For the intent of the Carbon Footprint (both product and organization), only self-consumed energy (quantified as PV energy) must be considered, as that sold to the grid goes into the national energy mix.
Yes, the verification statement issued by an accredited third-party body shall be made available and published in each registration data sheet.
No, the standard ISO 14067 stresses that “Carbon offsetting and communication of CFP or partial CFP information are outside the scope of this document”.
This concept is reiterated/reaffirmed also:
No, it is not possible to allocate these benefits only to a specific product, but they must be distributed over the entire production in accordance with the allocation procedures of the study, as these inputs are to be considered as pertaining to the entire production of the plant in question.
In other words, where the GOs purchased do not cover the entire plant's electricity consumption, it will be necessary to fairly consider, on the basis of the study's specific allocation procedures (e.g. mass or economic) the benefit derived from this share of GOs for all the goods produced at the site, and it will in no way be possible to go so far as to attribute 100% of GOs to some products and 0% to others.
In this regard, we are aware that the ISO 14040/14044 and ISO 14067 standards may lead to different interpretations on this and other points of the CFP studies, but in order to avoid an inconsistent approach, Carbon Footprint Italy has chosen to consider only the more conservative approach described above as acceptable, in order to ensure more comparable and credible results.
In case of coexistence of several PCRs, the Programme Operator Carbon Footprint Italy recognized the PCR from both the International EPD® System and EPDItaly. Otherwise, PEFCRs can also be accepted, after been evaluated by the Technical-Scientific Committee (TSC) of the CFI.
The CFP SA is outlined in the Annex C of the ISO 14067:2018. The section C.3.4 “Validation of the CFP systematic approach”, specifies that organizations shall conduct “internal CFP systematic approach assessments at planned intervals, to ensure its continuous suitability, adequacy and effectiveness”.
The goal of this is clearly that, through an internal control, the organisation can guarantee that the systematic approach (CFP SA) keeps being able to ensure the expected outcomes.
The internal audit can thus be considered to be a possible strategy to perform such evaluation, but it cannot be considered the only one.
Nevertheless, the interpretation that sees the internal audit as compulsory before the realization of the third-party verification is not by any means acceptable. This interpretation is to be justified through the experience of verification bodies in the environmental management system. In fact, in accordance to the ISO 17021-1, they include as objective of Stage 1 “to evaluate if the internal audits and management reviews are being planned and performed” (section 9.3.1.2.2 g); in addition, it is specified that during Stage 2 the internal audit and management review have to be revised (section 9.3.1.3 e).
Such requirements are not mentioned in the standards that are currently in force for the accreditation of GHG validation/verification activities (ISO 14064-3 e ISO 14065), nor in the generic standard for validation/verification activity as conformity assessment (ISO 17029), nor in the future revision of the ISO 14065. This is due to the fact that all the mentioned activities are intrinsically different from the certification of environmental management systems.
Therefore, in the GHG accreditation system of verification there is no instruction requiring the realization of an internal audit before the third-party verification.
The ISO 14067 describes in detail how to manage the uptake of CO2 in biomass in ‘cradle-to-grave’ studies. In fact, at paragraph 6.5.2, it requires that “Removals of CO2 into biomass shall be characterized in the LCIA as -1kg CO2e/kg CO2 in the calculation of the CFP when entering the product system. Emissions of biogenic CO2 shall be characterized as +1 kg CO2e/kg CO2 of biogenic carbon in the calculation of the CFP”. This implies the will of the standardizer to ensure that the benefit of the removal (uptake) of CO2 from biogenic processes is balanced by the emission that takes place in the end-of-life phase.
The standard is very precise in indicating when the requirements are also applicable to partial CFP studies. Since this case is not specified in this paragraph, the requirement 6.5.2 shall be understood as applicable only to ‘full’ CFP studies.
The standardizer has therefore not specified, in paragraph 6.5.2, what type of characterization shall be applied for uptake in ‘cradle-to-gate’ studies, and hence – since the partial CFP is not mentioned – it is believed that this “removal” should not be characterized in these studies.
On the other hand, paragraph 6.4.9.3 requires that “Information on biogenic carbon content shall be provided when performing cradle to gate studies, as this information may be relevant for the remaining value chain”. This indicates the desire for a transparent communication along the value chain that allows, in cradle-to-gate studies, the downstream subjects to know the information relating to the uptake values.
In this way, who carries out a cradle-to-grave study starting from the information provided by the cradle-to-gate study, will be able to use it to specify the amount of carbon fixed in the uptake processes that will then be released in the end-of-life.
In fact, paragraph 6.4.9.3 also specifies that information on carbon content is not part of the CFP value: “If a product’s biogenic carbon content is calculated, it shall be documented separately in the CFP study report but it shall not be included in the result of CFP or partial CFP”.
To conclude, the characterization envisaged in paragraph 6.5.2 of ISO 14067 only applies to full CFP, while for partial CFP the uptake value shall not be characterized. However, the uptake value shall be documented and communicated as additional information in the study report, to facilitate the development of further cradle-to-grave CFP studies by customers.
CFI accepts the cradle to gate approach as far as the company specifies in the notes "please note that there is a deviation respect to the PCR".
Moreover, the company must explain why the end-of-life is not considered (in the event that the PCR requires the cradle to grave approach).
In upstream, if you know the data from the suppliers, it is correct to use the residual mix, while for downstream, not having exact consumer information would be more correct to enter the electricity mix value. Unless otherwise indicated by the PCR.
Yes, it is possible to apply the label directly on the means of transport (e.g. truck), as it constitutes the verified product.
Similar products made from the same organization whose impact differs by +- 10% can be presented in a single CFP registration.
Air emissions should be included if the raw materials of the finished product or the finished product itself are shipped by air and not the air emissions contained within the datasets.
Where the study is generically referred to a product, it is necessary that all the plants involved in that product system fall within the system boundaries of the study. Alternatively, it is possible to limit the study to the production in a single plant; however, the report and the attestation of conformity documents must clearly state the applicability of the CFP to the single site, and the explicit exclusion of the other sites where that production takes place.
The Program Operator Carbon Footprint Italy suggests to not reporting these emissions within the category 3.1. – Indirect emissions from up-stream transport and distribution for goods, neither in category 3.2 – Indirect emissions from down-stream transport and distribution for goods. Therefore, CFI recommends to account them in a dedicated category: category 3.6 – Indirect emissions from transport of third-party processing.
No, according to the reference ISO standard, the organization may select which and how many facilities to include within the organizational boundaries of the GHG inventory, according to paragraph 5.1 of the ISO 14064-1, and is not required to provide any justification concerning this decision.
The Programme Operator Carbon Footprint Italy accepts the following options:
By reduction actions we mean those actions undertaken by the organization to actually reduce GHG emissions, therefore through process innovation, actions along the supply chain, use of less impactful raw materials, etc.
From this point of view, the use of certificates of guarantee of origin could be subject to various interpretations, sometimes as an effective use of energy with a lower carbon intensity and in others as a simple financial mechanism. For this reason, the increase in the use of GO is considered a possible supplementary action of other reduction actions (and therefore accounted for in the overall reduction) in the CFP area, but not in exclusive terms. Therefore, reductions resulting only from a change of electricity supply in favor of a contract with only renewable energy are not accepted.
Obviously, in the case of the CFO, this action is in no way acceptable as only the location-based approach is applicable.
(Carbon Footprint of Product). Methodology based on a LCA study in order to assess the GHG emssions of a product within its whole life cycle, “from cradle to grave”.
(European Union Emissions Trading Scheme). Known as Emission Trading, this European cap and trade system is implemented by limiting the CO2 emissions of the organizations of certain industry sectors and by creating a European market where it is possible to buy and sell CO2 quota.
(Greenhouse Gas). Shortcut with which are identified on international level the greenhouse gases. Those comprise, beside CO2, methane (CH4), nitrous oxide (N2O) and a number of organohalogenated products from chemical synthesis.
(International Organization for Standardization) is an international standardization body composed by the network of national standardization bodies of 162 countries. The general secretary which coordinates the system is headquartered in Geneva.
(Life Cycle Assessment). Life cycle assessment of a product. Methodology underlying the CFP and based on the requirements of ISO 14040 and ISO 14044.
(Organization Sectorial Rules). Documents that provide the rules, requirements and guidelines for developing a CFO for a specific sector of an organisation.
(Product Category Requirements). Specific requirements of the product category envisaged by ISO 14025 for Type III environmental declarations.
