.3 Has the evaluation been performed for compliance to point 6?

7.6.3 Has the evaluation of recovered energy been calculated using the following method?a) The claim shall only be made if R – E > 0b) A claim of net recovered energy shall be expressed as follows:

Net recovered energy (%) = ((R – E) / ((R – E) + P)) * 100Where P is the amount of energy from primary sources used in the manufacturing process to produce the product; R is the amount of energy resulting from the energy recovery process; E is the amount of energy from primary sources used in the energy recovery process to recover or

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extract the recovered energy.

7.7 – RECYCLABLE

7.7.1

Has the use of term “Recyclable” been used to indicate a characteristic of a product, packaging or associated component that can be diverted from the waste stream through available processes and programmes and can be collected, processed and returned to use in the form of raw materials or products?Material recycling is only one of a number of waste-prevention strategies. The choice of a particular strategy will depend on circumstances and account should be taken of differing regional impacts in making this choice.

7.7.2

If collection or drop-off facilities for the purpose of recycling the product or packaging are not conveniently available to a reasonable proportion of purchasers, potential purchasers and users of the product in the area where the product is sold, then has the following been applied? :A qualified claim of recyclability shall be used The qualified claim shall adequately convey the limited availability of collection facilitiesGeneralized qualifications, such as “Recyclable where facilities exist”, which do not convey the limited availability of collection facilities are not adequate.

7.7.3.2If a symbol is used for a recyclable claim, has the Mobius loop as described in paragraph 5.10.2 been used?When a recyclable claim is made, the use of a symbol is optional.

7.7.3.3 Is the Mobius loop, as described in paragraph 5.10.2, without a percentage value be taken to be a recyclable claim?

7.7.3.4 In case an explanatory statement has been used, is it compliant to what reported at 5.6?

7.7.3.5Does the explanatory statement include material identification?(optional)

7.7.4 Has the evaluation been undertaken in accordance with clause 6?

Does the information referred to in 6.5 include evidences of the following:a) The collection, sorting and delivery systems to transfer the materials from the source

to the recycling facility are conveniently available to a reasonable proportion of the

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purchasers, potential purchasers and users of the product;b) The recycling facilities are available to accommodate the collected materials.c) The product for which the claim is made is being collected and recycled?

7.8 – RECYCLED CONTENT

7.8.1.1

Has the use of term “Recycled content” and its associated terms been interpreted as follows:Recycled content – proportion, by mass, of recycled material in a product or packaging. Only pre-consumer and post-consumer materials shall be considered as recycled content, consistent with the following usage of terms.Pre-consumer material – Material diverted from the waste stream during a manufacturing process. Excluded is reutilization of materials such as rework, regrid or scrap generated in a process and capable of being reclaimed within the same process that generated it.Post-consumer material – Material generated by households or by commercial, industrial and institutional facilities in their role as end-users of the product which can no longer be used for its intended purpose. This includes returns of material from the distribution chain.Recycled material – Material that has been reprocessed from recovered (reclaimed) material by means of a manufacturing process and made into a final product or into a component for incorporation into a product.Recovered (reclaimed) material – Material that would have otherwise been disposed of as waste or used for energy recovery, but has instead been collected (reclaimed) as a material input, in lieu of new primary material, for a recycling or a manufacturing process?For the purposes of this International Standard, the expressions “recovered material” and “reclaimed material” are treated as synonyms; however, it is recognized that, in some countries, one or other of these expressions may be preferred for this application.

7.8.1.2

Has it been taken into consideration the fact taht a higher percentage of recycled content does not necessarily imply a lower environmental impact?Because of this, the recycled content claim, in particular, should be used with discretion. Material recycling is only one of a number of waste-prevention strategies. The choice of a particular strategy will depend on circumstances and account should be taken of differing regional impacts in making this choice.

7.8.2.1 Where a claim of recycled content is made, has the percentage of recycled material been stated?

7.8.2.2 Has the percentage recycled content of products and packaging been separately stated

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and not aggregated?

7.8.3.2

If a symbol is used for a recycled content claim, has it been used the Mobius loop accompanied by a percentage value stated as “X %”, where X is the recycled content expressed as a whole number calculated in accordance with 7.8.4?The use of a symbol is optional.

Has the percentage value been located either inside the Mobius loop or outside and immediately adjacent to the Mobius loop?

7.8.3.3 If the percentage recycled content is variable, has this been expressed with statements such as “at least X%” or “greater than X%”?

7.8.3.4 In case it has been used an explanatory statement, has it been respected what is requested at 5.6?

7.8.3.5 Where a symbol is used, has it been accompanied by material identification? (optional)

7.8.4.1

Has the evaluation been performed according to the point 6?

Has the recycled content been expressed quantitatively as a percentage, calculated as shown below?

X (%) = (A/P) * 100Where X is the recycled content, expressed as a percentageA is the mass of recycled materialP is the mass of product.As there are no methods available for directly measuring recycled content in a product or packaging, the mass of material obtained from the recycling process after accounting for losses and other diversions, shall be used.

7.8.4.2 Has the purchasing documentation and other available records been acquired in order to verify the source and the quantity of recycled materials?

7.9 – REDUCED ENERGY CONSUMPTION

7.9.2.1 Has the term “Reduced energy consumption” been used to indicate a reduction in the amount of energy associated with the use of a product performing the function for which it was conceived when compared with the energy used by other products performing an

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equivalent function?Claims of reduced energy consumption are commonly expressed as energy-content, energy-conserving or energy-saving.

7.9.2.2

Are the claims for reduced energy consumption based on the reduction in energy consumption in the use of products and delivery of services?

Do the claims for reduced energy consumption avoid to include the reduction of energy in the processes used to manufacture the product?

7.9.3

Has the evaluation been undertaken in accordance with clause 6?

Has the reduced energy consumption been measured in accordance with established standards and methods for each product?The average value should be calculated by statistical processing.

7.9.3 Is the selection of methods in accordance with 6.4?

7.10 – REDUCED RESOURCE USE

7.10.1

Is the term “Reduced resource use” used to indicate a reduction in the amount of material, energy or water used to produce or distribute a product or packaging or specified associated component?Resources include energy and water resources in addition to raw materials.

7.10.2.2 Are all the claims regarding reduced resource use be qualified?

7.10.2.3 Are the reductions in resource use for products and packaging separately stated and not aggregated?

7.10.2.4Are the reduced resource use claims expressed in terms of reduction percentage (%)?

As reduced resource use id a comparative claim, is the requirement of 6.3 met?

7.10.2.5 If reduced resource use claims are made, is the type of resource stated in an explanatory statement?

7.10.2.6 If an increase in the consumption of other resources occurs as a result of a claimed reduction of resource use, the increased resource and the percentage have been stated in

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an explanatory statement?When a resource reduction has been achieved, for an initial twelve-month period, a claim may be based on an estimated calculation of reduced resource based on the design or distribution of products or production process.

7.10.2.8 Has a change in resource use be expressed separately for each resource?

7.10.3

Has the evaluation been performed according to point 6?

With the exception of what allowed in 7.10.2.7, is the consumed resource per production unit been obtained by dividing the gross input of resources during a twelve-month period by the gross production in the same twelve-month period?

7.10.3

Has the reduced resource use rate percentage (U%) been obtained by the following formula?

U (%) = ((I – N) / I) * 100Where U is the reduced resource use per production unit, expressed as a percentageI is the initial resource use, expressed as consumed resource per production unitN is the new resource use, expressed as consumed resource per production unit

7.11 – REDUCED WATER CONSUMPTION3

7.11.1

Is the term “Reduced water consumption” used to indicate the reduction of water consumption associated with the use of a product performing the function for which it was conceived when compared with the amount of water used by other products performing an equivalent function?

7.11.2.1 Are all the claims regarding water efficiency or reduction be qualified? As reduced water consumption is a comparative claim, have the requirements of point 6.3 been met?

7.11.2.2

Are the reduced water consumption based on the reduction in water consumption in the use of the product?

Has it been avoided to include the water reduction in the manufacturing processes of the product?

3 Claims of reduced water usage are commonly expressed as water-efficient, water-conserving or water-saving.

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7.11.2.2

7.11.3

Is the evaluation done in compliance to the point 6?

Is the water consumption be measured in conformity to the standards and to the methods established for each product?The average value should be calculated by statistical processing.

Has the selection of the methods been performed in compliance to 6.4?

7.12 – REUSABLE AND REFILLABLE

7.12.1.1Has the term “reusable” been used to indicate a characteristic of a product or packaging that has been conceived and designed to accomplish within its life cycle a certain number of trips, rotations or uses for the same purpose for which it was conceived?

7.12.1.2

Has the term “Refillable” been used to indicate a characteristic of a product or packaging that cab be filled with the same or similar product more than once, in its original form and without additional processing except for specified requirements such as cleaning or washing?

7.12.2.1 Has it been avoided to claimed a product or a packaging as reusable or refillable unless the product or packaging can be reused or refilled for its original purpose?

7.12.2.2

Has a claim that a product or a packaging is reusable or refillable been performed just where:a) a programme exists for collecting the used product or packaging and reusing or

refilling it orb) facilities or products exist that allow the purchaser to reuse or refill the product or

package?

7.12.2.3 If programmes for collecting the used product or packaging, or facilities for the purpose of reusing or refilling it, are not conveniently available to a reasonable proportion of purchasers, potential purchasers and users of the product in the area where the product or packaging is sold, then has the following been applied?a) A qualified claim of reusability or refillability shall be usedb) The qualified claim shall adequately convey the limited availability of collection

programmes or facilities

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c) Generalized qualifications, such as “Reusable/refillable where facilities exist”, which do not convey the limited availability of collection programmes or facilities are not adequate.

7.12.3

Has the evaluation been undertaken in accordance with Clause 6?

Does the information referred to in 6.5 include evidence of the following:a) The product for which the claim is being made is being refilled or reused.b) That reuse or refilling facilities are available to accommodate the product for which the

claim is being made.c) The facilities required to reuse or refill the product are conveniently available to a

reasonable proportion of the purchasers, potential purchasers and users of the product?

7.13 – WASTE REDUCTION4

7.13.1Is the use of the term "waste reduction" used to indicate the reduction in the quantity (mass) of material entering the waste stream as a result of a change in the product, process or packaging?

7.13.2.1Have all claims regarding waste reduction been qualified?

As waste reduction is a comparative claim, have the requirements of point 6.3 been met?

7.13.2.4Do calculations of process waste reduction avoid to include in-process re-utilization of materials such as rework, regrind or scrap materials generated within the process and capable of being reused within the same process that generated it?

7.13.3Has the evaluation been undertaken in accordance with Clause 6?Reduced waste amount may be calculated from material balance sheets, as well as from the actual measurement of waste.

7.14 – RENEWABLE MATERIAL

4 Waste may include discharges to air and water as well as solid waste from manufacturing or treatment processes. Waste reduction of products and packaging may include reduction in waste generated in the production, distribution, use and disposal stages. Reduced waste claims may include not only the reduction in water content of solid waste but also the reduction in mass through waste treatment processes. Waste generators who transfer wastes to other users that intend to utilize the waste for a constructive purpose, other than to put it into the waste stream, may make a claim of waste reduction.

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7.14.1 Is the use of the term "renewable material" used to indicate the material that is composed of biomass from a living source and that can be continually replenished?

7.14.2

When claims of renewability are made for virgin materials, has it been verified that those materials come from sources that are replenished at a rate equal to or greater than the rate of depletion?

Has an unqualified claim of renewability been made only when the product consists of 100 % renewable material? (allowing for de minimis amounts of non-renewable materials being contained in that material)

7.14.2

Otherwise, have renewability claims been qualified as follows:a) where a claim of renewable material content is made, the percentage by mass of

renewable material to the total mass has been stated;b) the percentage of renewable material content (mass fraction) for products and

packaging has been separately stated and it hasn’t been aggregated.

Are all renewable claims compliant with all other requirements of this International Standard?

Has the onus on a claimant not been diminished by substituting like terms to follow the principles set out in clause 7.14.2?

7.14.3 Has the evaluation been undertaken in accordance with Clause 6?

7.15 – RENEWABLE ENERGY5

7.15.1

Is the use of the term "renewable energy" used to indicate the energy derived from sources that are non-exhaustible or capable of continuous replenishment?

Have claims of renewability for energy sources associated with movements of water been made only if they are from sources that are managed in accordance with the principles of sustainable development?

5 Renewable energy sources include, but are not limited to, sunlight and wind energy. They also include biomass and geothermal sources that conform with clause 7.14. Particular care is needed when making a claim for a product or process relating to use of electrical energy from the grid, when that electrical energy is claimed to contain a percentage of renewable energy.

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7.15.2

Has an unqualified claim for renewable energy been made only when 100 % of the energy supply is renewable?Otherwise, renewable energy claims shall be qualified.

Where a proportion of the energy supply is from renewable sources, has the percentage been clearly stated?

Are all renewable energy claims compliant with all other requirements of this International Standard?

7.15.2 Has the onus on a claimant not been diminished by substituting like terms to follow the principles set out in clause 7.15.2?

7.15.3 Has the evaluation been undertaken in accordance with Clause 6?

7.16 – SUSTAINABLE

7.16.1Have self-declared claims of achieving sustainability been avoided?

Has using unqualified claims of "sustainable" and "sustainability" been avoided?

7.16.1

When using a qualified claim of "sustainable", "sustainability" or "sustainable development", is any portion of that claim that relates to an environmental aspect conform to this International Standard?The term "sustainable" can be used in third-party verified schemes, such as those related to forestry and fisheries, but such schemes are outside the scope of this International Standard.

7.17 – CLAIMS RELATING TO GREENHOUSE GAS EMISSIONS

7.17.2 – PRODUCT "CARBON FOOTPRINT"

7.17.2.1 Is the use of the term "carbon footprint" used to indicate the net amount of GHG emissions during the life cycle of the product? (It also includes long-term net removals of CO2)

7.17.2.2 Has the quantification and communication of a product "carbon footprint" been carried out in accordance with ISO/TS 14067?

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7.17.3 – “CARBON NEUTRAL”6

7.17.3.1Is the use of the term "carbon neutral" used to indicate a product (as a product system) that has a "carbon footprint" of zero or a product with a "carbon footprint" that has been offset?

7.17.3.2

Have all the GHG emissions from all stages of the product life cycle, and within the specified product system, been reduced, removed or accounted for through a system of offsets or credits, or by other means?

Has an unqualified claim of "carbon neutral" been avoided?

7.17.3.3

Do "Carbon neutrality" claims include:a) a statement that the product "carbon footprint" is zero; orb) a clear statement about which elements of the product life cycle have been offset?

Are claims of "carbon neutrality" involving offsets also qualified with a statement that declares the product "carbon footprint" and clearly explains what has been offset, providing full details of the offset scheme used and information that enables the purchaser to access sources of further information explaining the offset programme?

Are all carbon neutral claims compliant with all other requirements of this International Standard?

Has the onus on a claimant not been diminished by substituting like terms to follow the principles set out in clause 7.17.3.3?

7.17.3.4

Is determination of "carbon neutrality" based on, first, the calculation of a carbon footprint, then the deduction of offsets equivalent to the emissions of the carbon footprint?

Alternatively, has carbon neutrality been achieved by a product whose "carbon footprint" is zero?

6 It is advisable that an organization give preference to achieving carbon neutrality through the strategies of prevention and reduction of its own emissions and substitution of renewable energy sources for fossil energy sources. Acquisition of carbon offsets can be used to compensate for remaining emissions.

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Table 2 – Findings Resolution

N.° Responses from the Organization Conclusions Status

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